Technologies and Technical Measures to Address Online Harms – WS 03 2026

27 May 2026 09:30h - 10:30h

Technologies and Technical Measures to Address Online Harms – WS 03 2026

Session at a glanceSummary, keypoints, and speakers overview

Summary

The discussion focused on technical and policy measures for addressing online harms, especially phishing, DNS or IP blocking, and the tradeoffs between user protection, effectiveness, and fundamental rights [1][7-15]. André Melancia framed the session as an interactive exchange on technologies to address online harms, with speakers presenting short introductions before audience discussion [1-2][7][11-15].


Miguel De Bruycker described Belgium’s anti-phishing approach, built around a public reporting address where suspicious messages are forwarded for analysis, which has grown to tens of thousands of submissions per day [21-31]. He said the Belgian Anti-Phishing Shield works with major internet service providers on an opt-out basis, using DNS synchronization to warn users when they try to visit domains assessed as highly likely malicious [34-48]. De Bruycker argued that AI is contributing to the growth of malicious content, and presented the system as a proportional warning mechanism rather than content removal, reporting 185 million warning-page displays last year and saying the system had generated no official complaints in seven years [32][60-64][67-73]. He also explained that analysis combines automated detection of phishing kits, anonymization, and support from commercial partners, while Belgium is expanding to detect broader scam indicators such as phone numbers and messaging accounts [79-84][99].


Raffaele Sommese contrasted user-protection blocking with blocking used to enforce government or private-party decisions, arguing the latter creates serious problems because IP and DNS are often the wrong technical tools [106-112]. Using Italy’s Piracy Shield as an example, he said it had blocked more than 10,000 IPs and 40,000 domains, caused thousands of cases of collateral damage to legitimate services, lacked transparency, relied on extra-judicial requests from copyright holders, and remained easy for illegal operators to evade cheaply by changing IPs or domains [133-160]. He added that the platform had not shown clear economic effectiveness and that more aggressive cross-border blocking raises extraterritoriality and internet freedom concerns [166-169].


In the broader discussion, participants emphasized that collaboration among states, service providers, platforms, and technical actors is essential, with one example showing that cooperation among European country-code domains improved phishing detection through shared machine-learning models [220-229][333]. De Bruycker said cooperation with providers and platforms is improving, including faster action by companies like Meta and the use of shared signal exchanges, while Belgium tries to avoid turning anti-phishing work into censorship by limiting its focus to known cybercrime-related abuse rather than lawful but harmful content [173-181][186-197][271-279][323-329]. Several speakers stressed that there is no “silver bullet,” that interventions must be proportionate and transparent, and that more granular, content-level responses are generally preferable to infrastructure-level blocking when possible [280-281][291-297][300-304][312-316][331][333]. The session concluded that online harms require balanced, multi-stakeholder solutions that protect users without causing unnecessary collateral damage or undermining internet freedom [333][338-354][355].


Keypoints

– The discussion centered first on Belgium’s anti-phishing approach as a practical technical measure against online harms. Miguel De Bruycker described a public reporting system for suspicious emails, the large volume of reports received, and the Belgian Anti-Phishing Shield, which uses DNS-based warning pages through major ISPs on an opt-out basis to alert users about highly confident malicious domains. He stressed proportionality, transparency, and a focus on clearly malicious cybercrime-related domains rather than broader content control. [21-35][40-49][60-72]


– A major theme was how such systems are built and evolving in response to new phishing methods. Miguel explained that Belgium combines automated analysis, phishing-kit detection, anonymization, and commercial partners to process reports, and is expanding beyond email and fake websites to include scam indicators such as phone numbers, WhatsApp accounts, and other messaging-based abuse. [79-84][95-99][101-103]


– A second major focus was criticism of infrastructure-level blocking, especially IP and DNS blocking for copyright enforcement. Raffaele Sommese argued that these tools are technically ill-suited for many government-led blocking goals because IP blocking causes extensive collateral damage and DNS blocking raises cross-border and jurisdictional problems. He used Italy’s Piracy Shield as a case study, saying it blocked thousands of IPs and domains, harmed legitimate services, lacked transparency, relied on extrajudicial private-party requests, and remained easy for illegal services to evade. [106-130][131-169]


– Participants repeatedly debated the tradeoff between security intervention and rights protections, especially transparency, freedom of expression, and the risk of censorship or overreach. Speakers distinguished targeted anti-phishing measures aimed at “known bad” cybercrime indicators from broader content blocking, while others warned that policymakers often pursue blunt “silver bullet” solutions that can undermine anonymity, speech, and legitimate access. The importance of balancing benefits and harms, and involving technical experts in that balancing process, was emphasized throughout. [186-197][280-281][291-297][300-304][323-331]


– Collaboration emerged as a key solution across the discussion: between governments, platforms, ISPs, registries, and across EU member states. Miguel highlighted improving voluntary cooperation with ISPs, Microsoft, Google, and Meta, while Raffaele and audience members stressed that cross-border and inter-stakeholder collaboration can improve phishing detection and abuse response. The discussion ended with the broader point that because the internet is largely privately operated infrastructure, governments must work collaboratively with service providers rather than rely only on coercive or purely national tools. [34][174-182][220-229][341-354]


The overall purpose of the discussion was to examine what technologies and technical measures can effectively address online harms, while also testing their limits. The panel compared protective cybersecurity tools such as Belgium’s anti-phishing shield with more controversial content- and copyright-blocking systems such as Italy’s Piracy Shield, in order to explore effectiveness, collateral damage, transparency, proportionality, and possible alternatives. [1][7-15][105][333]


The overall tone was professional, expert, and highly policy-oriented, with an initially practical and explanatory tone during the Belgian anti-phishing presentation. It then became more critical and cautionary during the discussion of IP/DNS blocking and Piracy Shield, especially around collateral damage, lack of transparency, and policymaker misunderstandings. By the end, the tone broadened into a reflective and collaborative one, emphasizing balance, rights, and multi-stakeholder cooperation rather than simple technical fixes. [16-18][60-72][135-169][312-316][331][341-355]


Speakers

– Andre Melancia – Moderator of the session; co-moderated “Workshop number three, technologies and technical measures to address online harms.”


– Miguel De Bruycker – Director General of the Center for Cybersecurity Belgium; presented insights on the Belgian Anti-Phishing Shield.


– Philip Struyf – Co-moderator/facilitator of the session.


– Raffaele Sommese – Professor at Twente University; presented research on the Italian Piracy Shield, including collateral damage and efficacy.


– Nenad Bogunovic – Acting Deputy Head of the Cybercrime Unit in Serbia.


– David Frautschy – From the Internet Society.


– Olivier Crepin Leblond – With the United Kingdom chapter of the Internet Society; active in internet governance discussions [S13].


– Peter Kovdynik – Participant/speaker in the discussion.


– Philip Lucas – Summarized the session messages at the end.


– Petra Arts – From Cloudflare.


– Participant – Various unnamed audience and remote participants asked questions and made comments.


Additional speakers:


– Stigl Fernandes – Former student / university student interested in technical applications to policy.


Full session reportComprehensive analysis and detailed insights

The session was framed by Andre Melancia as an interactive discussion rather than a set of long prepared speeches, with participation invited from both speakers and the audience, including remote participants [7-13][14-15]. The discussion then moved from a concrete anti-phishing case study in Belgium to a broader debate about internet blocking, proportionality, transparency, technical architecture, and fundamental rights [7-15][104-110].


Miguel De Bruycker, Director General of the Centre for Cybersecurity Belgium, presented Belgium’s anti-phishing model as an example of a technical protection measure aimed at cybercrime rather than general content regulation [19-25][34-35]. He explained that Belgium had launched a public awareness campaign eight years earlier telling people not to trust every message they receive and asking them to forward suspicious messages to “suspicious@safeonweb.be,” available in four languages [21-26]. The scale of this reporting system has grown sharply: Belgium now receives on average 27,000 suspicious emails per day, rising to 35,000 in January and 42,000 in April, which he linked in part to AI making malicious content easier to generate at scale [26-33][S58][S60]. He also used a concrete example to explain why such a system exists, describing scam campaigns that targeted thousands of Belgians, especially women aged 40 to 65, with fake advertisements for clothing brands offering implausible discounts; after action was taken, the scammers quickly switched to other brands, illustrating how rapidly these campaigns mutate [50-59].


De Bruycker then described the Belgian Anti-Phishing Shield as the main technical response built on top of that reporting channel [34-35]. He said the system works voluntarily with the country’s main internet service providers, which subscribe to a secure DNS arrangement under an opt-out model [34][40-46]. Domains extracted from reports are evaluated, and only those judged with extremely high confidence to be malicious are synchronised with ISP DNS systems so that users who try to access them receive a warning page [42-49]. He repeatedly stressed that Belgium’s system does not remove content and is meant to present a warning page rather than impose an absolute access ban [50-64][174-180]. He compared it to a public warning sign around a known danger and argued that the state has at least a duty to warn users when it knows a digital hazard exists, even if users can still choose to proceed or work around the warning [60][67-70]. He reported that the warning page had been displayed 185 million times in the previous year, which he presented as evidence that the system was having a meaningful protective effect despite its limits [60].


A central part of De Bruycker’s argument concerned safeguards. He repeatedly stressed proportionality, transparency, and restraint, saying that the Belgian system uses a low-risk approach, including lists of known-good domains, and only warns on domains when officials are as close as possible to certain that they are wholly malicious [36-39][60-64]. It is also opt-out: users on participating ISPs are covered by default, but can switch to a DNS service without the protection if they choose [40-46]. Users can also challenge a warning, after which the domain may be removed from the list following evaluation, with protections in place to prevent abuse of the challenge process by criminals [47-49]. He concluded that some technical protection at this level is necessary in the same way antivirus tools stop malicious files and spam filters stop malicious emails, while also acknowledging that the policy question is where to draw the line [67-72]. He argued that, after seven years, the system had generated no official complaints and no known mistakes or operational problems, which he presented as evidence that Belgium had found a workable balance in this limited anti-phishing context [71-72].


When asked by Andre Melancia how such large volumes of suspicious emails are processed, De Bruycker explained that Belgium uses a combination of automation and external support rather than a purely manual workflow [74-78][79-84]. He said the system automatically extracts links from messages, anonymises the data, and runs it through detection engines that identify, among other things, phishing kits-software packages rented on the dark web and used in more than 90% of phishing campaigns, according to his estimate [80-84]. The Belgian centre creates signatures for these kits and combines them with other parameters and the assistance of two commercial partners that evaluate anonymised links for maliciousness [81-84]. This showed that operational anti-phishing work depends on layered detection pipelines, commercial cooperation, and some limits on disclosure of exact methods so that attackers cannot easily adapt [79-84].


Questions from the audience then focused on how such systems may need to evolve. Nenad Bogunovic from Serbia, where a national cybercrime reporting system is being developed, asked whether Belgium’s approach would move beyond links and fake websites toward newer forms of abuse such as spear phishing, AI-generated scams, SMS phishing, and similar techniques [90-98]. De Bruycker responded that Belgium is already building a new project designed to ingest broader scam indicators, including phone numbers, WhatsApp accounts, and other messaging-related signals, with production expected by the end of the year [99][S103]. This exchange highlighted a shared view that anti-phishing systems cannot remain static as attack vectors diversify beyond classic email-based phishing [95-99].


A separate audience question raised end-to-end encrypted messaging services [100]. De Bruycker replied that the Belgian system was built for email, but that users who receive suspicious messages on services such as WhatsApp can take screenshots and forward them to the reporting address [101-103]. He stressed that the state does not scan end-to-end encrypted channels directly; instead, users voluntarily forward suspicious messages, after which the Belgian system strips personal data and analyses the submission [100-103]. He added that Belgium’s data protection authority oversees the system under a strong data protection framework, allowing him to argue that encryption itself is not undermined because the forwarded content comes from the recipient rather than from interference with the encrypted service [101-103].


The discussion shifted in tone when Raffaele Sommese presented research on Italy’s Piracy Shield and the wider issue of infrastructure-level blocking [104-105][106-110]. Sommese began by distinguishing between two very different uses of internet intervention: first, protective measures aimed at shielding end users from harms such as scams; and second, systems used to implement governmental, judicial, or private-party decisions to protect specific sectors such as copyright industries [106-110]. In his view, the main problems begin with the second category, because the technical tools most often used-IP and DNS blocking-are not well suited to those policy goals [110-112]. He then explained basic internet architecture for non-technical participants, describing IP addresses as something like the number of a building and DNS as the naming system that helps users reach a particular destination within shared infrastructure [113-121]. This supported his central point that internet resources are heavily shared, so coarse infrastructure interventions can affect far more than the intended target [122-126].


Sommese argued that IP blocking is easy to order but inherently risky because one blocked address may host many unrelated services, producing substantial collateral damage [122-125]. DNS blocking, in his account, is different but also problematic, especially once it involves public recursive resolvers or services operating beyond national borders [126-129]. He stressed that IP geolocation cannot reliably determine a user’s country, and that providers cannot confidently certify such information “in front of a judge,” making country-specific blocking at the global resolver level technically and legally unstable [127-129]. He presented this as both a technical and policy problem, arguing that some regulatory approaches in Europe are being developed without sufficient regard to how shared internet infrastructure and geolocation actually work [127-130][S109][S110].


Italy’s Piracy Shield served as his main case study [131-135]. He described it as a platform created to combat illegal online football streaming, often cited by some as a successful model, but one that his research found to be a poor example in practice [133-136]. According to Sommese, Piracy Shield has blocked more than 10,000 IPs and 40,000 domains across Italy and caused thousands of cases of collateral damage to legitimate websites and services [136]. He illustrated this with examples including web shops, car repair sites, and a Portuguese hosting provider that had rented infrastructure previously abused by a pirate streamer and then found its address blocked in Italy, leaving it unable to send invoices to Italian customers for a month [138-141]. He said the company did not even know why the block had been imposed because the system is opaque [141-148].


Transparency and accountability were among Sommese’s strongest criticisms. He said blocking requests are inserted by private copyright holders, must be acted on by operators within 30 minutes, and are extra-judicial in character because there is no vetting of the requests or of the forensic proof attached to them [142-145]. He also said the blocklist is not public, meaning affected parties may discover a problem only when they can no longer reach a service, without being told the legal or factual basis for the block [145-148]. In his view, this opacity is a governance problem because it prevents public scrutiny, independent audit, and effective remedies [141-148]. He further argued that the system remains easy for illegal services to evade, since IP addresses can be leased cheaply and domains can be registered at low cost, allowing operators making money from piracy to rotate infrastructure quickly and continue operating [150-157]. At the same time, he argued that, as implemented, these blocks “last forever,” because there is no later verification of whether the illegal resource is still there, which in his view causes long-term pollution of the internet’s namespace and harms later legitimate re-users of those resources [158-165].


Sommese also argued that Piracy Shield has not demonstrated economic success [166-169]. He said the number of subscriptions to legal services did not rise after the platform was introduced, undermining claims that it is an effective anti-piracy intervention [166-168]. He warned that the Italian regulator now wants to extend this approach even more aggressively to VPNs, recursive resolvers, and CDNs, which in his view would deepen the same extraterritorial and technical problems rather than solve them [169]. He therefore asked whether better alternatives exist and suggested that, given that 77% of blocked servers were located in the European Union, authorities should use available EU legal instruments to go after hosting providers and financial flows instead of relying on broad and ineffective network-level blocking [169-170]. This “follow the money” and source-level approach was one of the clearest alternatives proposed during the session [169].


A remote question then invited comparison between Belgium’s anti-phishing work and these more controversial blocking systems by asking what percentage of scams Belgium blocks and how it works with online platforms [171-172]. De Bruycker’s answer reinforced a recurring distinction in the discussion between Belgium’s warning model and broader blocking regimes [173-197]. He reiterated that Belgium’s cooperation with ISPs is constructive, non-legal, and non-binding, and explicitly agreed that blocking IP addresses is a bad idea because of collateral damage [174]. He also described growing cooperation with large technology companies through mechanisms such as the Global Signal Exchange, which he described as a spin-off of Oxford University, where Belgium shares domains it considers certainly malicious with companies including Google, Microsoft, and Meta [174-180]. As a result, providers may move emails containing such links from inboxes into spam folders rather than deleting them, or remove malicious advertisements more quickly than before [175-180]. He said recent improvements in response times, especially from Meta, suggested that some platforms increasingly recognise they bear practical responsibility when their services are abused for cybercrime and they receive credible notice [179-182].


On effectiveness, De Bruycker said the volume of reports gives Belgium “quite a good” and “representative” view of phishing campaigns affecting the country [183-185]. He explained that, at first, the system could extract and act on only around 25-30% of malicious links because officials were being extremely cautious to avoid being perceived as censors [186-188]. That figure has now risen, in his estimate, to around 60-70%, though many other domains are still treated as suspicious but not sufficiently certain for intervention [189-192]. He acknowledged that the system will never reach anything close to 99% and again compared it to spam filtering: imperfect but essential, because without such filtering email itself would become unusable [193-197].


Another audience question clarified that Belgium’s reports originally came entirely from citizens, but that the model is evolving [199-200][202-214]. De Bruycker said that until about a year earlier the feeds were 100% from the population, but Belgium now also has a priority channel for banks and the national digital identity provider Itsme to notify phishing domains targeting their services [202-206]. He also referenced a more proactive project aimed at finding domains registered with malicious intent against Belgian government and critical infrastructure, though he declined to explain the method publicly so as not to make evasion easier [207-214]. This exchange again highlighted the operational tension between transparency and secrecy that later became explicit in the discussion [210-214].


The audience then broadened the discussion from national systems to European and multi-stakeholder coordination. A participant from CleanDNS argued that Belgium, Italy, Serbia, and others were confronting similar threats and asked how member-state collaboration could be strengthened and what more could be done at the infrastructure level across the provider chain [220-221]. Andre Melancia encouraged participants to organise across the EU and build collective pressure so that concerns receive more political attention in European institutions [222-225]. Sommese added a technical example: a study had shown that cooperation among several European ccTLDs, sharing a machine-learning model trained on each other’s data, improved phishing detection across those domains [227-229]. In the closing synthesis, Philip Lucas summarized one of the recurring messages from the session as the need for multi-stakeholder collaboration across industry and government because online harms continue to evolve [333]. This part of the discussion showed broad support for greater cooperation, even though participants differed over the kinds of intervention that cooperation should enable [220-229][333][S35][S67].


David Frautschy from the Internet Society further deepened the critique of infrastructure blocking [232-248]. He argued that comparing IP addresses to telephone numbers can mislead policymakers because, unlike a single phone line, one IP address may support many websites and services [234-239]. He pointed to examples from Spain, including the disruption of a payment gateway that affected e-commerce during a football match, to show the real economic consequences of overbroad blocking [240-242]. Frautschy also questioned why policymakers seem more willing to listen to rights holders than to the technical community, despite repeated warnings about the harms of such systems [243-247]. Finally, he asked whether a liability scheme should require those who request blocks to compensate websites harmed by wrongful blocking [248-250].


Sommese responded by clarifying that his analogy referred to the number of an entire office building rather than a single household line, and by reiterating that while it is easy for a state to order national ISPs to comply, it is technically difficult to target only users from a single country once a service operates across borders [252]. On liability, he agreed the issue is important and gave the example of Piracy Shield blocking Google Drive in October 2024 for several hours [253-258]. He said such an incident may have had enormous business consequences, yet no liability attached to the party responsible for the block and there was no meaningful policy debate about compensation [259-261]. He added that liability would in any case require transparency, since only a public and auditable record of what was blocked, when, and why would allow harmed parties to prove losses and seek redress [261]. This exchange highlighted accountability and compensation for overblocking as unresolved governance questions [248-261].


