This input is provided by the eLiberare Association, a civil society organization working on preventing human trafficking and assisting victims of trafficking for over 12 years of experience in direct support, policy development, and cross-sector coordination in Europe and beyond.
Executive Summary
Across multiple contexts, persistent and evolving forms of the sale, sexual exploitation, and sexual abuse of children continue to emerge. While legal frameworks are often robust on paper, implementation gaps, chronic resource constraints, fragmented data systems, limited child-friendly procedures, and emerging digital threats undermine protection. Vulnerability is concentrated among children in or from alternative care, economically disadvantaged and marginalized communities, children with disabilities, children with substance use disorders, those affected by family separation due to migration, and children with multiple intersecting vulnerabilities.
We welcome the mandate’s focus on online-facilitated exploitation, survivor-centred approaches, and engagement with the private sector. However, greater emphasis is needed on measurable state implementation, private-sector accountability (especially in technology), ethically governed data, and meaningful survivor participation beyond consultation.
We propose:
- Minimum service guarantees and sustainable funding standards for child victims;
- A rapid cross-border child protection protocol and Identification & Referral Mechanism;
- Standardised frameworks across States for definitions, access to services, referral pathways, and case management;
- Expansion of identification of victims beyond law enforcement;
- Lowering the threshold for identification and shifting the burden of proof away from victims through harmonised indicators;
- Mandatory safe-by-design standards for digital platforms with strong enforcement;
- A global model for survivor participation and compensation mechanisms;
- Establishment of specialised multidisciplinary child protection centers;
- Designation of dedicated prosecutors for crimes involving child exploitation.
1. Gaps and Obstacles in Combating the Sale and Sexual Exploitation of Children
a) Child-centred implementation deficits
- Insufficient specialized services: Specialised centers (separated facility – apartment, etc) for children victims of human trafficking in each child protection sections specialised on children victims of human trafficking; lack of specialised psychotherapists.
- Fragmented pathways: Lack of risk screening, referral and case management vary by county, with specialized NGOs offering their services in this regard, such as eLiberare’s Kompass model of intervention.
- Delayed and re-traumatizing justice: Slow proceedings, limited use of child-friendly interviewing, and repeated statements undermine recovery and case outcomes.
b) Systemic obstacles
- Underfunded local services, due to major nation-wide institutional funding cuts.
- Staff turnover and training gaps: Social workers, police, and magistrates rotate frequently; there is lack of consistent continuous training on human trafficking indicators and reporting methods, digital-age exploitation, cultural competence, disability inclusion, and trauma-informed practices, despite several training sessions being delivered by specialized NGOs, such as eLiberare.
- Need to expand identification of child victims of human trafficking beyond law enforcement, and lower the threshold for identification and shifting the burden of proof from the vulnerable to prove their victimhood to effective standardisation of indicators.
c) Digital enforcement and prevention gaps
- Limited capacity for cyber-investigation: Backlogs in forensic analysis; inadequate tools for open-source intelligence (OSINT); insufficient cooperation channels with platforms for timely data preservation and takedowns.
- Age-appropriate design deficits: Children remain readily reachable by offenders; lack of efficient age verification requirements; default privacy is weak; reporting flows are complex.
- Moderation deficits: Entities still face a long and strenuous process to become recognized for reliably flagging illegal or harmful content to online platforms.
d) Inclusion and non-discrimination
- Roma children: Persistent discrimination lowers trust in authorities and service providers. Furthermore, child forced marriages continue to be a custom within the Roma community, although authorities are aware of their existence. Sometimes, cases involving these victims are thrown out.
- Children in/from alternative care: High exposure to grooming and the “loverboy” method; post-care support is minimal, and digital literacy programs are uneven.
- Children with disabilities: Accessibility barriers in reporting, interviewing and service delivery.
- Need for concrete, meaningful and efficient survivor engagement tools, such as survivor advisory groups for programs and public policy input.
e) Cross-border and administrative hurdles
- Slow mutual legal assistance for digital evidence and financial flows related to online exploitation; delays in recognizing protection orders or guardianship arrangements.
2) Are there any trends and emerging threats defining the scope and extent of the sale, sexual exploitation and sexual abuse of children especially in view of evolving global contexts?
a) Online-facilitated exploitation at scale. Blurred lines between trafficking and “consensual” online exchanges
- Sextortion and coerced self-generated content: Offenders use social engineering, deepfakes, and doxxing threats to coerce minors into producing content or paying.
- Livestreamed sexual abuse: Digital payment systems (including cryptocurrencies), and dark-web platforms have enabled offenders to commission and pay for abuse with relative anonymity.
- “Members-only” sites or groups on encrypted messaging apps promoting abusive practices towards children.
