STOP CSAM Act: Tech Giants Face $1M Fines, Victims Get Unlimited Time to Sue Platforms Over Exploitation

The Strengthening Transparency and Obligations to Protect Children Suffering from Abuse and Mistreatment Act of 2025, or the STOP CSAM Act, is a massive overhaul of how the federal government and tech companies handle child sexual exploitation. This bill isn’t just tweaking a few laws; it’s radically changing the rules for federal courts and putting serious compliance pressure—and financial risk—on every major online platform.

The Courtroom Gets a Needed Upgrade

For anyone involved in a federal case as a child victim or witness, this bill is a game-changer for protection. It significantly broadens the legal definitions of harm to include specific acts of “psychological abuse”—like isolating a child or withholding necessities to control them (Sec. 2). This means courts now have a much wider lens to recognize the non-physical damage done to kids. Crucially, the bill creates a presumption that publicly disclosing a child victim’s “protected information”—which covers everything from their name and email to medical records—is harmful. To get that information released, the other side has to prove a “compelling public interest” that outweighs the harm, which is a seriously high bar to clear (Sec. 2).

It also modernizes how kids testify. Outdated references to “videotape” are replaced with “video recording,” and if an adult attendant is near the child during testimony, that attendant must also be recorded as part of the court record. This aims to protect the integrity of the testimony while ensuring the child feels safe (Sec. 2).

Mandatory Restitution and the Trustee System

When it comes to financial justice, the bill mandates restitution for child pornography production offenses (Sec. 3). But the most practical change for victims is the creation of a trustee system for handling payments. If a victim is a minor, incapacitated, or a foreign citizen, the court can appoint a trustee to manage the restitution money in a trust or official account solely for the victim’s best interest (Sec. 3). This fixes a major problem where large restitution payments often went unmanaged or were difficult for vulnerable victims to access, ensuring the money actually helps the person it’s intended for. To fund this, the bill authorizes $15 million annually for the U.S. Courts to pay trustee fees (Sec. 3).

Tech’s New Accountability Checklist

This is where the bill hits the digital economy hard. Interactive computer services—think social media, hosting companies, and messaging apps—now have mandatory duties (Sec. 4). If a provider gets “actual knowledge” of child sexual exploitation occurring or sees “apparent child pornography,” they must report it to the CyberTipline (NCMEC) within 60 days. This report must include specific details like the user’s name, email, IP address, and account ID, if available.

Failing to report or preserve required material knowingly is now a crime with steep fines. Large providers (over 100 million monthly users) face fines up to $600,000 for a first offense, jumping to $1 million for subsequent violations if someone is harmed. Even civil penalties range from $50,000 to $250,000 for non-compliance (Sec. 4). This creates a huge new compliance burden, especially for mid-sized platforms that might struggle to implement the necessary reporting infrastructure.

Furthermore, large, profitable providers (over 1 million users and $50 million in revenue) must now submit annual reports to the Attorney General and FTC detailing their safety policies, the tools they use to prevent abuse, and the prevalence of CSAM on their services (Sec. 4). This level of mandatory public transparency is unprecedented and forces platforms to prioritize safety in their design and operations.

Unlimited Time to Sue the Platforms

Perhaps the most significant change for victims is the expansion of civil remedies (Sec. 5). Victims of certain serious crimes, even if the injury happened when they were minors, now have no time limit to file a civil lawsuit. This means survivors who spent years recovering before they felt ready to sue are no longer barred by statutes of limitations.

More importantly, the bill creates a new federal cause of action allowing victims to sue interactive computer services and app stores if those entities “intentionally, knowingly, or recklessly” promoted, aided, or abetted exploitation, or knowingly hosted child pornography (Sec. 5). This bypasses Section 230 of the Communications Act, which normally shields platforms from liability for user-generated content. If a victim wins, they are guaranteed either actual damages or liquidated damages of $300,000, plus legal fees.

Platforms do get a narrow defense: if they can prove they removed the illegal material within 48 hours of knowing about it, they might be off the hook. But this 48-hour clock means platforms will be under immense pressure to act quickly, potentially leading to hasty content removal decisions (Sec. 5). The bill also creates a new criminal offense for a provider that intentionally hosts child pornography, with fines up to $5 million if the violation causes harm.