A remote question from the perspective of a media regulatory authority asked whether “follow the money” is really a better alternative in hard cases such as copyright infringement, pornography, or other content harmful to minors when providers and hosts cannot be reached [263]. Sommese answered that this is indeed difficult and that for universally illegal material such as CSAM stronger blocking may sometimes be justified even at the risk of collateral damage [264-266]. However, he said the deeper problem remains the existence of bulletproof hosting providers that ignore legal authority and continue to host unlawful content [267-270]. De Bruycker responded more broadly that there are many possible responses to cybercrime, including law enforcement, following the money, and provider cooperation, and that no single tool is sufficient [271]. He again defended the value of warning the users one can protect, even if coverage is incomplete [271]. He also offered a practical lesson from Belgium’s cooperation with platforms: abuse notifications framed as violations of platform policies can prompt much faster responses than formal legal accusations, which are often routed through legal departments and slow things down [272-279]. In his experience, most providers will act if clearly notified that their services are being abused, though not all are equally responsive [271-279].


Andre Melancia then widened the discussion to rights implications beyond phishing and piracy, particularly age verification and child-protection measures [280-281]. He warned that certain internet blocking or verification schemes, such as restrictions on minors’ access to social media or mandatory age checks, can create serious harms to anonymity, freedom of expression, and even the ability of people in some countries to organise peaceful protest [280-281]. This linked the technical discussion to broader democratic concerns and reinforced the distinction between combating known cybercrime and trying to regulate lawful or borderline content through infrastructure controls [280-281][355].


A participant identified in the transcript as Peter Kovdynik then introduced one of the session’s most architecturally focused critiques [286-298]. He suggested that more attention should be paid to cross-border issues, the difference between voluntary and involuntary blocking, and the role of circumvention technologies [288]. He also challenged repeated claims that authorities could not disclose more about their methods, arguing that public authorities have transparency obligations, especially when they intervene in ways that may affect private market participants providing security services [289-291]. Most importantly, he questioned why content mitigation, which properly belongs at the application layer or user level, should happen at the infrastructure layer at all [292-295]. He pointed to more granular alternatives such as spam folders, browser plug-ins, and other user-facing tools that offer more control and avoid interference with the internet’s core infrastructure and its cross-border implications [296-297]. His intervention crystallised a key line of disagreement in the discussion: whether DNS-layer action can ever be sufficiently narrow, or whether even well-intentioned interventions are being attempted at the wrong technical layer [292-297].


In response, De Bruycker defended Belgium’s approach by distinguishing between transparency of purpose and disclosure of every operational detail [299-303]. He said Belgium is transparent about what it does, but argued that publishing all security methods would be like publishing every antivirus signature and would only help attackers adapt [300-302]. He acknowledged that tools such as spam filters could theoretically be abused by governments to suppress particular types of messages, but insisted that this possibility is not a reason to abandon all filtering, because without such safeguards the underlying services become unusable [302-303]. The real challenge, he argued, is to find the right balance between effective protection and abuse prevention, and he maintained that doing nothing would be a greater risk than trying to act within supervised limits [303]. Sommese partly converged with Kovdynik here, stating bluntly that IP and DNS are the wrong place to block certain kinds of content and that action should be taken at the source where possible, especially for content hosted within the European Union [304]. This exchange showed both some common ground and a continuing disagreement: De Bruycker defended narrowly scoped DNS-based warning pages for phishing, while others remained more sceptical of infrastructure-layer intervention as such [299-304].


After a participant asked for a simple explanation suitable for politicians of why the technical framework is ill-suited to child protection online [306-309], Olivier Crepin-Leblond shifted the discussion toward political incentives, arguing that policymakers often seek “silver bullet” solutions because they want immediate results [310-316]. Unless complexity, trade-offs, and risks of false positives are made clear, he warned, harmful measures such as overbroad age verification will keep recurring and make the internet harder to use [312-316]. Petra Arts then pointed participants to a commissioned study on the economic cost of network blocking, reinforcing the argument that the harms of overblocking are not merely theoretical [317-321]. A final remote question asked whether Belgium has supervised methodologies to ensure it preserves freedom of speech rather than becoming a censorship arm of government or private parties [322]. De Bruycker replied that Belgium focuses only on “known bad” cybercrime indicators such as phishing and does not move into content domains such as adult-site restrictions, precisely because there is no correct technical solution there [323-325]. He also said Belgium was in contact with Cloudflare, noting that many malicious domains use its infrastructure and arguing that collaboration with service providers is preferable to imposing duties solely through law [326-329].


In one of the final exchanges, Sommese summarised the broader lesson by saying there is no silver bullet: every internet intervention has consequences and must be balanced through discussion with technical experts [331]. In the closing synthesis, Philip presented three messages from the session: first, the evolving nature of online harms requires multi-stakeholder collaboration; second, intervention at the technical layer through IP or DNS blocking can seriously affect the availability of online resources and create collateral damage; and third, measures against illegal content or online harms must remain proportionate and respectful of users’ rights [333]. When asked for a recommendation for young participants, Sommese encouraged them to participate actively in these debates and define for themselves what harms they want protection from, especially when so many of these measures are justified in their name [338-340].


De Bruycker’s final remarks added a broader governance perspective [341-354]. He argued that the internet is not public space in the same way as a street is public space, but a largely privately owned ecosystem of devices, ISPs, carriers, and services [341-349]. Because governments do not simply enter that private environment and impose solutions unilaterally, he said, effective online safety requires cooperation with the companies operating the infrastructure [348-354]. At the same time, he argued that those private actors bear significant responsibility when their services are abused [353-354]. Andre Melancia closed by noting that concerns about restrictions, freedoms, and democratic backsliding are growing globally, and that these debates will continue beyond the session [355-360].


Overall, the discussion revealed recurring points of agreement alongside clear differences over methods [220-229][292-304][331][333]. Participants broadly agreed that phishing, scams, and other online harms are real and growing, and that doing nothing is not an acceptable response [26-33][333]. There was also repeated concern that IP-level blocking is especially blunt and that broad infrastructure-level blocking for copyright or other policy goals can create serious collateral damage, opacity, and cross-border problems [122-129][136-169][174][234-242][304][333]. At the same time, disagreement remained over whether carefully limited DNS-based warning systems such as Belgium’s anti-phishing shield are a justified and proportionate protective measure or whether even these should be treated more sceptically because they still intervene at the infrastructure layer [34-49][60-72][174-197][292-304]. The clearest contrast to emerge was between Belgium’s narrowly scoped, cybercrime-focused warning model-presented as voluntary, opt-out, transparent in purpose, and not aimed at content regulation-and broader blocking regimes such as Piracy Shield, which were criticised as opaque, overbroad, easy to evade, and harmful to legitimate services [34-49][60-72][131-169][174-197][323-329].


Session transcriptComplete transcript of the session
Andre Melancia

Shop number three, technologies and technical measures to address online harms. Both me and Philip will be moderating the session. My name is André Monsilla. We have Philip Zdrav. Apologies if some of the names that we say are going to sound terribly, terribly wrong, but we have multicultural names here everywhere, and, well, we are in the right place to get them wrong in the European Commission anyway. So with us we have, I will try to say this correctly, Miguel de Brucke, okay, and we have Raffaele Zometzi, okay, with us, and they will start the panel. And we also have, of course, and again, I will try to say this correctly, Philip Lukacs. okay and we have our two moderators there as well so they will help us out if anyone is remotely at this point you are more than free to ask questions and we will take questions from the audience remotely our idea for this is that in the spirit of juridic to spend the most amount of time actually getting interaction from the audience so we will have a starting five minutes introduction at most from each of our key speakers and then from that point on we’ll open it up to questions from the audience questions and of course comments okay please remember that while four or five of us are here on this side and also a lot more people in the back and in the front everyone here is an expert and you have valid points to share so we want to hear it as well okay so anything we should mention no i think we heard yesterday that there are still a lot of online harms to be addressed and the first key participant that we invited is Miguel Dubrakis.

He’s Director General of the Center for Cybersecurity Belgium and he wants to give some insights on the Belgian anti -phishing shield. So the floor is yours, Miguel. Miguel, just before you begin, let me put this up on screen. So we’re going to have some of these topics that we’re going to talk about. We’re not going to pretend that we are going to do them in an exact order because this will be very difficult, but we will try to talk about all of these. I know some of you are not technical people, right? So what we actually added is a few slides that over time we will share with you to actually explain some of the concepts that we will talk about later on.

But for now, let’s just share your slides.

Miguel De Bruycker

Yes. That’s my last one. Oh, okay. Thank you very much. Good day to everyone. So my name is Miguel de Bruyckers. As I was introduced, I’ll push this button. Center for Cybersecurity Belgium created 10 years ago, 8 years ago, we launched a campaign warning the people against phishing. You cannot trust every message, every email that you receive. And the call to action was if you see something suspicious, forward it to us. So we created a mail address in four languages. In English, it’s suspicious at safeonweb .be. And, well, it went a little bit crazy in the sense that, and I’ll put the numbers immediately on top of this, that last year, on average, we received 27 ,000 emails per day from the population.

It’s a small population, 27 ,000 emails. This is a lot to process. Now, in January, that went up to 35 ,000. In April, we were at 42 ,000. So it’s going up very fast. And AI and AI possibilities to create malicious, malicious content is certainly playing an important role of that. What do we do with that? We share it, for instance, with Microsoft and Google, the malicious domains. or for instance Google Safe Browsing we have the Belgian Anti -Phishing Shield we have an app warning people be careful now there is a large campaign using B -Post or using TaxPay or whatever, don’t get caught so we have quite a lot of different systems so 8 years ago we created that mail address 7 years ago we created the BAPS system the Belgian Anti -Phishing Shield that is actually with the main internet service providers voluntarily, they subscribe we take responsibility we filter out the malicious domains from those let’s say 14 ,000 emails that we get every day and through DNS RPC synchronization reads that our DNS is synchronizing with their DNS meaning that if you get a link with a domain of a domain that by us is flagged as …

99 .999 % for sure malicious, you will get a warning page. So we do an evaluation of all those domains. We have a low -risk approach. Like, for instance, we have made a huge list of what we know as the known good to make sure that we never warn for one of those domains. But there are a lot of other mechanisms. We detect phishing kits and things like that. It’s an op -out system. So by default, if you are under one of those five main Internet service providers, you are under that secure DNS. You get a warning page that is something like this. And you will see also that we also say, okay, we don’t want this secure DNS.

So we tell you how can you switch to another DNS that we provide where that security is not. But it’s an op -out. You have to do it yourself. Or you can say, I absolutely don’t agree with this warning. And then you can say, why and 24 -7 we will remove it from the mops list. after an evaluation. There are some criteria to remove it to make sure that criminals don’t abuse this. Why do we do it? Well, for instance, this is an example of the last few weeks. Last few weeks, thousands of Belgians, especially women, between 40 and 65, were being targeted with publicities for brands, Marimero, Marijoev. I’ve learned a lot. I had to ask my wife what is this.

They have created thousands of malicious domains, all linking to those brands and trying to convince those people to buy online with 80 % of discounts. This is, for instance, one of yesterday. Now they have switched because we have taken action. I have to admit, even together with Meta, there were advertisements online for these websites, and Meta is responding and is removing them, but it’s going so fast. So now they are switching from these brands to Fritz’s A .S. Adventure. That was yesterday. what are the benefits well I know that there are risks there are questions like for instance well if you set out those warnings you don’t remove the content and the effectiveness is limited of what you’re doing and that is absolutely correct but imagine that there is a hole in the street and you know that there is a hole I think as a government it’s important that you put out some warnings and that people can still fall into that and that there are ways to circumvent that I know but for the moment that is working we send out that warning page last year 185 million times so we do see a positive effect of what we’re doing it’s not perfect but at least it’s doing something you can have false positives there is the risk of over blocking of government abuse of that that is for us very important that is that proportionality, that is that transparency.

We do what we say and we say what we do. That is one of our mantras and people know that very well. And it must be proportioned what we’re doing. So we will only warn for a domain when we are as good as sure that it is 100 % malicious and the goal remains to protect people. Think about my last slide. Follow this. Yes. So as a conclusion, I think you cannot build a secure environment without some kind of protection. If you want to stop cyber crime, you will need to warn and even stop malicious processes using antivirus. You have to stop malicious emails using spam filters. And I think you have to warn for malicious domains.

using, well, DNS warning systems. And the big question is, of course, how do you find the right balance? And I think since we are doing this for seven years and we have no official complaints, no mistakes, no problems in using that system. Thank you.

Andre Melancia

Okay, so I think one of the things that we can do right now is open this up for one or two questions, and I will actually have a question myself. So when we saw your numbers and you mentioned 20 ,000, 40 ,000 requests per day, how do you process them? Do you use AI? Do you use humans? Is there an uncertainty here?

Miguel De Bruycker

Yes, thank you. Well, you have to use a lot of tools, and we have different methods. Okay. I cannot reveal it publicly how we’re doing it, but for instance, I have a question for you. we have a whole system that is detecting phishing kits. More than 90 % of those phishing mails are being sent using phishing kits, software that is used, that is rented on the dark web, $100 per month. You use that, and we create signatures of those phishing kits. So if we can detect, okay, we receive a link, we receive an email, we extract automatically, this is all done at our CCB, we anonymize it, and then it goes through the engine, and we will try to detect if we see, for instance, those phishing kits.

There are also some other parameters, and then together with a few commercial partners, there are actually two companies that are helping us to evaluate the anonymized links to flag them as malicious.

Andre Melancia

Okay, so let’s open this up to questions at any time. If you also have questions. If you have questions remotely, you guys will let us know. So any questions so far? We have a question there.

Nenad Bogunovic

Just a short question. Thank you so much. Well, first of all, I’m from Serbia, from the Cybercrime Unit, and we are currently developing a national cybercrime report system, and your system was one of the, sorry, yeah, and your, sorry, of course, Nenad Bogunovic, I’m the acting deputy head of the Cybercrime Unit in Serbia. So one of the key components we are using is also anti -fraud system, anti -phishing system. My only question is to you, I see that you’re more oriented to links and fake websites and so on and so on. Will you evolve your anti -phishing system to the evolution of phishing today, you know, more spear phishing, AI, generated content, SMS phishing, and so on and so on?

Because I see that. Maybe it’s, you know, maybe it should evolve in this regard as well. That’s at least something we are trying to do, and it’s really a big challenge from our side at least. thank you

Miguel De Bruycker

thank you very much well we have a new project that is up and running and that should be in production by the end of this year to to take all those malicious signals or scam indicators like phone numbers whatsapp accounts on a messenger like types a lot of other things that are being used now so this is a project that is up and running and that will be normally in use by the end of

Andre Melancia

more question of one question there yes when shock building around serve on the board of your Riddick come from Switzerland but I admit I’m not a technician how does this work the screening with end -to -end encryption did messaging systems

Miguel De Bruycker

Okay, so somebody receives a message Our system was built especially for emails But for instance, if you receive a WhatsApp message And there is a link to a WhatsApp account You can just take a screenshot And you can forward it to that mail address So that means that, imagine that you receive an email You have it in your inbox Now the population is aware through media That they can send it to suspicious at saveonweb .be And this is like a little bit of crowdsourcing You are using the population as a first filter To evaluate that something is wrong So the first evaluation actually is done by the population They see something suspicious, they say This doesn’t look right And they forward it to us And then that is where the analysis starts So we get actually the message from the population And then we extract everything that is related to personal, so we have a strong EPA in Belgium, and we’re under their control.

So we’re doing, as I said, we’re saying what we do and we do what we say, and this is quite important. So the fact that they extracted themselves and they forwarded to us the encryption is not an issue.

Philip Struyf

Thank you, Miguel, for the interesting presentation and addressing those questions. We will now hand over to Raffaele Sommese, professor at Twente University, who will present his research on the Italian Paris Shield and the collateral damages and the efficacy of that system.

Raffaele Sommese

Thanks a lot. So let me start first with, I mean, internet blocking is something that has been given as a sort of big blanket towards two different concepts. One is the concept that Miguel was introducing that was protecting the security of end users. From, for example, financial scam or financial harm. And the other aspect is implementing governmental or judge or private party decision for protecting certain sector. And the problems start to rise when we have the second category of implementation, because the current technology that we have is not actually the right tool. And the reason why it’s not the right tool is because the way it’s implemented is mostly with two aspects of the Internet.

One is the IP protocol and one is the DNS protocol. Now, for the one in the room that are not familiar with this concept, imagine the IPs as to be the phone number of the Internet, like a series of digits. And you call the house of someone. And then when you call them, you’re not sure of the person that will respond on the other side. There may be multiple persons. There may be like a 20 -story building office that you’re calling. So you want a specific person out of that number. To get a specific person out of that number, what we use is the IDN. It’s basically this phone book of the Internet that provides this translation from names, things that we can easily remember, Europa .eu, for example, to something that is more difficult to remember that are these numbers.

But they also give us the opportunity to select who we want when we call a specific number in that building. And blocking IPs from a perspective of a government, it’s very straightforward. You just order all the Internet service provider in your country to block that specific IP, and then all the customers for your country will be not able to access that IP. The problem is that you will cause a lot of collateral damage, because then all the people in that 20 -story building will be unable to access their services. And that’s the scenario nowadays in the Internet with the content delivery network, for example. To block DNS, it’s a bit more difficult concept, because you can do it, you can do it at an additional level, but…

But when you cross the border of national level, when you ask like a public recursive resolver out there to block specific names, you encounter the problem of extraterritoriality where basically you don’t know where the client that are connecting to this recursive resolver are from because on the Internet, we don’t have a stable way to determine where an IP address is connecting from, from which country it is. All the service that we have out there, all the geolocation providers that we have out there, they tell you, we do the best effort to provide you this information, but we cannot tell you this user is from Italy and we cannot swear this information in front of the judge.

So it’s a very challenging technical problem. And the other problem is, while this problem exists, this has been ignored by the regulation that is coming up in Europe, especially in Italy and Spain and in France. And in Italy, we have like a very bad case. That’s named piracy shield. So what is Piracy Shield? Piracy Shield is a platform that exists in Italy to try to prevent basically the online football streaming piracy. And while it has been considered by someone a good example of how to implement this, we did the research on this topic and we demonstrated basically with numbers that this is a very bad example. Because Piracy Shield as of today has blocked more than 10 ,000 IPs and 40 ,000 domains in all Italy and has caused thousands of collateral damage to legitimate websites.

Sorry that I was describing you before of the building. Imagine that when we did the research, we found like a lot of websites that were completely not piracy related, websites of web shops, websites of car repairs. It was like actually the case that I always report is this case of a Portugal hosting provider that was blocked because they rented. The infrastructure that was previously abused by someone that was streaming illegal content. and they ended up with an address that was blocked in Italy and they were not able to send invoices to their customer in Italy for an entire month. And they didn’t know that their address was blocked by this platform because the other problem is that there is no transparency in this platform.

The requests for blocking are requested and the cooperator should comply within 30 minutes. There are extra judicial orders because the requests for blocking are inserted by private parties that are the copyright owners and there is no vetting of these requests. There is just a forensic proof that is attached to this platform but actually no one is vetting this forensic proof. And the other problem is that there is no transparency. The list of block is not public. So you just notice that something is blocked because you see that you cannot connect to the website but you will never know why it has been blocked. This information is not provided to you. This is a video that was recorded in the last week of May.