- Generative AI misuse: Synthetic CSAM created through the use of non-consensual sexualized deepfakes of minors.
- Adolescents may engage in transactional sexual exchanges initiated online under coercive conditions that do not fit neatly into traditional trafficking paradigms, complicating identification and eligibility for services.
b) Mobility and mixed-migration contexts
- Children on the move (including unaccompanied minors) face targeted online/offline recruitment, with rapid cross-border movement that outpaces traditional child protection cooperation.
How adequate are current systems and strategies in protecting children effectively against such threats?
Current systems are behind the curve:
- Child protection is still organized around place-based risks, not always around platform-based harms;
- Forensic and financial investigation capacity is overstretched;
- Remedies for synthetic CSAM are under-developed.
3) Please provide information on concrete actions, initiatives and programs in engaging with children, youth, child-led and/or youth-led organizations and networks in the fight against the sale, sexual exploitation and sexual abuse of children. Please explain to what extent such actions, initiatives and programmes inform national policies.
- eLiberare’s SafeON educational program. Since 2016, in partnership with the Ministry of Education, eLiberare has implemented a national anti-trafficking education program that equips teachers with tailored resources to facilitate open and effective discussions with students about the risks of human trafficking, as well as child exploitation, both offline and online, and practical safety strategies. Targeting children aged 7-18, the program has reached 4,600+ schools through strategic partnerships, involving 12,000 teachers and impacting approximately 140,000 students each year. The class materials are designed to help students recognize the warning signs of trafficking, understand how to protect themselves from related risks and vulnerabilities, and become aware of their rights and responsibilities in such situations. The educational package includes theoretical content, interactive sessions, and case studies inspired by real-life scenarios and cases supported by eLiberare’s assistance team. Building on this experience, eLiberare aims to scale up SafeON to influence national education policy, with the goal of embedding the program into the mandatory school curriculum, ensuring that all students receive structured education on trafficking and exploitation as part of their regular learning.
- Launched in 2022 with input from experts by experience, the award winning Kompass intervention model was initially developed as a targeted response to support Ukrainian refugees, including children, in Romania, and protect them from human trafficking and exploitation. The model is built around four interconnected steps that create protective barriers for people on the move:
- Community Coordination & Capacity Building: Building trust and equipping authorities, frontline workers, grassroots leaders and NGOs to respond to trafficking efficiently.
- Awareness Raising: Informing people on the move about signs of trafficking and exploitation.
- Vulnerability Assessments & Individualized Safety Plans: Identifying risks and creating tailored responses.
- Assistance & Referrals: Connecting survivors to accessible, needs-based referrals and resources.
Impact in the first 3 years: 4,382 refugees supported with individual safety plans, 19,000 people reached through 690 info-sessions, 1,980 frontline workers trained across 155 sessions, 101 institutional partnerships built, 626 refugees received legal counselling, services & tailored referrals, 2 victims of trafficking identified and supported, 1 million people reached via social media. What was initially developed as an urgent, localized intervention for refugees arriving in Romania, has since evolved into a globally relevant framework for protecting people on-the-move against trafficking and exploitation. Kompass has been deployed in the Republic of Moldova, Ukraine, Greece, and East Africa. Global results so far: 431 refugees reached with individual safety plans, 2,000+ informed through awareness sessions, 300 frontline workers trained, 37 partnerships forged. eLiberare aims to scale Kompass globally, providing an adaptable framework to protect displaced populations from trafficking and exploitation in conflict and crisis contexts.
- Through active participation in governmental working groups and contributions to parliamentary special commissions, the organization has consistently advocated for more effective legislation, improved prevention mechanisms, and a stronger regulatory framework. This has included publishing public policy positions, facilitating dialogue through multi-stakeholder roundtables, and engaging with key decision-makers.
4) How impactful has the mandate of the Special Rapporteur been in contributing to the fight against the sale, sexual exploitation and sexual abuse of children? What are some positive impacts of your/your Government’s engagement with the mandate? What are the gaps in the approach and implementation of the mandate? How can the impact of the mandate be further enhanced in the future?
From our perspective, the mandate of the Special Rapporteur has played an important normative and advocacy role in maintaining international visibility on the issues of child sale, sexual exploitation and sexual abuse. The reports and thematic guidance have provided a valuable reference framework for aligning national efforts with international standards, especially in areas such as online protection, child participation, and private-sector accountability. At national level, the mandate’s analyses and recommendations have indirectly supported initiatives on strengthening digital child protection, enhancing victim-centred approaches in policy and service provision. The thematic focus on online sexual exploitation and technology-facilitated abuse has been particularly relevant, as these issues are increasingly reflected globally in the child protection agenda.