And the other problem is, despite causing a lot of collateral damages, this platform has proven to be ineffective because the Internet is a big place and illegal services evades very easily these blocks. I mean, an IP address on the market today costs 30 cents to lease and 20 euro to buy. You can get, if you go like on an IP leasing market, you can get like an entire network block and a single IP will cost you 30 cents. So if they block an IP, these streamers will just need to allocate 30 cents of their money to get a new one and evade the block. And same goes for domain names. Domain names goes from 50 cents to 15 euro. So again, if you are a platform that is making a lot of money out of this illegal streaming, you have a very easy tool to evade this kind of blocking.

You can invest money and just escape the blocking. And the problem is that blocking, the way that they are implemented, lasts forever. There is no verification after if the illegal resource is not there anymore. So we are polluting the Internet with blocks at a level that they should not be there. And these blocks are lasting forever and harming users that will reuse these resources later on. Because, yes, Internet is a big place, but we reuse resources constantly on the Internet. IP gets reused. They get reassigned to new people. You can lease the IP that someone else was leasing before. You can register a domain that expires after someone was using the domain before. And the other problem is that it’s also being proved ineffectively from an economic perspective.

Because the amount of subscription after this platform was introduced in Italy didn’t went up. And so it has been considered a good example, but the numbers show that this is not a really good example. And Spain and France that are once ago down the same road, and some other European countries that were once ago down the same road, seems to not understand that this is not a good solution. and now to solve this problem basically the Italian regulator wants to be even more aggressive with the internet providers saying that these blocks need to be applied to all VPNs all the recursive resolver, all the CDN out there but again we cannot differentiate traffic when it comes from a specific country and it’s very hard to do and unless we accept the faith that these blocks should be done for all the internet users something that is illegal in a specific country may not be illegal in another country and we should not harm users in other countries this may be problematic and it in general violates the idea of extraterritorial and the fact that we will reduce the freedom on the internet and the freedom for the user of the internet so the question that I have for the public is actually do we have a better alternative or not?

the majority of blocks that Piracy Shield issued were towards servers that reside within the European Union 77 % of the server blocks were within the European Union we have legislative instruments to go after these people within the border of the EU this bulletproof hosting way that they are named that are within the European Union and actually take them down and perform what’s called follow the money so basically trace back the transaction, the economic transaction that led to the creation of this service and the client of this service to actually take down this business so can we do something else? Thanks

Andre Melancia

Let’s have a look at some questions that are presented remotely We have one question and it is w

Participant

hat is the amount in percent of scans you block and how do you work with online platforms?

Miguel De Bruycker

Okay, thank you It was a question for me, I suppose How do you work with online platforms? First of all, with the Belgian internet service providers There is a constructive, non -legal, non -binding collaboration Allow me also to say that The idea of blocking IP addresses I think it’s not a good idea Because there you have too much collateral damage And it’s too difficult Collaboration with, let’s say, US hyperscalers To name them Is improving a lot the last year It is really changing For instance, there is something like The Global Signal Exchange It’s a spin -off of the Oxford University And there you have the big players The Googles, the Microsofts, the Metas Who are linked to that Global Signal Exchange platform And there you have the big players our Belgian Anti -Phishing Shield, our domains, the domains that we flag as 100 % or as good as malicious are uploaded.

And for instance, what they are doing now is they are moving emails that have links to those malicious domains from the inbox to the spam folder. So they are not deleting them, but in an automated way, they are saying they are not on the inbox anymore, they are in the spam folder. So yes, you can go to a website like that. Yes, you can click on that link, but at least you will have the notification that, well, it was in the spam folder. It’s less trustworthy. So bit by bit, we see that, for instance, last weekend, apparently Meta did remove advertisements to those malicious online shops. And they did it within hours, which for us was quite new.

So I have the impression that the last six months to one year, the collaboration is starting and that they understand that as a service provider online, when you provide a service and that can be a telco that provides a phone number or an email address, an IP address, hosting of a website, that when your service is being abused for cybercrime and you get a notification, well, you get some kind of not legal, but you get some kind of liability. So we don’t oblige internet service providers in Belgium to collaborate with us by law, but we explain them that, well, if we get notified by the population that something is wrong, that something is like the hole in the street, there is a hole, well, at least let’s work together to put a warning sign in front of that.

And the other question was, do you have any idea how much you’re blocking? I have to admit that with the more or less 40 ,000 emails that we get every day, we have quite a good view, a representative view, on phishing campaigns being sent out in Belgium. So we are doing, for the moment, analysis. And I have to admit that at the beginning, we were only able to extract 25 to 30 percent of the malicious links, because we had to be very, very, very cautious. We don’t want to be seen as government censorship, and we will not allow our system to be used as government censorship. We want to filter out malicious domains, cybercrime. Now we are pulling that up, and I think more or less we are at 60 to 70 percent.

That is what we can filter out. We see a lot of other domains that we consider as malicious, but we’re not sure enough. So I have to admit that we cannot go to 99 percent. That will probably be, but it’s a little bit like a spam filter. A spam filter is not perfect. It’s not perfect, but it’s not perfect. But imagine that we would take out spam filters on our mailbox. Our mailbox is dead, honestly. 95 % of all emails that are being sent out worldwide are being filtered out by spam filters what you get in your spam folder is less than 10 % of what is being filtered out so you have to do something to protect the environment and I think that we are at a level now if you see how it is going up that you are at a point where you have to accept that DNS warning like a spam filter is more than necessary

Andre Melancia

Thank you Miguel for a clear and elaborate answer I believe we have another question

Participant

Hi, so thank you for your attention my name is Stigl Fernandes I was a student two years ago and now I’m a university student who’s really interested in technical application to policy so I have two questions actually but maybe we can do one on one how much time do we have? do we have enough time? alright then, I’ll go right away so my first question is regarding the first presentation my understanding is that all reports come directly from users is that the case? or do you have also forwarded reports from Google for instance Gmail, Hotmail or is there maybe an automatic mail filtering system in place and the second answer is regarding last presentation It was mentioned that it is often cited as an example, the IP blocking of CDNs and such, but by whom?

Is it usually like the legislators, just the legislators for doubling down? is it the ISB companies or what stakeholders is mainly coming from? Thank you very much.

Miguel De Bruycker

Okay, thank you. Let’s say up until more or less a year ago, it was 100 % feeds of the population. What we now did is in collaboration with Belgian banks and with our more or less digital identity provider on a national level, it’s called It’s Me. We have a system, It’s Me, it’s our digital identity. That there were so much campaigns against banks and against It’s Me that they have a separate priority channel to notify malicious domains. So that is one additional channel that we have because if they get notified that, for instance, a certain bank is that there is a campaign, there is abuse of a bank and there is a malicious domain. they can notify it to us through a priority channel.

That’s one thing. And another project is called Fishnemo. I will not reveal too much because is this like public?

Andre Melancia

Fully public. Fully public.

Miguel De Bruycker

Then I have to be careful because if I tell too much, how, okay. Okay, let’s say we’re trying to find domains that are linked to Belgian government and critical infrastructure but have been registered for malicious intent. So I will not explain how we’re doing this because if I explain how, it’s probably a bit easier to circumvent. But that is an additional system. So we’re trying. Okay, is there, are there domains that are being created linked to critical infrastructure that are not owned by that critical infrastructure? absolutely what you’re trying to do.

Raffaele Sommese

Thanks again, Miguel. I’ll answer the second question. So, of course, I mean, the people that are, the stakeholders interested in this system are the copyright owners first, because they are the ones that pushed for the creation of this anti -piracy system, but there is also a lot of support from government, so from government bodies, and actually in Italy from our national regulator, that is Agicom, the regulator for the communication. And on the opposite side, I mean, operators and internet users and companies for freedom of the internet are completely against this platform. Operators mainly also because of a cost problem that this platform introduced, that they need to, the burden is on them and they don’t get any compensation for implementing these blocks.

Andre Melancia

Okay, so we already have three questions, so we have a question from so let’s take your questions first

Participant

good afternoon everyone thank you for your excellent presentation gentlemen we have representation from belgium from italy and from serbia in the room we’re talking about very similar activities i’m from an organization called clean dns we work extensively in this space i’d like to ask the presenters about the importance of collaboration between member states because it seems as though we’re all pursuing very similar interests at a national level and greater collaboration could be of extreme advantage to citizens and to governments how can we pursue that uh further in terms of the presentation that identified uh ip address uh restrictions uh reputation block list if you like i also agree that that is not uh a panacea however i can understand how at a certain level of government taking activity through what is perhaps perceived as an easy option will give a certain profile an advantage, but this is a multifaceted environment where we need all stakeholders to be involved.

So in terms of taking action to restrict phishing and those activities which are malicious, what else should be done, especially at the infrastructure level, thinking of the different providers in the chain to help us address this at a

Andre Melancia

Again, that’s a very good question, and we are in a perfect place to debate that kind of question in the European Commission. Next door, of course, we have the Parliament. One of the recommendations that I would say is get in touch with other people around the European Union one by one, grow bigger, and then you’ll be noticed a bit more by the people who usually are around these buildings and maybe sometimes, something… completely European can be born to actually attack that problem. Sadly, usually our colleagues that usually live here usually pay attention only when things get bigger enough for that. But I will pass on to both of you if you want to comment.

Raffaele Sommese

I have a comment on that. Basically, a couple of years ago already there was published a study that a collaboration between several European and CCTLD, I can pass you the name later on, several European and CCTLD led to an increased phishing detection for these CCTLDs because they were able to share the machine learning model they used trained on the different data of each CCTLD and they were able basically to detect abuse going from one CCTLD to the other CCTLD. So yes, collaboration is the key from this perspective.

Andre Melancia

Thank you. So, I guess we go to the next question. Gentleman at the end.

David Frautschy

Hello, I’m David from the Internet Society. So, I have a few comments from the presentations and also a couple of questions. On the comments, I think the analogy of IP addresses like telephone numbers can be misleading. Because when you have an urge to cut a telephone line, it’s unique. So, you can cut this line or you can cut my home line. And it will be only my house. And that’s it. IP addresses, as you explained very well, when you block IP addresses, you will be blocking many other websites, potentially. So, the impacts are enormous, potentially. You explained extensively the case of Italy. I know more. In the case of Spain. Nowadays websites Many times are composed by blocks That are just appearing in front of your face But it’s not coming from a single address But just coming in And for instance One of the blockings recently affected A payment gateway So it was all e -commerce affected In the country during this football match Not all e -commerce but most e -commerce Because when payments were to be done Requests to verify Credit card information was not possible Because this website was shut down So I think this analogy Can mislead Policymakers who just don’t know What we are talking about here So The other thing I don’t Agree is with the Blockings are difficult to do I think they are easy to do Too much easy to do Especially if the ISP doing the Blockings is an interested party Like in the case of Spain Where Where the blockings are issued by the content right ownership, right hold owner, and then in many cases they are issued and to be executed by Telefonica which is the retailer of the football matches themselves by the channel, so they are forced immediately, they want to do the blockings.

So my questions are why these policy makers are listening more to rights holders than to the technical community. We are trying to explain this is wrong. There are notorious cases of blockings. Why is this happening? That we are not able to reach out our voice correctly to the right people and explain this is wrong. Now the other question is, do you think a liability scheme would be appropriate so that right holders would be required to pay to those websites that are being affected by their IP requests

Raffaele Sommese

t

David Frautschy

o be blocked? I didn’t… O

Raffaele Sommese

kay. so on the on the example of the phone number uh i tried to explain it’s more the phone number of an entire building so the the phone number for example of a company that has many employees they’re not the phone number your phone numbers your cell phone number to make it clear um um on the on the question of the uh whatever uh this it’s easy or not it’s easy to mandate it’s easy to request the internet service provider in your country because they need to comply they cannot i mean otherwise you go then we’re there with police and you arrest whatever is not complying with that rules and regulation so the technical way exists the difficult part is what if you want to do these on a service that is residing outside the country and you want to country just for the italian users you cannot do this because there is no way you can enforce that users from italy goes here and users from all the other countries goes in another direction On the question of liability, I think you raised an important point.

And Piracy Shield blocked in October of 2024 in Italy for more than a couple of hours, drive .google .com, so the domain name of Google Drive, basically. And that block lasted for many hours. Now, arguably, Google Drive is a service that is used for many, many users for many, many companies. So it’s very hard to quantify the business impact of that blocking. We were lucky that the blocking happened on a Saturday evening where possibly not a lot of people were working. But that may have had tremendous consequences. Yet no liability was given to the content blocker. And there is no discussion of giving. Giving that liability. Basically, there is no discussion of what if something goes wrong, who needs to pay.

and the other problem is that to have that kind of liability you need to have transparency in the system so the system of the blocks that are requested needs to be public because there needs to be someone that can audit these blocks and can tell this block can happen from this day to this day hence the financial consequences that happen for me are these but none of this is in the current regulation and none of this is in the current

Andre Melancia

So we have two more questions so I’ll ask Arun and Samridhi to actually read it out and then we’ll hand it

Participant

So the question is from the perspective of a media regulatory authority that orders DNS blocks, all of the money is only a better alternative when it comes to precisely such cases of copyright infringement, pornographic platforms etc. but it doesn’t help with sites containing other types of content harmful to minors, the providers themselves as well as the hosting providers cannot be reached So what would be the better alternative here from your view?

Raffaele Sommese

That’s something very hard and that’s something where a stricter block to a certain extent is somehow required. I mean, side hosting, CSAM content are arguably illegal in the whole European country and probably the whole world. So that’s a case where you can say you need to have a block that goes beyond, even to the risk of causing collateral damage, may go beyond basically the intended purposes. The problem is also that, I mean, a lot of these content are hosted on platforms that are not responding to legal authority. And we need to make an effort to curb down the fact that these bulletproof hosting out there exist. And they can host this content that are illegal.

Not removable by any legislation in the world.

Miguel De Bruycker

well my experience is that there are different ways and a lot of different ways to respond to these crimes you can of course can follow the money you can count on law enforcement and that is absolutely necessary because if those bad guys are never caught I mean it’s like well it’s a never ending story on the other hand we can do a lot and it’s true that Belgian people that go abroad or use another provider than the five that are currently in our system they will not be warned that’s correct but let’s at least try to warn those people that we can warn my experience is that for most of the providers and for me a provider that can be a telco for a phone number that can be whatsapp can be meta that can even be a bank that provides an online bank account or a credit card company that can be a telco for a phone number that can be a bank account or a credit card company that provide us, if you notify them that their services are being abused, they’re listening.

What they don’t want, like for instance, we have a program that is evaluating online advertisements. And at the beginning, we were notifying to Meta Advertisements, giving the references, the legal references of Belgian law. This is an infraction of Belgian law, article Y. They said, please don’t do that, because when you deliver something to Meta that has a legal reference that says, this is an infraction of law, we have to immediately send it to our legal department. And they have to start an investigation because they have, of course, that umbrella. They will take the responsibility, but it will be through their legal department. So if you want a response within hours and not days or weeks, it’s better not to put.

So we created, we looked at the policies of Google, of Meta, and we said, well, we’re going to do this. And to be honest, everything that is illegal in Belgium is almost forbidden in their policy. so it’s better to put references in general saying okay this is impersonational and you say this is what they are doing but in their terms and conditions and my experience is that they do respond and they do take action but that’s not the case for all providers on the web unfortunately

Andre Melancia

Okay so we have a few more questions there’s also another one remotely so we will try to make this quick so that everyone is heard before handing it over to Peter let me just add something to this question because this question mentions some of this one of the things that we’ve been seeing about internet blocking in general is situations where we have internet social media for instance in Australia being blocked to minors in the UK they want to implement a verification that actually causes a lot of issues, especially related to freedoms, because suddenly you are not free, you are not allowed to look at the Internet in an anonymous way. So we still have a few minutes to talk about this later, but it is important to point out that this actually causes a lot of harms related to the freedoms that we have, freedom of speech, and especially the typical scenarios of countries, and we have seen this, a lot of countries trying to control the population that is no longer able to use the Internet as a means to gather and as a means to start some peaceful protests, etc.

So let’s hand it over to Peter at this moment. Yeah, thank you. Very interesting. Peter, do you want to? Did it work? No, it worked. Sorry. Peter Kovdynik, apologies.

Peter Kovdynik

So again, interesting discussion. Not the first time we’re having this topic, and discussion is progressing, but we always get new players in the game. I think there are a couple of things, or a couple of parts that may deserve a bit more attention, like cross -border issues, voluntary versus involuntary blocking, and circumvention technologies. And then I’ve heard twice I can’t tell you what we’re doing, because otherwise some things would happen. That’s a bit between security by obscurity and a magician sharing all their tricks. But from a state actor, or from a public authority, I do think there’s a certain transparency obligation, especially given that there are private markets participants that provide protection services, and sometimes public authorities are actually interfering with that part of the market.

Finally, I think the most important part when we talk about DNS or internet blocking… I still don’t understand why content mitigation, which is at the application layer or the user level, would have to happen at the infrastructure level, which is the core governance question. Why do we fiddle with it, even though it is not very granular? And what would the participants do to arrive at more appropriate and more granular alternatives? We’ve heard about spam folders that address mail issues. There are browser plug -ins and so on and so forth, which are more lean towards the user, give the user more control over the blocking and the protection, and also would not fiddle with the core infrastructure and avoid the cross -border issues as well.

Thank you so much.

Andre Melancia

Miguel, could you address the transparency?

Miguel De Bruycker

Yes, absolutely. As I said, everything we do is transparent, but that doesn’t mean you have to be transparent. You have to make it public. If you have security measures in place, I mean it’s like an antivirus you don’t publish all signatures that you have found immediately otherwise the counterpart knows that that’s the way you try to protect your environment and of course those systems can be abused to my knowledge ours is absolutely not and I would never accept that. A spam filter could be abused by governments to remove specific content if you say we don’t want people to receive messages with this content or on this topic technically you could do that but that doesn’t mean that we have to remove spam filters as I said if we would do that the email system is dead so it’s about finding the right balance between applying security measures in a correct way, in a transparent way and as I said we are very transparent and we are under the control of the DPA and well, protecting your citizens and finding that right balance that is I think what is first the most important, but I do understand the concerns but on the other hand not doing nothing is I think more of a concern than trying to do something

Raffaele Sommese

And I want to add that I completely agree IP and DNS are the wrong place where to block things for certain kind of content and you need to go to the source, you need to block the content and then source, especially if the content are within the European Union, because we have other mechanisms to act

Andre Melancia

Okay, so I think we have about 10 minutes and we still have to see the messages let’s do it like this, so we have four pending questions let’s take the questions now and then we’ll try to come up with answers for all of them if that’s okay feel free to start.

Participant

Yeah, I’m sure quickly here. Could you just once again explain in a way to a layman, to a child, or to an average politician, why exactly the technical framework is not apt to help with the question of child protection online? So what’s really a very, very basic explanation why not for a politician? Please continue.

Olivier Crepin Leblond

Thank you, Olivier Crepin-Leblanc. I’m with the United Kingdom Charter of the Internet Society. We’ve had to deal for a long time with the UK government in regards to age verification, online harms, etc. One of the problems we find with politicians is that they have a very limited lifespan of a few years and need immediate solutions. They like silver bullet scenarios and some firms… Some companies go, speak to them, and say, we have this stuff about it. We have the answer for you, this immediate thing, which unfortunately is not the solution because it’s got a whole lot of repercussions. Unless we can prove that there are no silver bullets and these are complicated issues that need balance, that need certain mitigation and analysis, we will continue having problems where there will be the false positives and the Internet will be somehow a lot harder to use if all these things are implemented, such as age verification, etc., etc.

Petra, you were there.

Petra Arts

Yes, thank you. Petra Arts from Klaus Flair. Two small comments. Thank you, Alfredo, I think, for also highlighting the issues around global resolvers. We obviously have quite a lot of concerns around that from some of the developments that are happening in some of the countries from the legislation perspective. Thank you for highlighting that. I wanted just to point to people that want to kind of know more about the economic impact of looking to a study that we commissioned last year from Analysis Mason, a consultant center. it’s to be found online it’s called the economic cost of network blocking where we try to also illustrate a number of these kind of the things that were mentioned by a number of people in the room and maybe it’s helpful for for people as a resource so thank

Philip Struyf

you yeah i think it’s also listed in the further reading uh section of the on the wiki yeah yeah it’s there now final question online um do you have supervised methodology to ensure that you preserve freedom of speech ensuring you’re not turning into a censorship arm of a government or

Miguel De Bruycker

even private parties oh yes absolutely we are um we are detecting phishing emails so it’s like an antivirus um it is detecting the known bad it’s about identifying the known bad and bad means you know you’re not you’re not you’re not you’re not you’re not you’re not you’re not within a specific cyber crime domain and not in a content domain. And we do check that we never go on content. It’s not because somebody is saying something like adult sites trying to protect young people that is currently absolutely not what we are doing because we don’t have a correct solution for that. And coming back to, for instance, Cloudflare, we are actually in good contact with Cloudflare.

Because more than half of the malicious domains are using Cloudflare, are using that infrastructure to anonymize themselves partially. But as we understand with the collaboration of Cloudflare, they don’t want to be, let’s say, a provider for cybercrime too. And they’re also asking, okay, how can we collaborate and how can we with governments have a better exchange so that… we are not those ones that make sure that those bad guys are never being called so it’s about finding a way in a balanced way together with those I also call you a service provider in that way you’re delivering a service on how can we do it but not by law, by talking to each other by listening to each other what can we do together and that is I think the model that we set up and that we’re trying to defend

Andre Melancia

Raffaele?

Raffaele Sommese

I will be extremely brief to answer, there is no silver bullet and everything we do on the internet as consequence every action that we take and where we interact with the internet protocol in general as consequence there is all there needs always to be a balance between the risks and the benefit of the action that we take and that balance needs to be discussed with technical brewers that’s the important part

Andre Melancia

thank you, now over to Philip for the messages from this session

Philip Lucas

yes, I’ll very briefly share the messages I did my best to to summarize the conversation, so you should be able to see that now, so so, the first message is that the evolving nature of online harms requires a multi -stakeholder collaboration to be tackled effectively, as we heard from Miguel and this may take form of collaboration among industry players or across industry and the government second, intervention of the technical area by blocking the IP addresses or DNS have significant impact on the availability of online resources, like websites and cause unnecessary collateral damage without necessarily addressing the legal content in question and thirdly that interventions on illegal content to increase online safety should be proportionate so the rights of

Andre Melancia

Okay, we have one or two minutes if anyone wants to comment

Participant

Thank you, Rishi, Clint, DNS I’d like to ask the panelists this is coming just on the apologies I was going to ask for the youth diggers for one recommendation for them to think about arising out of this session

Raffaele Sommese

Sorry, can you repeat?

Participant

I would like to ask for one recommendation from the panelists for the youth diggers attending this session

Raffaele Sommese

Be active and participate in this discussion because I mean, some of these discussions center around the fact that part of these blocking are for protecting young people on the Internet. You need to have a voice on what is really the harm you want to be protected from. It’s more important that this comes from you.

Miguel De Bruycker

The Internet is not public space. What I mean is that when I leave this building, I’m on the street. There, as a government, you can put cameras, you can even put policemen, you can control. The Internet, when I connect here to the web, it’s a privately owned… Well, this is now government, but that’s the exception. I mean, you have a private device connecting to a private ISP, going to carriers, services. They’re all owned by companies. As a government, you don’t enter private space just like that. It’s a different story. Meaning that if you want to achieve something, we will have to collaborate. With respect for each other and understanding that ecosystem. It’s private space. It’s privately owned.

Yes, but that means that those service providers, those private companies, they’re taking a lot of responsibility. And we have to, together with governments, figure out how to secure that in a balanced way together in that private space.

Andre Melancia

Okay, so we are perfectly on time So let’s just wrap this up for today I think that it’s not going to be the end of this conversation because this topic will go on forever So let me just mention that at this moment we have 73% of countries which are no longer democracies if some of them ever were and these kind of limitations that we see especially the last topics that we talked about these kind of problems are growing more and more so we will discuss them in future events as well. We want to thank you all very much for being here. We want to especially thank Miguel and Rafael for being our guests. We also want to thank everyone who participated, and especially we want to thank Philip Lucas, and we want to thank Arun and Samridi for moderating remote sessions.

And of course, Philip and I, we really want to thank everyone for being here in person or remotely, and I hope you have a great event coming up. Okay, thank you everyone.

Related ResourcesKnowledge base sources related to the discussion topics (21)
Factual NotesClaims verified against the Diplo knowledge base (10)
Confirmedmedium

“Miguel De Bruycker was identified as Director General of the Centre for Cybersecurity Belgium, and the CCB was described as a central public authority for Belgian cybersecurity policy.”

The knowledge base confirms the institutional role of the Centre for Cybersecurity Belgium as the body that monitors, coordinates, and oversees Belgian cybersecurity policy, and notes that CERT.be operates as its national CSIRT [S123]. This supports the report’s description of De Bruycker speaking from the CCB’s central operational and policy role.

Additional Contextmedium

“Belgium’s anti-phishing model was presented as a technical protection measure aimed at cybercrime rather than general content regulation.”

This framing is consistent with broader knowledge-base material distinguishing cybercrime-oriented blocking of phishing, malware, and botnets from wider content-control regimes. A technical session report notes that DNS or other filtering is commonly used to hinder access to phishing websites, malware, and botnets, while also highlighting the need for care in implementation [S87].

Confirmedhigh

“The Belgian Anti-Phishing Shield works through DNS-based warning mechanisms rather than removing content.”

The technical distinction is supported by the knowledge base: blocking name resolution means the content can continue to exist while access is hindered unless the exact IP address is known [S87]. Separately, guidance on jurisdiction stresses that taking down a domain removes all websites and e-mail accounts associated with that domain, showing why DNS-layer intervention is different from content removal [S54].

Additional Contexthigh

“De Bruycker stressed that Belgium’s system does not remove content and is meant to show a warning page rather than impose an absolute access ban.”

The knowledge base supports the underlying technical and policy distinction. DNS-level blocking affects resolution rather than deleting hosted material [S87], while domain takedowns are much more sweeping because they remove every website and e-mail account on the domain [S54]. This adds context to the report’s claim that the Belgian model was framed as a warning-based intervention rather than full removal.

Additional Contextmedium

“Belgium’s approach involved cooperation with major ISPs and used secure DNS arrangements.”

The knowledge base contains relevant technical background on DNS as an Internet infrastructure layer that can be altered by ISPs, including examples of ISP-operated DNS manipulation and discussion of DNS policy’s broad effects [S36] and [S86]. While it does not verify the Belgian program details, it supports the plausibility and significance of ISP-based DNS implementation.

Additional Contextmedium

“The report linked the growth of phishing reports in part to AI making malicious content easier to generate at scale.”

The knowledge base adds supporting context that AI has created new cybersecurity threats and is being used in phishing campaigns, including for sophisticated fake images, videos, and social engineering [S129]. It also notes the rise of deepfake-enabled fraud and scalable multimodal deception, which reinforces the report’s point about AI increasing the scale and realism of scams [S130].

Confirmedmedium

“Belgium had launched a public awareness campaign encouraging users to forward suspicious messages, and this anti-phishing effort was part of a broader cybersecurity-awareness strategy.”

Belgium’s cybersecurity strategy explicitly states that the CCB raises awareness of major cyber threats and how to protect against them, and that citizens should be informed and aware of the main risks when using ICT and the internet [S123]. The knowledge base also highlights awareness-raising as an important anti-cybercrime measure more generally [S35].

Confirmedhigh

“The discussion expanded from a concrete anti-phishing case toward wider debates about blocking, proportionality, transparency, technical architecture, and fundamental rights.”

The knowledge base confirms that these are standard fault lines in discussions on Internet blocking and filtering. Reports on content blocking discuss proportionality, transparency, overblocking risks, and freedom of expression concerns [S87] and [S88], while DNS-policy materials stress that infrastructure-layer decisions can have broad rights implications [S86].

Additional Contexthigh

“De Bruycker emphasized proportionality, transparency, and restraint as safeguards for the Belgian system.”

The knowledge base strongly supports the relevance of these safeguards. Discussion of Internet blackouts and other restrictions highlights the principle that governments should act proportionately in cyberspace and in accordance with law [S88]. Separate material on content blocking stresses that lack of transparent and accountable processes can be harmful and can lead to overblocking [S87].

Additional Contextlow

“The moderator framed the session as an interactive discussion with audience and remote participation rather than a sequence of long prepared speeches.”

The knowledge base does not verify this specific session setup, but it provides strong background that Diplo and related Geneva events routinely emphasized remote participation, interaction, and blended formats rather than purely in-room exchanges [S118], [S119], [S120], and [S121].