Gaps identified:
- Limited national visibility: The mandate’s role and tools are not widely known among all relevant institutions, professionals or civil society, which limits opportunities for structured engagement or follow-up. More country visits or technical dialogue with national authorities could help identify specific priorities, raise awareness of the mandate’s scope, and promote inter-institutional coordination.
5) How impactful have the roles of child protection actors been?
In our experience, the impact of child protection actors in addressing the sale, sexual exploitation and sexual abuse of children has been mixed, showing significant progress in institutional capacity, but also persistent gaps in coordination, prevention, and victim support.
- Institutional Progress: Many States have strengthened legislative and institutional frameworks, aligned with the Lanzarote Convention, EU Directives, and global standards.
- Civil Society Leadership: NGOs play a critical role in identification, psychosocial support, legal aid, and prevention, but remain underfunded and project-dependent.
Persistent Gaps:
- Fragmented coordination within the National Referral Mechanism (NRM): Actors involved in the protection and assistance of child victims often operate independently, communicating through rigid institutional channels rather than through multidisciplinary team meetings. This approach undermines a victim-centered response.
- Insufficient training: Many specialists lack training on the NRM and trauma-informed practices, which reduces the effectiveness and quality of interventions.
- Shortage of specialized professionals and facilities: There is a lack of child psychotherapists specialized in trauma recovery, as well as a shortage of detoxification centers for teenagers. These gaps hinder recovery and reintegration, increasing the risk of revictimization and retrafficking.
- Specialized services for child victims of online exploitation are largely absent, with limited capacity for digital evidence collection and trauma-informed counseling.
- Many victims remain unidentified, especially among children in institutional care or those migrating within the EU.
- Lack of specialized centers dedicated exclusively to child victims of human trafficking. Existing centers accommodate both victims of abuse and abandoned children with mental health problems, making it nearly impossible to provide targeted interventions and specialized protection for trafficking victims.
- Absence of specialized department: a lack of a dedicated unit for cases involving child victims of trafficking. Professionals responsible for these cases manage all types of child abuse and neglect cases, resulting in high workloads and limited attention to trafficking-specific needs.
6. Accountability Measures
Accountability of private-sector actors, particularly in technology, travel, and financial industries, remains limited.
- Monitoring and enforcement are inconsistent, especially for smaller companies.
- Algorithmic transparency and data governance are underdeveloped.
- Stronger cross-sector collaboration and regulatory oversight are needed to ensure genuine accountability.
Regulation of platform accountability, data governance, and algorithmic transparency remains underdeveloped – particularly for SMEs operating outside public digitalisation initiatives. Similarly, most travel and tourism businesses are not subject to systematic reporting or external monitoring, as current regulations primarily target large firms or those engaged in public contracts.
Even where integrity frameworks exist, monitoring and enforcement capacity are weak, and compliance is often formal rather than substantive. Strengthening coordination, expanding oversight to smaller firms, and improving enforcement are essential to ensure genuine private-sector accountability.
7) How effective are current regional and international mechanisms in facilitating cross-border cooperation to combat the sale, sexual exploitation and sexual abuse of children? What forms of collaboration are further needed or should be strengthened?
Effective tools:
- Europol/Eurojust cooperation frameworks; cross-border case conferences; hotline networks.
Remaining challenges:
- Delays in data preservation and cross-border legal assistance.
- Lack of standardized referral mechanisms, definitions, and victim status recognition.
Recommendations:
- Develop bilateral and multilateral protocols for rapid identification and referral.
- Establish standardized case management, indicators, and service mapping across regions.
- Create an EU-level or regional cross-border child protection mechanism with designated focal points.
8) What are the current gaps in data collection and analysis on the sale, sexual exploitation and sexual abuse of children? What are child safeguarding considerations that should guide research and data collection involving child victims and survivors?
- Lack of harmonized data on victim identification, including by source (state or NGO).
- Limited data on ethnicity, disability, and intersectional vulnerabilities.
- Fragmented case management systems hinder monitoring and follow-up.
Safeguarding principles for research:
- Do-no-harm primacy: Research must never be prioritized over a child’s safety plan; immediate risk management takes precedence.
- Informed, ongoing consent tailored to age and evolving capacity; assent sought from the child with supportive, non-coercive explanations.
- Minimal data & purpose limitation: collect only what is necessary; avoid open-text fields that can inadvertently store identifying details.
- Child-friendly methods: trauma-informed interviewing, flexible pacing, and options to pause/withdraw; accessible formats for children with disabilities.
- Meaningful survivor engagement: a standing survivor ethics panel to review tools and debrief findings; fair compensation and support.
- Secure infrastructure: encrypted storage, access logs, strict role-based permissions, and data retention schedules.
- Feedback to participants in age-appropriate formats on what changed because they contributed.