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S113
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S115
Closing the Governance Gaps: New Paradigms for a Safer DNS — However, it was argued that these amendments could be strengthened by providing more concrete measures and objectives. T…
S116
Internet and jurisdiction: a necessary dialogue — However, when a domain is taken down, requesters need to know that it actually means removing every website and every e-…
S117
Hey, Govs – leave those ISPs alone! (2) — Keeping the messenger alive requires an understanding of the complex multidisciplinary area of Internet governance, but …
S118
E-Participation Webinar – Remote Participation in International Organisations — Remote Participation programmes and initiatives make International Agencies more transparent and inclusive.  This was th…
S119
Remote Participation – Opportunities and Challenges for Multilateral Diplomacy — Panel at the 2012 WSIS Forum: Thursday, 17 May 2012 (video) The Internet has entered conference rooms worldwide. Discuss…
S120
Geneva Engage in videos — We heard speakers from the Internet Corporation for Assigned Names and Numbers (ICANN) (Nigel Hickson, Vice President, G…
S121
E-participation Day: towards a more open UN? — The E-participation Day was part of the Geneva E-diplomacy Platform and built on the first Geneva E-diplomacy Day (16 No…
S122
Privacy issues discussed at CONNECTing the Dots — She said that although it is less visible and more controversial, privacy needs to be discussed more. In addition, more …
S123
Belgium Cybersecurity Strategy 2.0 | 2021-2025 — International cooperation is an important pillar of a decisive national cybersecurity policy. Cybersecurity requires a h…
S124
Agenda item 5: discussions on substantive issues contained inparagraph 1 of General Assembly resolution 75/240 (continued) – session 1 — Echoing China’s concerns about the adverse effects of attributing malignant ICT operations, Belarus emphasises the need …
S125
Fake news: what’s behind the media frenzy — In fact, the walls of these echo chambers can be so thick that ‘any misinformation spreads almost instantaneously within…
S126
Time to (re)take responsibility — It’s not a gun that kills someone; it’s the person who pulls the trigger. It’s not Facebook or e-mail that ruins people’…
S127
Text message campaign spread coronavirus disinformation — During the last couple of days a text message campaign spreading coronavirus disinformation hit the United States. The m…
S128
Governments vs ChatGPT: Investigations around the world — Read more: Italy’s rage against the machine In compliance, OpenAI geo-blocked access to ChatGPT to anyone residing in …
S129
AI and Digital in 2023: From a winter of excitement to an autumn of clarity — Cybersecurity: Preserving the internet in difficult times In 2023, cybersecurity has emerged in a wide range of con…
S130
Deepfakes and the AI scam wave eroding trust — How can societies respond to synthetic deception? Deepfakes remain one of the most disruptive and unsettling AI develo…
S131
Addressing discrimination in data-driven advertising: Regulatory opportunities and failures within the EU — The marketing industry has become a data-driven realm. It uses data to predict consumer preferences, to anticipate their…
S132
[Briefing #14] Internet governance in April 2015 — Radunovic also noted that an investigation of attacks by Russian hackers from last autumn revealed that some of Obama’s …
Speakers Analysis
Detailed breakdown of each speaker’s arguments and positions
M
Miguel De Bruycker
10 arguments156 words per minute3480 words1337 seconds
Argument 1
Belgian anti-phishing shield as a practical protective layer – Miguel De Bruycker
EXPLANATION
Miguel presents the Belgian Anti-Phishing Shield as a concrete technical mechanism to reduce phishing harm by warning users before they access malicious domains. His argument is that even if such protection is imperfect, it provides a meaningful layer of defense for ordinary users and helps create a safer online environment.
EVIDENCE
He explains that after launching a public phishing-reporting campaign, Belgium created the Belgian Anti-Phishing Shield with major ISPs, using DNS synchronization so that when a user tries to visit a domain flagged as almost certainly malicious, they receive a warning page instead [21-25] [34-45]. He also says the system displayed warning pages 185 million times in the previous year, which he offers as evidence that the tool is having a positive effect in practice [60].
EXTERNAL EVIDENCE (KNOWLEDGE BASE)
External sources support layered anti-phishing prevention: cybercrime prevention requires both user awareness and technological protection measures [S33], and sophisticated phishing specifically requires robust security measures beyond basic filters alongside education and awareness [S34].
MAJOR DISCUSSION POINT
Major discussion point 1: Technical measures to address phishing and online harms
AGREED WITH
Raffaele Sommese, Philip Lucas, Peter Kovdynik, David Frautschy
DISAGREED WITH
Raffaele Sommese, Peter Kovdynik
Argument 2
User reports act as crowd-sourced first detection, then automated analysis and partner review classify malicious domains – Miguel De Bruycker
EXPLANATION
Miguel argues that the Belgian system begins with citizens acting as a first filter by forwarding suspicious messages, after which automated and assisted analysis determines whether domains are malicious. The design combines public participation, technical processing, anonymization, and third-party review rather than relying on a single detection method.
EVIDENCE
He says the public is encouraged to forward suspicious messages to a dedicated address, and describes this as a form of crowdsourcing in which the population performs the first evaluation by noticing that something seems wrong [23-26] [101]. He then explains that the center automatically extracts links from reports, anonymizes the data, runs it through detection engines such as phishing-kit signature matching, and works with two commercial partners to evaluate anonymized links and flag them as malicious [79-84].
MAJOR DISCUSSION POINT
Major discussion point 2: Design, operation, and safeguards of the Belgian anti-phishing system
Argument 3
The system is DNS-based, voluntary with ISPs, opt-out for users, and aims only at domains judged almost certainly malicious – Miguel De Bruycker
EXPLANATION
Miguel argues that the Belgian anti-phishing model is carefully scoped: it relies on voluntary ISP participation, operates as an opt-out DNS warning system, and only flags domains when the center is extremely confident they are malicious. The point is to provide targeted protection while minimizing overblocking and preserving user choice.
EVIDENCE
He states that the system works with the main internet service providers on a voluntary basis and uses DNS synchronization so that customers of participating providers see a warning page when trying to access a domain assessed as 99.999% certainly malicious [34-35] [41-45]. He further notes that users can opt out by changing DNS settings, can contest warnings, and that the center maintains a known-good list and a low-risk approach to avoid false positives and overblocking [36-49] [64].
EXTERNAL EVIDENCE (KNOWLEDGE BASE)
There is relevant context on DNS-focused abuse mitigation: DNS is described as a critical shared Internet resource, and narrowly scoped action against clearly malicious categories such as phishing, malware distribution, botnets, and malicious spam is presented as a legitimate and limited form of ‘technical DNS abuse’ response [S37].
MAJOR DISCUSSION POINT
Major discussion point 2: Design, operation, and safeguards of the Belgian anti-phishing system
DISAGREED WITH
Raffaele Sommese, Peter Kovdynik
Argument 4
Transparency, proportionality, and DPA oversight are necessary to avoid turning phishing detection into censorship – Miguel De Bruycker
EXPLANATION
Miguel argues that anti-phishing interventions are legitimate only if they are transparent, proportionate, and subject to oversight, so they do not become a censorship mechanism. He frames the Belgian model as focused strictly on cybercrime indicators, not on regulating lawful content or opinions.
EVIDENCE
He says that false positives, overblocking, and the risk of government abuse are serious concerns, and responds by emphasizing proportionality and transparency, repeating that the center does what it says and says what it does [60-64]. He also explains that Belgium has a strong data protection authority overseeing the system, and later clarifies that the system targets phishing and known bad cybercrime indicators rather than content, including explicitly stating that it is not being used for areas such as adult-content controls [101-103] [300-303] [323-325].
EXTERNAL EVIDENCE (KNOWLEDGE BASE)
External sources reinforce the need to balance security with privacy and rights, stressing transparency, legal safeguards, and independent oversight to avoid abuse [S39]. Additional commentary warns that poorly bounded security measures can chill expression and argues for transparency and human-rights-centered cooperation rather than coercive approaches [S40].
MAJOR DISCUSSION POINT
Major discussion point 2: Design, operation, and safeguards of the Belgian anti-phishing system
AGREED WITH
Raffaele Sommese, Peter Kovdynik, David Frautschy, Participant
DISAGREED WITH
Raffaele Sommese, Andre Melancia, Olivier Crepin Leblond
Argument 5
Warning users is imperfect but still valuable, much like spam filtering or warning signs around known hazards – Miguel De Bruycker
EXPLANATION
Miguel argues that partial, imperfect interventions can still be justified if they reduce harm at scale. He compares warning systems to physical hazard signs and spam filters: they do not eliminate danger entirely, but they materially improve safety.
EVIDENCE
He uses the analogy of a hole in the street, saying that even if people can still fall in, government should at least put up warnings when it knows there is danger [60]. He also compares DNS warnings to spam filters, arguing that if spam filters were removed email would become unusable, and says DNS warnings are similarly necessary even though they cannot catch everything [189-197].
EXTERNAL EVIDENCE (KNOWLEDGE BASE)
A broader analogy is supported by discussion of failed or delayed public warning systems: even basic warning mechanisms can be crucial for reducing harm, and failures in timely alerts can have severe consequences [S44]. At the same time, external commentary cautions that precautionary interventions must account for false positives and trade-offs rather than assuming ‘better safe than sorry’ is always justified [S42].
MAJOR DISCUSSION POINT
Major discussion point 4: Effectiveness limits of blocking and alternative approaches
AGREED WITH
Raffaele Sommese, Peter Kovdynik, Olivier Crepin Leblond, Nenad Bogunovic
DISAGREED WITH
Raffaele Sommese, Peter Kovdynik
Argument 6
The right approach is balance: doing nothing is not acceptable, but interventions must be carefully scoped – Miguel De Bruycker
EXPLANATION
Miguel argues that the policy question is not whether to intervene at all, but how to strike the right balance between safety and restraint. In his view, inaction in the face of large-scale cybercrime is more dangerous than carefully bounded protective measures.
EVIDENCE
He concludes that a secure online environment requires protective measures such as antivirus, spam filters, and DNS warning systems, and says the key question is how to find the right balance in using them [67-72]. He later repeats that while he understands concerns about abuse, doing nothing is a greater concern than trying to protect citizens in a transparent and balanced way [300-303].
EXTERNAL EVIDENCE (KNOWLEDGE BASE)
This balancing approach is strongly echoed in external sources: cybercrime prevention requires multiple strategies and cooperation across individuals, organizations, governments, and industry rather than inaction [S33], while security and privacy must be balanced through transparent, rights-respecting frameworks [S39] [S40].
MAJOR DISCUSSION POINT
Major discussion point 4: Effectiveness limits of blocking and alternative approaches
AGREED WITH
Raffaele Sommese, Peter Kovdynik, Olivier Crepin Leblond, Nenad Bogunovic
DISAGREED WITH
Raffaele Sommese
Argument 7
Collaboration with hyperscalers and platforms is improving, leading to faster action such as moving harmful emails to spam or removing malicious ads – Miguel De Bruycker
EXPLANATION
Miguel argues that practical collaboration with large online platforms is becoming more effective and is an important part of reducing online harms. Instead of relying only on legal compulsion, he highlights operational cooperation that produces faster protective outcomes.
EVIDENCE
He describes participation in the Global Signal Exchange, where malicious domains identified by the Belgian system are shared with major companies such as Google, Microsoft, and Meta [174]. He says that emails containing those links are now being moved from inboxes to spam folders and that Meta removed advertisements for malicious online shops within hours, which he presents as evidence that cooperation has improved in the last six to twelve months [175-180].
MAJOR DISCUSSION POINT
Major discussion point 6: Cross-border issues and cooperation across actors and states
AGREED WITH
Raffaele Sommese, Philip Lucas, Participant, Andre Melancia
DISAGREED WITH
Raffaele Sommese
Argument 8
Because the internet is largely private space owned and operated by companies, governments must work collaboratively with service providers rather than act unilaterally – Miguel De Bruycker
EXPLANATION
Miguel argues that the internet is fundamentally built on privately owned infrastructure and services, which means governments cannot simply impose security outcomes without cooperation. Effective online harm reduction therefore depends on building relationships with providers and understanding their role and responsibilities.
EVIDENCE
He says that unlike a public street, the internet consists mainly of private devices, private ISPs, carriers, and services owned by companies, so governments do not simply enter that private space and control it directly [341-349]. He concludes from this that governments and service providers must collaborate respectfully and jointly figure out how to secure that private space in a balanced way [350-354].
EXTERNAL EVIDENCE (KNOWLEDGE BASE)
External sources provide strong context that cybercrime prevention depends on cooperation between government and private industry [S33], and that multistakeholder engagement across state, private sector, and civil society is necessary for effective Internet governance and resilient digital policy [S51].
MAJOR DISCUSSION POINT
Major discussion point 8: Role of private infrastructure providers and practical cooperation
AGREED WITH
Raffaele Sommese, Philip Lucas, Participant, Andre Melancia
Argument 9
Providers often respond better to policy-based abuse reports than to formal legal citations, which can slow action through legal departments – Miguel De Bruycker
EXPLANATION
Miguel argues that operational language aligned with platform policies can be more effective than formal legal accusations when quick intervention is needed. His point is pragmatic: legal escalation may trigger slow internal review processes, whereas policy-based notifications can produce rapid action.
EVIDENCE
He recounts that when Belgian authorities initially sent Meta abuse notifications citing Belgian legal provisions, Meta asked them not to do that because legal references forced the matter into the company’s legal department for investigation [272-277]. He says they instead began framing reports in the language of platform terms and conditions, and found that platforms responded more quickly because content illegal in Belgium was usually already prohibited under platform policies [278-279].
EXTERNAL EVIDENCE (KNOWLEDGE BASE)
There is relevant contextual support from studies of cross-border provider responses: service providers often respond through discretionary, trust-based cooperation mechanisms rather than only through formal legal channels, and these relationships can produce faster action within policy and legal constraints [S55].
MAJOR DISCUSSION POINT
Major discussion point 8: Role of private infrastructure providers and practical cooperation
Argument 10
Service providers whose infrastructure is abused for cybercrime bear practical responsibility to act once notified – Miguel De Bruycker
EXPLANATION
Miguel argues that while this may not always be a formal legal duty, providers have a practical responsibility to respond when informed that their services are being used for cybercrime. He extends this reasoning across different types of providers, from telecoms and hosts to banks and social platforms.
EVIDENCE
He says that when an online service provider offers phone numbers, email addresses, hosting, or similar services that are abused for cybercrime and receives notice of that abuse, some form of responsibility arises even if it is not strictly legal liability [181-182]. He later broadens this by saying that many providers, including telcos, WhatsApp, Meta, banks, and credit card companies, will listen and respond when notified that their services are being abused [271].
EXTERNAL EVIDENCE (KNOWLEDGE BASE)
External sources support the view that service and hosting providers are uniquely positioned within Internet infrastructure to help prevent cybercrime, though the issue is described as nuanced because it raises questions of responsibility, liability, and technical limits [S55]. Additional discussion notes that proactive engagement by infrastructure actors is important when handling abuse reports and mistaken requests [S56].
MAJOR DISCUSSION POINT
Major discussion point 8: Role of private infrastructure providers and practical cooperation
A
Andre Melancia
4 arguments155 words per minute1283 words496 seconds
Argument 1
Session focus should be on concrete technologies and audience interaction – Andre Melancia
EXPLANATION
Andre frames the session as a practical discussion centered on technologies and technical measures, while also emphasizing audience participation. He argues that the discussion should not be a one-way panel but a collaborative exchange among experts in the room and remote participants.
EVIDENCE
At the start, he introduces the workshop as focused on technologies and technical measures to address online harms and says the goal is to maximize interaction from the audience after brief opening remarks from speakers [1-2] [7]. He also stresses that everyone present is an expert with valid points to share and that questions and comments from both in-person and remote participants are welcome [7].
MAJOR DISCUSSION POINT
Major discussion point 1: Technical measures to address phishing and online harms
Argument 2
Processing large reporting volumes requires clarity on whether AI, humans, or both are used – Andre Melancia
EXPLANATION
Andre’s argument is that when a system handles tens of thousands of phishing reports each day, it is important to understand the decision-making process behind classification. He raises the issue of whether such systems rely on AI, human review, or some combination, implying that this affects reliability and accountability.
EVIDENCE
After hearing the scale of reports received by the Belgian system, he explicitly asks how the requests are processed and whether the center uses AI, humans, or some uncertain mix [74-78].
EXTERNAL EVIDENCE (KNOWLEDGE BASE)
External sources add context that automated moderation systems can be useful but suffer from bias and error, especially across languages, and should not be treated as fully reliable substitutes for accountable human oversight [S50].
MAJOR DISCUSSION POINT
Major discussion point 2: Design, operation, and safeguards of the Belgian anti-phishing system
Argument 3
Government attention often comes only when concerns scale up politically, so coordinated advocacy matters – Andre Melancia
EXPLANATION
Andre argues that policymakers often respond only once an issue becomes large and visible enough, so advocates should build coalitions and scale their concerns strategically. He presents coordinated engagement across the EU as a practical way to gain institutional attention.
EVIDENCE
Responding to a question about collaboration, he recommends that participants connect one by one across the European Union, grow their network, and become visible enough that institutions around the European Commission and Parliament notice them [222-225]. He adds that officials in those buildings usually pay attention only when issues have grown big enough, which he offers as a realistic description of how political attention works [224-225].
EXTERNAL EVIDENCE (KNOWLEDGE BASE)
External sources provide broader governance context that effective Internet policy depends on inclusive multistakeholder processes and active stakeholder participation to influence formal outcomes [S51] [S52].
MAJOR DISCUSSION POINT
Major discussion point 5: Transparency, accountability, and governance of blocking systems
AGREED WITH
Miguel De Bruycker, Raffaele Sommese, Philip Lucas, Participant
Argument 4
Child protection and age-verification measures can create serious harms to privacy, anonymity, and freedom of expression – Andre Melancia
EXPLANATION
Andre argues that measures justified in the name of child protection, such as age verification or restrictions on minors’ access to platforms, can undermine core freedoms. He warns that these systems may erode anonymous internet use and can be repurposed in ways that affect free expression and civic mobilization.
EVIDENCE
He points to examples such as social media restrictions for minors in Australia and verification plans in the UK, saying these create harms related to freedoms because they make anonymous internet use more difficult [280]. He then broadens the warning by noting that such limitations can affect freedom of speech and can be used by governments to prevent people from using the internet to organize and gather peacefully [281].
EXTERNAL EVIDENCE (KNOWLEDGE BASE)
External sources support this concern by warning that security-focused digital measures can erode privacy and enable monitoring without sufficient oversight [S39], and that surveillance-related environments can chill online expression and self-censorship [S40].
MAJOR DISCUSSION POINT
Major discussion point 7: Child protection, age verification, and fundamental rights
AGREED WITH
Raffaele Sommese, Olivier Crepin Leblond, Participant, Raffaele Sommese
DISAGREED WITH
Raffaele Sommese, Miguel De Bruycker, Olivier Crepin Leblond
N
Nenad Bogunovic
1 argument148 words per minute164 words66 seconds
Argument 1
Similar national systems are being developed elsewhere and must evolve toward AI, spear-phishing, SMS, and other scam indicators – Nenad Bogunovic
EXPLANATION
Nenad argues that anti-phishing systems should not remain narrowly focused on fake links and websites because phishing tactics are evolving. He points out that national cybercrime reporting systems under development, including Serbia’s, need to adapt to spear-phishing, AI-generated content, SMS phishing, and other emerging indicators.
EVIDENCE
He states that Serbia is developing a national cybercrime report system and that the Belgian system is one of the models informing their work, including its anti-fraud and anti-phishing components [92-93]. He then asks whether the Belgian system will evolve beyond links and fake websites toward current phishing trends such as spear phishing, AI-generated content, and SMS phishing, noting that this is also a major challenge in Serbia [94-98].
EXTERNAL EVIDENCE (KNOWLEDGE BASE)
External sources support the claim that anti-phishing systems must evolve with changing threats: sophisticated phishing and social engineering require continuous improvement of cybersecurity practices and advanced measures beyond traditional filters [S34]. Broader cybercrime frameworks also stress technology-neutral implementation, capacity building, and rapid adaptation by national systems [S35].
MAJOR DISCUSSION POINT
Major discussion point 1: Technical measures to address phishing and online harms
AGREED WITH
Miguel De Bruycker, Raffaele Sommese, Peter Kovdynik, Olivier Crepin Leblond
P
Philip Lucas
3 arguments127 words per minute123 words58 seconds
Argument 1
Multi-stakeholder collaboration is needed to tackle evolving online harms effectively – Philip Lucas
EXPLANATION
Philip summarizes the session by arguing that online harms are dynamic and therefore require collaboration among multiple actors rather than isolated responses. He frames this as a core takeaway from the discussion, linking effective action to cooperation across industry and government.
EVIDENCE
In his closing summary, he states that the evolving nature of online harms requires multi-stakeholder collaboration to be tackled effectively and says this may take the form of collaboration among industry players or between industry and government [333].
EXTERNAL EVIDENCE (KNOWLEDGE BASE)
This is directly supported by external sources emphasizing that cybercrime prevention requires cooperation and resources from government and private industry [S33], and that multistakeholder engagement is essential for inclusive and effective Internet governance [S51].
MAJOR DISCUSSION POINT
Major discussion point 1: Technical measures to address phishing and online harms
AGREED WITH
Miguel De Bruycker, Raffaele Sommese, Participant, Andre Melancia
Argument 2
Illegal-content interventions should remain proportionate because technical blocking can unnecessarily restrict access to lawful resources – Philip Lucas
EXPLANATION
Philip argues that technical interventions aimed at increasing online safety must be proportionate, because infrastructure-level blocking can have broad side effects on lawful content and services. His summary captures the session’s emphasis on safeguarding rights while responding to harm.
EVIDENCE
He summarizes that blocking IP addresses or DNS can significantly affect the availability of online resources and cause unnecessary collateral damage without necessarily addressing the illegal content itself [333]. He then states that interventions on illegal content to increase online safety should therefore be proportionate, explicitly tying this to rights protection [333].
EXTERNAL EVIDENCE (KNOWLEDGE BASE)
External sources support this caution: domain takedowns can unintentionally remove every website and email account attached to a domain if requests are mis-targeted [S54]. Broader commentary on precautionary action also warns that false positives and collateral damage must be weighed carefully rather than assuming intervention is automatically justified [S42].
MAJOR DISCUSSION POINT
Major discussion point 3: Internet blocking, overblocking, and collateral damage
AGREED WITH
Miguel De Bruycker, Raffaele Sommese, Olivier Crepin Leblond, Andre Melancia
Argument 3
Effective online harm reduction depends on collaboration among industry players and between industry and government – Philip Lucas
EXPLANATION
Philip argues that harm reduction online cannot be achieved by any single actor and instead depends on cooperation across the ecosystem. He specifically highlights both intra-industry collaboration and public-private coordination as necessary forms of governance.
EVIDENCE
In the session messages, he says that effective responses to evolving online harms may take the form of collaboration among industry actors or collaboration between industry and government [333].
EXTERNAL EVIDENCE (KNOWLEDGE BASE)
External sources corroborate this directly: cybercrime prevention requires cooperation between government and private industry [S33], and international and multistakeholder collaboration are presented as central to effective digital governance [S35] [S51].
MAJOR DISCUSSION POINT
Major discussion point 6: Cross-border issues and cooperation across actors and states
AGREED WITH
Miguel De Bruycker, Raffaele Sommese, Participant, Andre Melancia
P
Peter Kovdynik
3 arguments156 words per minute264 words101 seconds
Argument 1
Infrastructure-level mitigation should be questioned when more granular user- or application-level tools may exist – Peter Kovdynik
EXPLANATION
Peter argues that it is not obvious why content mitigation should happen at the DNS or internet infrastructure layer when more precise tools may be available closer to the user or application. He suggests that more granular approaches could preserve user control and avoid unnecessary interference with core internet functions.
EVIDENCE
He asks why content mitigation, which he sees as fundamentally an application-layer or user-level issue, would have to happen at the infrastructure level, calling this the core governance question [292-295]. He also points to examples such as spam folders and browser plug-ins as alternatives that give users more control and avoid tampering with core infrastructure and cross-border internet operations [296-297].
EXTERNAL EVIDENCE (KNOWLEDGE BASE)
External sources provide supporting context that domain-level action can be mis-targeted and that a more appropriate response may be directed at the web hosting provider rather than the whole domain, illustrating the value of more granular interventions [S54]. DNS is also described as a core shared resource of the Internet, which supports caution about using it for broad interventions [S37].
MAJOR DISCUSSION POINT
Major discussion point 1: Technical measures to address phishing and online harms
AGREED WITH
Miguel De Bruycker, Raffaele Sommese, Olivier Crepin Leblond, Nenad Bogunovic
DISAGREED WITH
Miguel De Bruycker, Raffaele Sommese
Argument 2
Content mitigation should not automatically be imposed at the infrastructure layer because it is not granular enough – Peter Kovdynik
EXPLANATION
Peter argues that infrastructure-layer controls are too coarse for many content-mitigation problems and should not be treated as the default intervention point. His concern is both technical and governance-related: blunt infrastructure measures create broader impacts than necessary.
EVIDENCE
He explicitly says he does not understand why content mitigation at the application or user level would have to be done at the infrastructure level and asks what more appropriate and granular alternatives participants would propose [292-297].
EXTERNAL EVIDENCE (KNOWLEDGE BASE)
External material supports this concern by noting that domain takedowns can remove all websites and email accounts associated with a domain when requests are technically misdirected [S54]. DNS is also characterized as a foundational global resource, suggesting that interventions at that layer require special restraint [S37].
MAJOR DISCUSSION POINT
Major discussion point 3: Internet blocking, overblocking, and collateral damage
AGREED WITH
Raffaele Sommese, Philip Lucas, David Frautschy, Miguel De Bruycker
Argument 3
Public authorities have transparency obligations, especially when their interventions affect markets and private protection services – Peter Kovdynik
EXPLANATION
Peter argues that public authorities cannot hide too much behind security secrecy when they intervene in internet protection systems. Because these actions affect private market actors and potentially distort private protection services, state actors have a heightened obligation to be transparent.
EVIDENCE
He notes that the discussion included statements that some methods could not be disclosed, and says this sits uneasily between security by obscurity and a magician hiding tricks [289-290]. He then argues that a state actor or public authority has a transparency obligation, especially where private market participants offer protection services and public authorities may be interfering with that market [291].
EXTERNAL EVIDENCE (KNOWLEDGE BASE)
External sources reinforce the importance of transparency where state or quasi-regulatory intervention affects rights and markets: balancing security and privacy requires transparency and trust-building [S39] [S40], and Internet-jurisdiction discussions also identify transparency as a recurring need in takedown practices [S54].
MAJOR DISCUSSION POINT
Major discussion point 5: Transparency, accountability, and governance of blocking systems
AGREED WITH
Miguel De Bruycker, Raffaele Sommese, David Frautschy, Participant
DISAGREED WITH
Miguel De Bruycker, Raffaele Sommese
P
Participant
5 arguments136 words per minute579 words254 seconds
Argument 1
Reports initially came from citizens, but priority channels from banks and identity providers now improve detection – Participant
EXPLANATION
This argument raises the operational point that reporting channels matter for detection quality and asks whether the Belgian system receives only public reports or also trusted feeds from institutional actors. The concern is that relying solely on citizen reports may be insufficient and that integration with banks or email providers could improve responsiveness.
EVIDENCE
A participant asks whether all reports come directly from users or whether the system also receives forwarded reports from providers such as Gmail or Hotmail, or from automatic mail filtering systems [199]. Miguel’s answer confirms the substance of the argument by stating that until about a year earlier reports were 100% from the population, but that banks and Belgium’s digital identity provider now have a separate priority channel to notify malicious domains when abuse campaigns are detected [202-206].
MAJOR DISCUSSION POINT
Major discussion point 2: Design, operation, and safeguards of the Belgian anti-phishing system
Argument 2
Freedom of speech must be protected through supervised methodologies that target cybercrime indicators rather than content – Participant
EXPLANATION
This argument emphasizes that anti-harm systems must include safeguards so they do not drift into censorship. The underlying point is that methodology and supervision matter: interventions should focus on cybercrime indicators, not speech or content categories.
EVIDENCE
A remote participant asks whether there is a supervised methodology to ensure preservation of freedom of speech and to avoid becoming a censorship arm of government or private parties [322]. Miguel’s response reinforces the point by saying the Belgian system detects phishing emails and known bad cybercrime indicators, not content, and that it avoids moving into content domains such as adult-site restrictions because there is no correct solution for that [323-325].
EXTERNAL EVIDENCE (KNOWLEDGE BASE)
External sources support this rights-based distinction: security measures should be bounded by legal safeguards, transparency, and human-rights protections [S39], while broader debate on illegal-content enforcement warns that anti-harm systems can drift into censorship if not carefully constrained [S49].
MAJOR DISCUSSION POINT
Major discussion point 2: Design, operation, and safeguards of the Belgian anti-phishing system
AGREED WITH
Miguel De Bruycker, Raffaele Sommese, Peter Kovdynik, David Frautschy
Argument 3
Collaboration among member states and sector actors can improve phishing detection and response – Participant
EXPLANATION
This argument holds that countries and actors confronting similar phishing and online abuse problems would benefit from more structured cooperation. The speaker suggests that cross-border coordination could help governments and citizens by pooling knowledge and improving collective action.
EVIDENCE
A participant from CleanDNS says Belgium, Italy, and Serbia are discussing very similar activities and asks about the importance of collaboration between member states, arguing that greater collaboration could be of extreme advantage to citizens and governments [220].
EXTERNAL EVIDENCE (KNOWLEDGE BASE)
External sources strongly support this: international cooperation frameworks such as the Budapest Convention are presented as important for quick response, information sharing, and national capacity building [S35]. Cross-sector, international signal sharing is also highlighted as necessary to reduce fraud and improve threat response at scale [S48].
MAJOR DISCUSSION POINT
Major discussion point 6: Cross-border issues and cooperation across actors and states
AGREED WITH
Miguel De Bruycker, Raffaele Sommese, Philip Lucas, Andre Melancia
Argument 4
Some harmful or illegal content involving minors is difficult to address when providers and hosts are unreachable, making stricter measures tempting – Participant
EXPLANATION
This argument highlights a hard case for online safety policy: when harmful content involving minors is hosted by actors who cannot be reached, softer approaches like follow-the-money may not work. The point is that this practical difficulty creates pressure for stricter blocking approaches, even if they are problematic.
EVIDENCE
A remote participant asks whether follow-the-money is really a better alternative in cases such as copyright infringement, pornographic platforms, and other content harmful to minors when neither providers nor hosting providers can be reached [263].
EXTERNAL EVIDENCE (KNOWLEDGE BASE)
External sources provide context that online-content enforcement often becomes more restrictive when platforms or providers are hard to reach, but also warn that such pressure can create censorship risks and difficult trade-offs [S49]. Cross-border service-provider cooperation is often limited by jurisdiction and trust, which helps explain why unreachable hosts create pressure for stronger measures [S55].
MAJOR DISCUSSION POINT
Major discussion point 7: Child protection, age verification, and fundamental rights
AGREED WITH
Andre Melancia, Raffaele Sommese, Olivier Crepin Leblond, Raffaele Sommese
Argument 5
The burden of implementing blocking often falls on operators, who may oppose such systems if costs are imposed without compensation – Participant
EXPLANATION
This argument concerns the practical economics of blocking systems: even when governments or rights holders want blocking, operators often carry the implementation burden. If they must absorb the costs without compensation, they have strong reasons to resist such schemes.
EVIDENCE
A participant asks who mainly promotes IP blocking of CDNs and similar measures, whether legislators or ISPs and other stakeholders [199-200]. Raffaele’s answer confirms that operators are among those opposed to the platform in Italy specifically because the burden and cost of implementing blocks falls on them without compensation [216-218].
EXTERNAL EVIDENCE (KNOWLEDGE BASE)
External sources provide related context that imposing liability or enforcement duties on Internet intermediaries is costly and controversial, with technical, manpower, and business burdens falling on intermediaries [S53].
MAJOR DISCUSSION POINT
Major discussion point 8: Role of private infrastructure providers and practical cooperation
R
Raffaele Sommese
11 arguments154 words per minute2478 words961 seconds
Argument 1
IP and DNS blocking are blunt tools that often affect many unrelated services because internet resources are shared – Raffaele Sommese
EXPLANATION
Raffaele argues that IP and DNS blocking are technically coarse mechanisms because internet infrastructure is shared by many different services. As a result, blocking one address or name frequently affects unrelated websites and applications that happen to use the same underlying resource.
EVIDENCE
He explains that IP addresses are like the phone number of a building rather than a single person, and that many services may sit behind the same IP [111-125]. He then says that government-ordered IP blocking removes access to that entire address for all users in a country, causing collateral damage to all those other services in the same ‘building’ [122-125].
EXTERNAL EVIDENCE (KNOWLEDGE BASE)
External sources support this by noting that a domain takedown removes every website and email account associated with that domain, often because requesters misunderstand Internet architecture [S54]. Broader analysis of attacks and mitigation on core infrastructure also shows how actions at shared Internet layers can affect many unrelated users and services [S38].
MAJOR DISCUSSION POINT
Major discussion point 3: Internet blocking, overblocking, and collateral damage
AGREED WITH
Philip Lucas, Peter Kovdynik, David Frautschy, Miguel De Bruycker
DISAGREED WITH
Miguel De Bruycker, Peter Kovdynik
Argument 2
Piracy Shield in Italy has blocked thousands of IPs and domains, causing major collateral damage to legitimate services – Raffaele Sommese
EXPLANATION
Raffaele argues that Italy’s Piracy Shield is not just theoretically problematic but empirically harmful. He says the system has blocked a very large number of internet resources and has repeatedly disrupted legitimate businesses and services that had nothing to do with piracy.
EVIDENCE
He states that Piracy Shield has blocked more than 10,000 IPs and 40,000 domains in Italy and has caused thousands of cases of collateral damage to legitimate websites [136]. He gives examples including web shops, car-repair sites, and a Portuguese hosting provider whose address was blocked after previous abuse, leaving it unable to send invoices to customers in Italy for an entire month [138-140].
MAJOR DISCUSSION POINT
Major discussion point 3: Internet blocking, overblocking, and collateral damage
AGREED WITH
Philip Lucas, Peter Kovdynik, David Frautschy, Miguel De Bruycker
Argument 3
Blocking is often ineffective against piracy because operators can cheaply rotate IPs and domains and evade restrictions – Raffaele Sommese
EXPLANATION
Raffaele argues that blocking systems are structurally ineffective against piracy because the targeted operators can easily and cheaply move to new infrastructure. This means blocks often fail to eliminate the underlying service while still causing damage elsewhere.
EVIDENCE
He says the internet is a big place and illegal services evade blocks very easily, noting that an IP address can cost 30 cents to lease and 20 euros to buy, while domain names can range from 50 cents to 15 euros [150-156]. He argues that operators making substantial money from illegal streaming can therefore simply buy new IPs and domains and continue operating, while the blocks imposed on previous resources may last forever [157-161].
EXTERNAL EVIDENCE (KNOWLEDGE BASE)
External sources provide partial contextual support: Internet-jurisdiction discussions emphasize that domain or website-level action can be technically misdirected and that proper targeting matters [S54], while broader debates on intermediary enforcement suggest that simplistic blocking approaches are often poor substitutes for more direct action against underlying actors [S53].
MAJOR DISCUSSION POINT
Major discussion point 4: Effectiveness limits of blocking and alternative approaches
DISAGREED WITH
Miguel De Bruycker, Peter Kovdynik
Argument 4
Better alternatives include follow-the-money investigations, using EU legal tools against hosting providers, and source-level takedowns – Raffaele Sommese
EXPLANATION
Raffaele argues that instead of relying on infrastructure blocking, authorities should use more targeted legal and investigative tools against the actual operators and enablers of illegal services. His preferred alternatives focus on taking down the business and hosting source of the harm rather than blocking access at the network edge.
EVIDENCE
He asks whether better alternatives exist and notes that 77% of the server blocks issued by Piracy Shield concerned servers located within the European Union [169]. He argues that, because these resources are inside the EU, authorities have legislative instruments to go after the hosting providers directly and should use follow-the-money approaches to trace the economic transactions and identify and dismantle the business behind the service [169].
EXTERNAL EVIDENCE (KNOWLEDGE BASE)
External sources support the argument for better targeting: instead of taking down a whole domain, requests should often go to the web hosting provider responsible for the specific content or service [S54]. Broader discussion of intermediary liability also questions whether intermediaries are the right actors to police content, reinforcing the case for action closer to the source [S53].
MAJOR DISCUSSION POINT
Major discussion point 4: Effectiveness limits of blocking and alternative approaches
AGREED WITH
Miguel De Bruycker, Peter Kovdynik, Olivier Crepin Leblond, Nenad Bogunovic
DISAGREED WITH
Miguel De Bruycker
Argument 5
Any action on internet protocols has consequences, so risk-benefit balancing with technical experts is essential – Raffaele Sommese
EXPLANATION
Raffaele argues that there is no technically neutral intervention on the internet: every action at the protocol or infrastructure level has downstream effects. Because of that, policy decisions must be grounded in careful balancing and informed by technical expertise.
EVIDENCE
In his final reply, he says there is no silver bullet and that everything done on the internet has consequences [331]. He adds that every action interacting with internet protocols involves trade-offs, and that the balance between risks and benefits must always be discussed with technical experts [331].
EXTERNAL EVIDENCE (KNOWLEDGE BASE)
External sources reinforce this directly: governments sometimes regulate Internet functions without consulting technical experts, creating harmful consequences and even fragmentation [S52]. Related commentary also warns that precautionary interventions can produce serious false positives if costs and trade-offs are not carefully analyzed [S42].
MAJOR DISCUSSION POINT
Major discussion point 4: Effectiveness limits of blocking and alternative approaches
AGREED WITH
Miguel De Bruycker, Peter Kovdynik, Olivier Crepin Leblond, Nenad Bogunovic
Argument 6
Piracy Shield lacks transparency because blocklists are not public, blocks are requested by private parties, and forensic evidence is not independently vetted – Raffaele Sommese
EXPLANATION
Raffaele argues that one of the biggest governance failures of Piracy Shield is its opacity. In his view, the system allows private interests to trigger blocking quickly without sufficient independent scrutiny, while outsiders cannot inspect what has been blocked or why.
EVIDENCE
He explains that blocking requests are inserted by private copyright owners, must be complied with within 30 minutes, and are extra-judicial in nature [142-143]. He adds that while forensic proof is attached to requests, no one actually vets that proof, and that the block list itself is not public, so users only discover a site is blocked when they cannot connect and are given no explanation [144-148].
EXTERNAL EVIDENCE (KNOWLEDGE BASE)
External sources add relevant context that transparency remains a major challenge in online-content enforcement and takedown systems [S50] [S54]. More broadly, balancing security with rights requires transparency and oversight to sustain trust [S39] [S40].
MAJOR DISCUSSION POINT
Major discussion point 5: Transparency, accountability, and governance of blocking systems
AGREED WITH
Miguel De Bruycker, Peter Kovdynik, David Frautschy, Participant
DISAGREED WITH
David Frautschy, Olivier Crepin Leblond
Argument 7
If blocking systems are opaque, harmed parties cannot audit decisions or claim compensation for damages – Raffaele Sommese
EXPLANATION
Raffaele argues that transparency is a prerequisite for accountability and remedy. If blocks are hidden and undocumented, legitimate businesses and users who suffer harm cannot prove what happened, audit decisions, or seek compensation.
EVIDENCE
In response to a question about liability, he cites the October 2024 blocking of drive.google.com in Italy for several hours and says the business impact could have been tremendous, yet no liability attached to the blocker [253-260]. He then argues that in order to establish liability, the blocking system would need transparent public records showing what was blocked and when, so affected parties could demonstrate the financial consequences they suffered [261].
EXTERNAL EVIDENCE (KNOWLEDGE BASE)
External sources provide supporting context that transparency around takedown requests remains insufficient and that lack of clear records undermines accountability [S54]. Rights-centered approaches to security also stress transparency and meaningful redress mechanisms as necessary safeguards [S39] [S41].
MAJOR DISCUSSION POINT
Major discussion point 5: Transparency, accountability, and governance of blocking systems
AGREED WITH
Miguel De Bruycker, Peter Kovdynik, David Frautschy, Participant
DISAGREED WITH
Miguel De Bruycker, Peter Kovdynik
Argument 8
Cross-border DNS or resolver blocking raises extraterritoriality problems because user location cannot be reliably determined from IP addresses – Raffaele Sommese
EXPLANATION
Raffaele argues that resolver- or DNS-level blocking becomes especially problematic once it extends beyond national borders because the internet does not offer a reliable way to identify users’ country of origin from IP addresses. This creates a risk that one country’s rules spill over onto users in other jurisdictions.
EVIDENCE
He explains that when a country asks a public recursive resolver to block names, it cannot know where the clients using that resolver are actually located because the internet lacks a stable way to determine country from IP addresses [126-129]. He notes that geolocation services only provide best-effort information and cannot reliably certify that a user is from a specific country, making such blocking a difficult technical and legal problem [127-129].
EXTERNAL EVIDENCE (KNOWLEDGE BASE)
External sources provide closely related context on the sensitivity of DNS intervention and cross-border governance. DNS is described as a global shared resource whose security and reliability matter worldwide [S37], while Internet-jurisdiction discussions stress that territorial legal approaches often map poorly onto Internet infrastructure and require further multistakeholder dialogue [S54].
MAJOR DISCUSSION POINT
Major discussion point 6: Cross-border issues and cooperation across actors and states
Argument 9
Shared models and cooperation among European registries/CCTLDs have already improved phishing detection – Raffaele Sommese
EXPLANATION
Raffaele argues that practical technical cooperation across European internet actors can produce measurable improvements in anti-phishing work. He uses prior collaboration among registries as evidence that shared data and machine learning models can strengthen abuse detection across borders.
EVIDENCE
He refers to a published study showing that collaboration among several European ccTLDs increased phishing detection because they shared a machine learning model trained on each registry’s data [227-229]. He says this allowed them to detect abuse moving from one country-code top-level domain to another, supporting his conclusion that collaboration is key [228-229].
EXTERNAL EVIDENCE (KNOWLEDGE BASE)
External sources support the broader logic of this claim: international and cross-sector cooperation is emphasized as essential for fighting cybercrime effectively [S35], and real-time cross-sector signal sharing is presented as a practical way to improve fraud detection and reduce the cost of threat intelligence [S48].
MAJOR DISCUSSION POINT
Major discussion point 6: Cross-border issues and cooperation across actors and states
AGREED WITH
Miguel De Bruycker, Philip Lucas, Participant, Andre Melancia
Argument 10
For universally illegal content such as CSAM, stronger blocking may sometimes be justified, but the existence of bulletproof hosting remains a core problem – Raffaele Sommese
EXPLANATION
Raffaele argues that some categories of content, particularly CSAM, are so universally illegal that stronger blocking measures may sometimes be justified despite their risks. Even so, he emphasizes that the deeper structural issue is the continued existence of hosting services that shelter such content from legal action.
EVIDENCE
Responding to a question about harmful content to minors, he says that content such as CSAM is arguably illegal across Europe and likely worldwide, making it a case where stricter blocking may be required even at the risk of some collateral damage [264-266]. He then adds that much of this content is hosted on platforms that do not respond to legal authority and says more effort is needed to curb the existence of bulletproof hosting that keeps such illegal content online [267-270].
EXTERNAL EVIDENCE (KNOWLEDGE BASE)
External sources provide contextual support and caution: illegal-content policy increasingly pushes platforms toward faster removal and stronger intervention, but these measures also raise freedom-of-expression concerns and must be handled carefully [S49]. Internet-jurisdiction discussions further suggest that requests should be directed to the correct technical layer, such as hosting providers, where possible [S54].
MAJOR DISCUSSION POINT
Major discussion point 7: Child protection, age verification, and fundamental rights
AGREED WITH
Andre Melancia, Olivier Crepin Leblond, Participant
DISAGREED WITH
Miguel De Bruycker, Andre Melancia, Olivier Crepin Leblond
Argument 11
Young people should actively state what harms they actually want protection from, rather than having solutions imposed on them – Raffaele Sommese
EXPLANATION
Raffaele argues that youth should not be passive subjects of online protection policies. Because many blocking and safety debates are justified as protecting young people, he says young people themselves should articulate what harms matter to them and what kind of protections they want.
EVIDENCE
When asked for a recommendation to youth attendees, he urges them to be active and participate in the discussion because many blocking measures are presented as being for the protection of young people online [338]. He says it is more important that the definition of the harms they want protection from comes from them directly [339-340].
EXTERNAL EVIDENCE (KNOWLEDGE BASE)
This is directly reinforced by external guidance stating that platform users, including marginalized groups, should be included in policymaking, and that youth in particular have valuable expertise about the harms they face and the likely effects of proposed protections [S50].
MAJOR DISCUSSION POINT
Major discussion point 7: Child protection, age verification, and fundamental rights
AGREED WITH
Andre Melancia, Olivier Crepin Leblond, Participant
D
David Frautschy
3 arguments139 words per minute410 words176 seconds
Argument 1
Telephone-number analogies can mislead policymakers because blocking an IP can disrupt many websites and services at once – David Frautschy
EXPLANATION
David argues that simple analogies comparing IP addresses to ordinary phone numbers risk giving policymakers the wrong mental model. Unlike a unique home phone line, an IP address often supports many different services, so blocking it can have broad and unintended effects.
EVIDENCE
He says that when you cut a traditional telephone line, it affects only a single house, whereas blocking an IP address can disrupt many websites at once [234-239]. He gives the example of Spain, where a recent blocking affected a payment gateway during a football match, disrupting payment verification requests and therefore much of the country’s e-commerce activity [241-242].
EXTERNAL EVIDENCE (KNOWLEDGE BASE)
External sources support this warning by noting that Internet requests are often mis-targeted because policymakers misunderstand technical architecture; for example, taking down a domain can unintentionally remove all associated websites and email accounts [S54]. Broader analysis of core-infrastructure effects also shows that disruptions at shared network layers can affect many unrelated users and services [S38].
MAJOR DISCUSSION POINT
Major discussion point 3: Internet blocking, overblocking, and collateral damage
AGREED WITH
Raffaele Sommese, Philip Lucas, Peter Kovdynik, Miguel De Bruycker
Argument 2
Rights holders should potentially face liability when wrongful blocking harms legitimate websites and businesses – David Frautschy
EXPLANATION
David argues that if rights holders or others request wrongful blocks that damage legitimate businesses, they should potentially be liable for the consequences. His question implies that without liability, there is too little deterrence against careless or overbroad blocking requests.
EVIDENCE
He asks directly whether a liability scheme would be appropriate so that rights holders would have to pay websites harmed by their requests for IP blocking [243-250].
EXTERNAL EVIDENCE (KNOWLEDGE BASE)
External sources provide related accountability context: transparency and effective complaint or redress mechanisms are necessary when people or businesses are harmed by misuse of data or regulatory systems [S39] [S41].
MAJOR DISCUSSION POINT
Major discussion point 5: Transparency, accountability, and governance of blocking systems
AGREED WITH
Miguel De Bruycker, Raffaele Sommese, Peter Kovdynik, Participant
Argument 3
Policymakers often favor rights holders or quick-fix solutions over technical community warnings, which distorts regulation – David Frautschy
EXPLANATION
David argues that there is a structural imbalance in whose advice policymakers heed. In his view, legislators often listen more to rights holders and apparent easy fixes than to technical experts warning about the harms and inefficacy of blocking measures.
EVIDENCE
He asks why policymakers are listening more to rights holders than to the technical community, despite repeated technical explanations that these blocking approaches are wrong and despite notorious examples of harmful blocking [243-247].
EXTERNAL EVIDENCE (KNOWLEDGE BASE)
External sources support this broader critique: governments sometimes legislate Internet matters without understanding technical consequences or consulting experts, which can lead to harmful outcomes and fragmentation [S52]. Additional commentary warns that policymakers are often attracted to simplistic intermediary-liability solutions because they appear quick and practical [S53].
MAJOR DISCUSSION POINT
Major discussion point 5: Transparency, accountability, and governance of blocking systems
DISAGREED WITH
Raffaele Sommese, Olivier Crepin Leblond
P
Petra Arts
1 argument208 words per minute140 words40 seconds
Argument 1
Economic harm from network blocking is real and documented, including effects on payment gateways and broader online commerce – Petra Arts
EXPLANATION
Petra argues that the economic costs of network blocking are significant and should be part of policy analysis. Her point is that these harms are not merely anecdotal; they have been studied and can affect commercial infrastructure and broader digital economic activity.
EVIDENCE
She refers participants to a study commissioned the previous year from Analysys Mason, titled ‘the economic cost of network blocking,’ as a resource illustrating the kinds of economic harms discussed during the session [317-321].
EXTERNAL EVIDENCE (KNOWLEDGE BASE)
External sources provide supporting context that disruptions at shared Internet infrastructure layers can have widespread effects on unrelated services and users [S38], and that mis-targeted takedowns can remove legitimate websites and email services, implying real commercial harm [S54].
MAJOR DISCUSSION POINT
Major discussion point 3: Internet blocking, overblocking, and collateral damage
O
Olivier Crepin Leblond
2 arguments149 words per minute166 words66 seconds
Argument 1
There are no silver bullets; all internet interventions have trade-offs and require technical scrutiny – Olivier Crepin Leblond
EXPLANATION
Olivier argues that policymakers are often attracted to fast and simple solutions, but internet governance problems do not have single perfect fixes. He stresses that such measures require balance, mitigation, and analysis because easy answers often create serious side effects.
EVIDENCE
He says politicians have short time horizons and want immediate solutions, which makes them susceptible to ‘silver bullet’ pitches from companies claiming to have the answer [312-315]. He warns that unless it is shown that there are no silver bullets and that these are complex issues requiring balance and analysis, false positives and a harder-to-use internet will continue to result from measures such as age verification [315-316].
EXTERNAL EVIDENCE (KNOWLEDGE BASE)
External sources strongly support this: precautionary approaches can create major false-positive harms if trade-offs are not carefully assessed [S42], and governments that regulate without consulting technical expertise risk unintended consequences for the Internet [S52].
MAJOR DISCUSSION POINT
Major discussion point 4: Effectiveness limits of blocking and alternative approaches
AGREED WITH
Miguel De Bruycker, Raffaele Sommese, Peter Kovdynik, Nenad Bogunovic
DISAGREED WITH
David Frautschy, Raffaele Sommese
Argument 2
Politicians often seek fast “silver bullet” child-safety solutions despite the complexity and side effects of such measures – Olivier Crepin Leblond
EXPLANATION
Olivier argues specifically in the child-safety context that politicians tend to prefer quick and politically attractive fixes over more nuanced approaches. He warns that this dynamic drives support for measures like age verification without sufficient attention to their broader consequences.
EVIDENCE
He says that in dealing with the UK government on age verification and online harms, politicians often want immediate solutions and are receptive to firms promising a ready-made answer [312-315]. He adds that this leads to problematic policies with many repercussions unless policymakers accept that these are complicated issues needing balance, mitigation, and analysis [315-316].
EXTERNAL EVIDENCE (KNOWLEDGE BASE)
External sources support the warning that security-focused and child-protection-related digital measures can undermine privacy and other rights if implemented without adequate safeguards [S39]. Broader policy reporting also notes that rapid regulatory pressure around harmful content frequently generates censorship and over-removal concerns [S49].
MAJOR DISCUSSION POINT
Major discussion point 7: Child protection, age verification, and fundamental rights
AGREED WITH
Andre Melancia, Raffaele Sommese, Participant, Raffaele Sommese
DISAGREED WITH
Raffaele Sommese, Miguel De Bruycker, Andre Melancia
P
Philip Struyf
1 argument133 words per minute95 words42 seconds
Argument 1
Work on blocking and online harms should be informed by further reading and an evidence base, not only by live debate
EXPLANATION
Philip Struyf implicitly argues that discussion of blocking, online harms, and technical measures should be grounded in documented research and reference materials. By pointing participants to further reading already collected in the session materials, he frames the issue as one that requires continued study and evidence-informed policy engagement rather than ad hoc reactions.
EVIDENCE
When Petra Arts mentions a study on the economic cost of network blocking, Philip adds that it is already listed in the ‘further reading’ section on the wiki, signaling that the session has curated background material to support deeper and more informed analysis of the topic [321-322].
EXTERNAL EVIDENCE (KNOWLEDGE BASE)
External sources support the value of evidence-based policy development: Internet-jurisdiction discussions call for further dialogue, research, and dedicated resources to reconcile technical and legal concerns [S54], while global policy work highlights the need for better data access and stronger research foundations to evaluate platform harms and responses [S50].
MAJOR DISCUSSION POINT
Major discussion point 5: Transparency, accountability, and governance of blocking systems
Agreements
Agreement Points
Multi-stakeholder and cross-actor collaboration is necessary to address online harms effectively
Speakers: Miguel De Bruycker, Raffaele Sommese, Philip Lucas, Participant, Andre Melancia
Collaboration with hyperscalers and platforms is improving, leading to faster action such as moving harmful emails to spam or removing malicious ads – Miguel De Bruycker Because the internet is largely private space owned and operated by companies, governments must work collaboratively with service providers rather than act unilaterally – Miguel De Bruycker Shared models and cooperation among European registries/CCTLDs have already improved phishing detection – Raffaele Sommese Multi-stakeholder collaboration is needed to tackle evolving online harms effectively – Philip Lucas Effective online harm reduction depends on collaboration among industry players and between industry and government – Philip Lucas Collaboration among member states and sector actors can improve phishing detection and response – Participant Government attention often comes only when concerns scale up politically, so coordinated advocacy matters – Andre Melancia
Several speakers converged on the view that online harms cannot be handled by any single actor and require cooperation across governments, industry, platforms, operators, and states. Miguel described constructive collaboration with Belgian ISPs and improving cooperation with major platforms such as Google, Microsoft, and Meta [174-182][341-354]. Raffaele said collaboration across European ccTLDs improved phishing detection and concluded that collaboration is key [227-229]. Philip’s session summary explicitly stated that the evolving nature of online harms requires multi-stakeholder collaboration among industry and government [333]. A participant likewise argued that member states pursuing similar efforts would benefit from stronger collaboration [220], and Andre encouraged coordination across the EU to gain political traction [222-225].
POLICY CONTEXT (KNOWLEDGE BASE)
This aligns with repeated multistakeholder governance framing in online safety discussions: regulators, companies, and civil society are described as needing to collaborate to tackle harms effectively [S69], cross-sector dialogue is presented as essential to trust and safety governance [S71], and IGF/parliamentary discussions likewise frame collaborative approaches as central to addressing online harms [S72][S95][S96].
IP and DNS blocking are often blunt infrastructure-level tools that can cause substantial collateral damage
Speakers: Raffaele Sommese, Philip Lucas, Peter Kovdynik, David Frautschy, Miguel De Bruycker
IP and DNS blocking are blunt tools that often affect many unrelated services because internet resources are shared – Raffaele Sommese Piracy Shield in Italy has blocked thousands of IPs and domains, causing major collateral damage to legitimate services – Raffaele Sommese Illegal-content interventions should remain proportionate because technical blocking can unnecessarily restrict access to lawful resources – Philip Lucas Infrastructure-level mitigation should be questioned when more granular user- or application-level tools may exist – Peter Kovdynik Content mitigation should not automatically be imposed at the infrastructure layer because it is not granular enough – Peter Kovdynik Telephone-number analogies can mislead policymakers because blocking an IP can disrupt many websites and services at once – David Frautschy Belgian anti-phishing shield as a practical protective layer – Miguel De Bruycker
There was broad agreement that infrastructure-level blocking, especially at the IP layer, is technically coarse and can affect many lawful services. Raffaele explained that shared internet infrastructure means blocking one IP can hit many unrelated services and pointed to extensive collateral damage under Italy’s Piracy Shield [111-125][136-148]. Peter questioned why content mitigation should happen at the infrastructure layer at all when more granular tools exist closer to users or applications [292-297]. David reinforced that blocking an IP can disrupt many websites and gave the example of payment systems being affected in Spain [234-242]. Philip summarized the same concern in his closing messages, warning that DNS and IP blocking can significantly affect lawful online resources [333]. Miguel, despite defending DNS warnings for phishing, also agreed that blocking IP addresses is not a good idea because of collateral damage [174].
POLICY CONTEXT (KNOWLEDGE BASE)
This is strongly supported by prior technical-policy discussions. DNS and IP interventions have been described as affecting entire sites or many unrelated services rather than specific content [S73][S78][S93]. Layered-policy discussions warn that blocking one IP can inadvertently affect millions of domains [S79], and earlier analyses of infrastructure attacks underline how interventions at core layers can create spillover effects beyond intended targets [S85].
Interventions against online harms must be proportionate, balanced, and designed with safeguards against overreach
Speakers: Miguel De Bruycker, Raffaele Sommese, Philip Lucas, Olivier Crepin Leblond, Andre Melancia
Transparency, proportionality, and DPA oversight are necessary to avoid turning phishing detection into censorship – Miguel De Bruycker The right approach is balance: doing nothing is not acceptable, but interventions must be carefully scoped – Miguel De Bruycker Any action on internet protocols has consequences, so risk-benefit balancing with technical experts is essential – Raffaele Sommese Illegal-content interventions should remain proportionate because technical blocking can unnecessarily restrict access to lawful resources – Philip Lucas There are no silver bullets; all internet interventions have trade-offs and require technical scrutiny – Olivier Crepin Leblond Child protection and age-verification measures can create serious harms to privacy, anonymity, and freedom of expression – Andre Melancia
A strong area of agreement was that action is needed, but measures must be carefully balanced and proportionate. Miguel repeatedly emphasized proportionality, transparency, and limiting action to domains judged almost certainly malicious, while arguing that security measures should protect citizens without becoming censorship [60-72][300-303]. Raffaele said all interventions on internet protocols have consequences and require balancing of risks and benefits with technical experts [331]. Philip’s summary explicitly stated that interventions to increase online safety should be proportionate [333]. Olivier warned against ‘silver bullet’ solutions and stressed the need for balance and analysis [312-316]. Andre similarly warned that child-protection and age-verification measures can produce serious rights harms if implemented without care [280-281].
POLICY CONTEXT (KNOWLEDGE BASE)
This reflects established rights-based policy framing. DNS/content interventions have long been debated in terms of proportionality and risk of overreach [S73][S78], while counter-terrorism and cybercrime discussions stress balancing security goals with freedom of expression and human rights protections [S74][S88][S94]. Current trust-and-safety discussions also favor risk-based approaches over blanket measures [S71].
There is no silver bullet; online harms require layered or alternative responses rather than reliance on one blocking tool
Speakers: Miguel De Bruycker, Raffaele Sommese, Peter Kovdynik, Olivier Crepin Leblond, Nenad Bogunovic
Warning users is imperfect but still valuable, much like spam filtering or warning signs around known hazards – Miguel De Bruycker The right approach is balance: doing nothing is not acceptable, but interventions must be carefully scoped – Miguel De Bruycker Better alternatives include follow-the-money investigations, using EU legal tools against hosting providers, and source-level takedowns – Raffaele Sommese Any action on internet protocols has consequences, so risk-benefit balancing with technical experts is essential – Raffaele Sommese Infrastructure-level mitigation should be questioned when more granular user- or application-level tools may exist – Peter Kovdynik There are no silver bullets; all internet interventions have trade-offs and require technical scrutiny – Olivier Crepin Leblond Similar national systems are being developed elsewhere and must evolve toward AI, spear-phishing, SMS, and other scam indicators – Nenad Bogunovic
Speakers broadly agreed that no single technical intervention solves online harms. Miguel defended DNS warnings as one useful but imperfect layer, comparing them to spam filters and warning signs rather than complete solutions [60][189-197]. Raffaele argued against overreliance on blocking and proposed alternatives such as follow-the-money approaches and source-level legal action [166-169][304]. Peter pointed to more granular tools like spam folders and browser plug-ins [296-297]. Olivier explicitly said there are no silver bullets and that simplistic fixes create repercussions [312-316]. Nenad also implied the need for evolving, multi-faceted systems by urging anti-phishing efforts to adapt to spear-phishing, AI-generated content, SMS phishing, and other scam indicators [92-98].
POLICY CONTEXT (KNOWLEDGE BASE)
External sources repeatedly reject one-tool solutions. Risk-based and behavior-focused approaches are preferred to single enforcement mechanisms [S71], anti-harm and child-safety debates emphasize principles-based, ecosystem-wide responses [S72][S95][S96], and technical literature on filtering shows both effectiveness limits and trade-offs, reinforcing that blocking alone is insufficient [S91][S93].
Transparency and accountability are important safeguards in online harm mitigation systems
Speakers: Miguel De Bruycker, Raffaele Sommese, Peter Kovdynik, David Frautschy, Participant
Transparency, proportionality, and DPA oversight are necessary to avoid turning phishing detection into censorship – Miguel De Bruycker Piracy Shield lacks transparency because blocklists are not public, blocks are requested by private parties, and forensic evidence is not independently vetted – Raffaele Sommese If blocking systems are opaque, harmed parties cannot audit decisions or claim compensation for damages – Raffaele Sommese Public authorities have transparency obligations, especially when their interventions affect markets and private protection services – Peter Kovdynik Rights holders should potentially face liability when wrongful blocking harms legitimate websites and businesses – David Frautschy Freedom of speech must be protected through supervised methodologies that target cybercrime indicators rather than content – Participant
Multiple speakers agreed that online harm mitigation needs transparency and accountability safeguards, though they differed on implementation. Miguel stressed that his system is transparent in purpose, proportionate, and under DPA oversight, and said it is confined to cybercrime indicators rather than content [60-64][101-103][300-303][323-325]. Raffaele criticized Piracy Shield for opaque, extra-judicial blocking with non-public blocklists and no independent vetting, arguing this also prevents compensation for damage [141-148][253-261]. Peter said public authorities have a transparency obligation, especially where they affect private markets [289-291]. David raised the possibility of liability for wrongful blocks [243-250]. A remote participant likewise asked for supervised methodologies to preserve freedom of speech and avoid censorship drift [322].
POLICY CONTEXT (KNOWLEDGE BASE)
This is directly reinforced by multiple sources treating transparency as a prerequisite for accountability in platform governance and rights protection [S69][S70][S81]. The DSA-related discussion also frames transparency and oversight as explicit objectives for content-moderation systems, including at infrastructure layers [S78], while historical transparency-reporting practice by companies is cited as an important governance tool [S90][S92].
Child protection and harms to minors are genuine concerns, but the policy response is complex and rights-sensitive
Speakers: Andre Melancia, Raffaele Sommese, Olivier Crepin Leblond, Participant, Raffaele Sommese
Child protection and age-verification measures can create serious harms to privacy, anonymity, and freedom of expression – Andre Melancia For universally illegal content such as CSAM, stronger blocking may sometimes be justified, but the existence of bulletproof hosting remains a core problem – Raffaele Sommese Politicians often seek fast “silver bullet” child-safety solutions despite the complexity and side effects of such measures – Olivier Crepin Leblond Some harmful or illegal content involving minors is difficult to address when providers and hosts are unreachable, making stricter measures tempting – Participant Young people should actively state what harms they actually want protection from, rather than having solutions imposed on them – Raffaele Sommese
Speakers agreed that harms to minors are a legitimate policy concern, but they also agreed the issue is difficult and cannot be solved by simplistic fixes. A participant highlighted the hard cases where harmful content and unreachable providers make stricter measures tempting [263]. Raffaele acknowledged that for universally illegal material such as CSAM, stronger blocking may sometimes be justified, while emphasizing the deeper structural problem of bulletproof hosting [264-270]. Andre warned that child-protection measures like age verification can undermine anonymity, freedom of speech, and civic freedoms [280-281]. Olivier similarly argued that politicians are drawn to quick child-safety fixes despite their broader consequences [312-316]. Raffaele added that young people themselves should help define what harms they want protection from [338-340].
POLICY CONTEXT (KNOWLEDGE BASE)
This reflects authoritative framing that child safety is a legitimate and urgent objective, while policy responses must still respect privacy and other rights [S69][S72]. Recent debates on scanning and age-verification likewise stress that protecting children is a shared goal but that technical mandates can create serious rights and implementation concerns [S89][S96].
Similar Viewpoints
Although they defended different tools in different contexts, both speakers distinguished between narrowly targeted anti-phishing DNS warnings and broader blunt blocking. Miguel said IP blocking is not a good idea because of collateral damage, while defending carefully scoped DNS warnings for domains judged almost certainly malicious [174][34-49][64]. Raffaele similarly argued that IP and DNS blocking are often blunt and harmful, especially in piracy enforcement, and called for more targeted action against hosting and financial infrastructure instead [111-125][136-169].
Speakers: Miguel De Bruycker, Raffaele Sommese
Belgian anti-phishing shield as a practical protective layer – Miguel De Bruycker IP and DNS blocking are blunt tools that often affect many unrelated services because internet resources are shared – Raffaele Sommese Better alternatives include follow-the-money investigations, using EU legal tools against hosting providers, and source-level takedowns – Raffaele Sommese
These speakers shared the view that infrastructure-layer controls are generally too coarse for many online harm problems. Peter explicitly questioned why application-layer problems should be handled at the infrastructure layer and pointed to alternatives such as spam folders and browser plug-ins [292-297]. Raffaele explained the technical reasons that IP and DNS blocking affect many unrelated services [111-125]. David gave real-world examples of widespread disruption from such blocking [234-242]. Philip summarized this position by warning that such interventions can unnecessarily restrict access to lawful resources [333].
Speakers: Peter Kovdynik, Raffaele Sommese, David Frautschy, Philip Lucas
Infrastructure-level mitigation should be questioned when more granular user- or application-level tools may exist – Peter Kovdynik Content mitigation should not automatically be imposed at the infrastructure layer because it is not granular enough – Peter Kovdynik IP and DNS blocking are blunt tools that often affect many unrelated services because internet resources are shared – Raffaele Sommese Telephone-number analogies can mislead policymakers because blocking an IP can disrupt many websites and services at once – David Frautschy Illegal-content interventions should remain proportionate because technical blocking can unnecessarily restrict access to lawful resources – Philip Lucas
These speakers converged on the need for safeguards so that harm-mitigation systems do not become censorship tools. Miguel said his system targets known bad cybercrime indicators, not content, and is overseen and proportionate [60-64][323-325]. A participant asked directly for supervised methodologies that preserve freedom of speech [322]. Peter argued that public authorities owe transparency when intervening in this space [289-291]. Raffaele showed the opposite case, criticizing Piracy Shield for opaque operation and lack of independent vetting [141-148].
Speakers: Miguel De Bruycker, Participant, Peter Kovdynik, Raffaele Sommese
Transparency, proportionality, and DPA oversight are necessary to avoid turning phishing detection into censorship – Miguel De Bruycker Freedom of speech must be protected through supervised methodologies that target cybercrime indicators rather than content – Participant Public authorities have transparency obligations, especially when their interventions affect markets and private protection services – Peter Kovdynik Piracy Shield lacks transparency because blocklists are not public, blocks are requested by private parties, and forensic evidence is not independently vetted – Raffaele Sommese
These speakers shared a rights-sensitive approach to child-safety policy. Andre warned that age-verification and similar measures can harm anonymity and freedom of expression [280-281]. Olivier argued that politicians often seek fast child-safety fixes without acknowledging complexity and repercussions [312-316]. Raffaele added that young people themselves should participate in defining what harms matter and what protections are appropriate [338-340].
Speakers: Andre Melancia, Olivier Crepin Leblond, Raffaele Sommese
Child protection and age-verification measures can create serious harms to privacy, anonymity, and freedom of expression – Andre Melancia Politicians often seek fast “silver bullet” child-safety solutions despite the complexity and side effects of such measures – Olivier Crepin Leblond Young people should actively state what harms they actually want protection from, rather than having solutions imposed on them – Raffaele Sommese
These speakers shared the idea that anti-phishing systems must evolve with changing threats and use multiple technical and institutional inputs. Nenad emphasized the need to adapt to spear-phishing, AI-generated content, SMS phishing, and other indicators [92-98]. Miguel described a system that combines public reports, automated analysis, phishing-kit detection, partner review, and expanding scam indicators [79-84][99]. Philip’s summary generalized this into a call for multi-stakeholder responses to evolving harms [333].
Speakers: Nenad Bogunovic, Miguel De Bruycker, Philip Lucas
Similar national systems are being developed elsewhere and must evolve toward AI, spear-phishing, SMS, and other scam indicators – Nenad Bogunovic User reports act as crowd-sourced first detection, then automated analysis and partner review classify malicious domains – Miguel De Bruycker Collaboration with hyperscalers and platforms is improving, leading to faster action such as moving harmful emails to spam or removing malicious ads – Miguel De Bruycker Multi-stakeholder collaboration is needed to tackle evolving online harms effectively – Philip Lucas
Unexpected Consensus
A defender of DNS-based anti-phishing intervention and critics of blocking both agreed that IP blocking is especially problematic
Speakers: Miguel De Bruycker, Raffaele Sommese, David Frautschy
Belgian anti-phishing shield as a practical protective layer – Miguel De Bruycker IP and DNS blocking are blunt tools that often affect many unrelated services because internet resources are shared – Raffaele Sommese Telephone-number analogies can mislead policymakers because blocking an IP can disrupt many websites and services at once – David Frautschy
This was notable because Miguel was the main advocate for a technical intervention, yet he explicitly said the idea of blocking IP addresses is not a good idea because of collateral damage [174]. That aligned with Raffaele’s detailed critique of shared infrastructure and collateral harm [111-125][136-140], and with David’s warning that IP blocking can disrupt many unrelated services such as payment infrastructure [234-242].
POLICY CONTEXT (KNOWLEDGE BASE)
This is consistent with technical-policy literature describing IP blocking as especially overbroad because one IP can host many unrelated domains and services [S79][S93]. Infrastructure-layer moderation discussions similarly identify URL/DNS/IP blocking as blunt tools, with IP-based measures particularly prone to collateral damage [S78].
Speakers with different policy instincts agreed that child-safety measures are legitimate in aim but dangerous if oversimplified
Speakers: Andre Melancia, Raffaele Sommese, Olivier Crepin Leblond, Participant
Child protection and age-verification measures can create serious harms to privacy, anonymity, and freedom of expression – Andre Melancia For universally illegal content such as CSAM, stronger blocking may sometimes be justified, but the existence of bulletproof hosting remains a core problem – Raffaele Sommese Politicians often seek fast “silver bullet” child-safety solutions despite the complexity and side effects of such measures – Olivier Crepin Leblond Some harmful or illegal content involving minors is difficult to address when providers and hosts are unreachable, making stricter measures tempting – Participant
Despite coming from different angles, these speakers converged on a nuanced middle ground: child protection is a valid concern, but simplistic solutions are risky. The participant stressed the practical difficulty of addressing harmful content involving minors when providers are unreachable [263]. Raffaele accepted that stronger blocking may sometimes be justified for universally illegal content such as CSAM [264-266]. At the same time, Andre and Olivier warned that age-verification and similar fast political fixes can undermine anonymity, rights, and broader internet freedoms [280-281][312-316].
POLICY CONTEXT (KNOWLEDGE BASE)
This is supported by broader policy debates that treat child protection as necessary but contest simplistic technical fixes. Sources on online safety and child protection emphasize safety-by-design and rights-sensitive design [S69][S72], while recent debates on encrypted scanning and age verification warn that child-safety policies can become counterproductive or privacy-invasive if framed too narrowly [S89][S96].
Even speakers who disagreed on how much operational detail should be public agreed that anti-harm systems need safeguards against censorship and abuse
Speakers: Miguel De Bruycker, Peter Kovdynik, Participant, Raffaele Sommese
Transparency, proportionality, and DPA oversight are necessary to avoid turning phishing detection into censorship – Miguel De Bruycker Public authorities have transparency obligations, especially when their interventions affect markets and private protection services – Peter Kovdynik Freedom of speech must be protected through supervised methodologies that target cybercrime indicators rather than content – Participant Piracy Shield lacks transparency because blocklists are not public, blocks are requested by private parties, and forensic evidence is not independently vetted – Raffaele Sommese
There was an unexpected convergence between Miguel, who defended withholding some operational details for security reasons, and critics who demanded stronger transparency. Miguel still insisted his system was transparent in purpose, proportionate, and not content-based [300-303][323-325]. Peter pressed for stronger transparency obligations from public authorities [289-291]. A participant asked for supervised methodologies to protect freedom of speech [322], while Raffaele showed how lack of transparency in Italy undermined accountability [141-148]. The shared core was that anti-harm systems need safeguards against abuse and censorship, even if the exact level of disclosure remained contested.
POLICY CONTEXT (KNOWLEDGE BASE)
This maps onto established transparency-and-rights discourse: transparency is valued, but always alongside safeguards against misuse, censorship, and privacy harms [S71][S81]. Historical debates on filtering, counter-extremism, and infrastructure moderation similarly warn that anti-harm systems can be abused without clear accountability and human-rights guardrails [S74][S78][S91].
Overall Assessment

The strongest agreements were that online harms are real and require action; that collaboration across governments, platforms, operators, and technical actors is essential; that IP and DNS blocking are often blunt tools with serious collateral risks; and that any intervention must be proportionate, rights-sensitive, and accompanied by safeguards such as transparency or oversight [174-182][227-229][292-297][333].

Differences
Different Viewpoints
Whether DNS-based blocking/warning is an appropriate and effective technical measure for online harms
Speakers: Miguel De Bruycker, Raffaele Sommese, Peter Kovdynik
Belgian anti-phishing shield as a practical protective layer – Miguel De Bruycker The system is DNS-based, voluntary with ISPs, opt-out for users, and aims only at domains judged almost certainly malicious – Miguel De Bruycker Warning users is imperfect but still valuable, much like spam filtering or warning signs around known hazards – Miguel De Bruycker IP and DNS blocking are blunt tools that often affect many unrelated services because internet resources are shared – Raffaele Sommese Blocking is often ineffective against piracy because operators can cheaply rotate IPs and domains and evade restrictions – Raffaele Sommese Infrastructure-level mitigation should be questioned when more granular user- or application-level tools may exist – Peter Kovdynik
Miguel argues that DNS-based warning systems are a necessary protective layer against clearly malicious phishing domains, comparing them to spam filters and hazard warnings, and presents the Belgian Anti-Phishing Shield as a practical, opt-out, ISP-supported system that has shown positive effects in use [34-45][60][67-72][189-197]. By contrast, Raffaele argues that IP and DNS blocking are structurally blunt and often ineffective because shared infrastructure creates collateral damage and malicious actors can cheaply evade blocks by rotating IPs and domains [110-125][136-161]. Peter sharpens this critique by asking why content mitigation should occur at the infrastructure layer at all when more granular, user- or application-level tools such as spam folders or browser plugins may exist [292-297].
POLICY CONTEXT (KNOWLEDGE BASE)
This disagreement has clear historical precedent. IGF and DNS-governance discussions have long been divided over whether DNS-level action is effective or appropriate versus source-level removal through hosts [S73]. Technical and policy analyses note DNS blocking is easy to bypass, does not remove content, and may undermine Internet functionality, while some policymakers still argue there can be limited legitimate uses under certain conditions [S73][S78][S93].
How much transparency public authorities owe about anti-phishing and blocking systems
Speakers: Miguel De Bruycker, Peter Kovdynik, Raffaele Sommese
Transparency, proportionality, and DPA oversight are necessary to avoid turning phishing detection into censorship – Miguel De Bruycker Public authorities have transparency obligations, especially when their interventions affect markets and private protection services – Peter Kovdynik Piracy Shield lacks transparency because blocklists are not public, blocks are requested by private parties, and forensic evidence is not independently vetted – Raffaele Sommese If blocking systems are opaque, harmed parties cannot audit decisions or claim compensation for damages – Raffaele Sommese
Miguel stresses that his system is transparent, proportionate, and overseen, but also argues that transparency does not mean making all security methods public, since publishing defensive details could help adversaries evade protections [60-64][101-103][300-303]. Peter challenges this approach, saying that when state actors intervene in protection systems they have a transparency obligation, especially where public action affects private market participants and protection services [289-291]. Raffaele reinforces the accountability side of this disagreement by criticizing Piracy Shield for non-public blocklists, unvetted private-party requests, and lack of auditable records, arguing that opacity prevents harmed parties from understanding, auditing, or seeking compensation for wrongful blocks [141-148][253-261].
POLICY CONTEXT (KNOWLEDGE BASE)
This sits within a wider transparency-governance debate. Human-rights and platform-governance sources argue that transparency reporting by governments and companies is essential for accountability [S81][S92], while trust-and-safety discussions note transparency remains uneven and contested in practice [S70][S71]. Historical policy commentary also distinguishes between full transparency and more limited ‘translucency’ in sensitive enforcement contexts [S90].
Whether infrastructure-level blocking should be preferred over source-level takedown and follow-the-money approaches
Speakers: Miguel De Bruycker, Raffaele Sommese
The right approach is balance: doing nothing is not acceptable, but interventions must be carefully scoped – Miguel De Bruycker Better alternatives include follow-the-money investigations, using EU legal tools against hosting providers, and source-level takedowns – Raffaele Sommese Collaboration with hyperscalers and platforms is improving, leading to faster action such as moving harmful emails to spam or removing malicious ads – Miguel De Bruycker
Miguel argues that protective intervention is necessary now, even if imperfect, and that warning users through DNS and collaborating with platforms to demote harmful emails or remove malicious ads are justified practical responses to cybercrime [67-72][174-182][300-303]. Raffaele instead argues that for many problems, especially where servers are in the EU, authorities should go after the source through hosting-provider action and follow-the-money investigations rather than rely on infrastructure blocking that is both damaging and ineffective [166-169][304]. The disagreement is therefore over the primary intervention layer: immediate user-side/network-side protection versus direct action against the underlying operators and infrastructure providers [169][271-279][304].
POLICY CONTEXT (KNOWLEDGE BASE)
External sources provide strong context that this is a longstanding policy divide. DNS-focused debates explicitly contrast blocking at the DNS layer with acting against hosting providers and other upstream actors [S73]. Infrastructure-moderation discussions emphasize that lower-layer services usually cannot target specific content and therefore are poor substitutes for source-level remedies [S78][S86].
How far stricter blocking should be used in child protection and universally illegal content cases
Speakers: Raffaele Sommese, Miguel De Bruycker, Andre Melancia, Olivier Crepin Leblond
For universally illegal content such as CSAM, stronger blocking may sometimes be justified, but the existence of bulletproof hosting remains a core problem – Raffaele Sommese Transparency, proportionality, and DPA oversight are necessary to avoid turning phishing detection into censorship – Miguel De Bruycker Child protection and age-verification measures can create serious harms to privacy, anonymity, and freedom of expression – Andre Melancia Politicians often seek fast “silver bullet” child-safety solutions despite the complexity and side effects of such measures – Olivier Crepin Leblond
Raffaele says that in cases such as CSAM, stronger blocking may sometimes be justified even at the risk of collateral damage because the content is universally illegal and often hosted by unresponsive providers [264-270]. Miguel takes a narrower line for his own system, saying it is limited to phishing and known cybercrime indicators and explicitly does not move into content domains such as adult-site restrictions because there is no correct solution for that [323-325]. Andre warns that child-protection and age-verification measures can undermine anonymity, freedom of expression, and even civic organizing [280-281], while Olivier argues that politicians are too often drawn to quick child-safety “silver bullet” measures without sufficiently weighing repercussions [312-316].
POLICY CONTEXT (KNOWLEDGE BASE)
This reflects a broader unresolved tension in online safety policy. Child protection is widely recognized as a legitimate priority [S69][S72], but debates over age verification, encrypted scanning, and technical mandates show substantial disagreement over how far rights-intrusive measures should go even for serious harms [S89][S96]. Earlier DNS/content debates also caution that different categories of illegality may require different thresholds and tailored responses rather than a uniform blocking rule [S73].
How strongly policymakers should rely on rights-holder or government-backed blocking schemes despite technical community objections
Speakers: David Frautschy, Raffaele Sommese, Olivier Crepin Leblond
Policymakers often favor rights holders or quick-fix solutions over technical community warnings, which distorts regulation – David Frautschy Piracy Shield lacks transparency because blocklists are not public, blocks are requested by private parties, and forensic evidence is not independently vetted – Raffaele Sommese There are no silver bullets; all internet interventions have trade-offs and require technical scrutiny – Olivier Crepin Leblond
David questions why policymakers keep listening more to rights holders than to the technical community despite repeated warnings and clear harmful examples, and suggests that this preference for quick fixes is itself part of the problem [243-247]. Raffaele provides an example of this dynamic in Piracy Shield, where private copyright owners can trigger rapid extra-judicial blocking with little vetting and no transparency [142-148]. Olivier generalizes the concern by arguing that politicians are drawn to silver-bullet offers from firms and therefore underappreciate the trade-offs and false positives of such interventions [312-316].
POLICY CONTEXT (KNOWLEDGE BASE)
This has deep historical roots in intermediary-liability and filtering debates. Rights holders and some governments have pushed stronger filtering/cooperation duties, while technical and civil society actors have warned of overblocking, privacy harms, and inappropriate delegation of adjudication to intermediaries [S77][S91]. DNS-governance debates also document concerns that using technical infrastructure for content control can globalize the impact of politically contested decisions [S73][S86].
Unexpected Differences
Disagreement over transparency despite broad support for rights-respecting safeguards
Speakers: Miguel De Bruycker, Peter Kovdynik
Transparency, proportionality, and DPA oversight are necessary to avoid turning phishing detection into censorship – Miguel De Bruycker Public authorities have transparency obligations, especially when their interventions affect markets and private protection services – Peter Kovdynik
This disagreement is somewhat unexpected because both speakers present themselves as concerned with safeguards and preventing abuse, yet they diverge on what transparency requires. Miguel says the system is transparent and overseen but insists that not all methods can be made public because that would weaken defenses [300-303]. Peter responds that public authorities still have a special transparency obligation when they intervene in this space, especially where their actions affect private market actors [289-291].
POLICY CONTEXT (KNOWLEDGE BASE)
This is well situated within the long-running tension between transparency and sensitive enforcement. Multiple sources endorse transparency as vital for rights protection and accountability [S69][S81], yet trust-and-safety discussions show persistent disagreement over what must be disclosed and how [S70][S71]. Historical commentary explicitly notes that some policy processes may justify limited visibility rather than full operational openness [S90].
Disagreement within a generally security-oriented discussion over whether any infrastructure-layer intervention should occur at all
Speakers: Miguel De Bruycker, Peter Kovdynik, Raffaele Sommese
Belgian anti-phishing shield as a practical protective layer – Miguel De Bruycker Infrastructure-level mitigation should be questioned when more granular user- or application-level tools may exist – Peter Kovdynik IP and DNS blocking are blunt tools that often affect many unrelated services because internet resources are shared – Raffaele Sommese
A notable and somewhat unexpected split appears not between security and rights camps, but within a shared concern for user safety. Miguel presents a bounded DNS-layer warning system as a legitimate and useful defense against phishing [34-45][67-72], while Peter questions the whole premise of doing mitigation at the infrastructure layer [292-297], and Raffaele broadly characterizes IP/DNS blocking as the wrong tool because of collateral effects and ineffectiveness [110-125][150-161].
POLICY CONTEXT (KNOWLEDGE BASE)
This mirrors longstanding divides in Internet governance over whether infrastructure actors should participate in content control. DNS and infrastructure-moderation sources document deep disagreement over whether operators should intervene at all, given the mismatch between infrastructure functions and content-specific judgments [S73][S78]. Earlier civil society and technical commentary similarly warns against turning DNS and other intermediaries into content police [S77][S86].
Disagreement over child-protection tools among speakers who all accept the need to protect minors
Speakers: Raffaele Sommese, Miguel De Bruycker, Andre Melancia, Olivier Crepin Leblond
For universally illegal content such as CSAM, stronger blocking may sometimes be justified, but the existence of bulletproof hosting remains a core problem – Raffaele Sommese Transparency, proportionality, and DPA oversight are necessary to avoid turning phishing detection into censorship – Miguel De Bruycker Child protection and age-verification measures can create serious harms to privacy, anonymity, and freedom of expression – Andre Melancia Politicians often seek fast “silver bullet” child-safety solutions despite the complexity and side effects of such measures – Olivier Crepin Leblond
It is unexpected that a discussion framed around online harms would reveal such a sharp divide over child-protection methods even though no one disputes the objective. Raffaele leaves room for stronger blocking in extreme cases like CSAM [264-270], Miguel explicitly refuses to extend his system into broader content control areas such as adult-site restrictions [323-325], and Andre and Olivier stress the freedom, privacy, and overreach risks of age-verification and similar child-safety measures [280-281][312-316].
POLICY CONTEXT (KNOWLEDGE BASE)
This is directly echoed in current policy debates where there is consensus on protecting minors but conflict over means. Recent sources show disputes over age verification, encrypted scanning, and privacy-preserving alternatives, even among actors who share the child-safety goal [S89][S96]. Broader online-safety discussions likewise frame child protection as legitimate while emphasizing that implementation choices remain contested and rights-sensitive [S69][S95].
Overall Assessment

The main disagreements were not about whether online harms are real, but about which technical layer should be used to address them, how much transparency and accountability public interventions require, and how to balance urgent protection goals against collateral damage and rights risks. The sharpest divide was between Miguel’s defense of narrowly scoped DNS warning for phishing and Raffaele’s and Peter’s broader skepticism toward infrastructure-layer intervention [34-45][60-64][110-125][150-161][292-297]. A second major fault line concerned governance safeguards: Miguel defended limited disclosure of methods within an overseen system, while Peter and Raffaele pushed for stronger transparency and auditability, especially where public action causes harm or affects markets [141-148][253-261][289-303]. Child-protection cases added a further tension between stronger intervention for universally illegal content and concern about privacy, anonymity, and overbroad controls [264-270][280-281][312-316][323-325].

Moderate. The speakers broadly shared end goals such as reducing cybercrime, protecting users, and avoiding abuse, but they disagreed substantially on implementation choices and safeguards. This level of disagreement implies that future policy on online harms is likely to hinge less on whether action is needed and more on designing narrowly tailored, transparent, technically informed, and rights-respecting mechanisms that distinguish between phishing/cybercrime mitigation and broader content control [67-72][169][292-297][331][333].

Partial Agreements
Both speakers agree on the goal of reducing online harm and tackling cybercrime, and both reject crude IP blocking as especially problematic [174][304]. They diverge on method: Miguel defends carefully limited DNS warning for highly confident phishing cases as a necessary protective layer [34-45][64][67-72], while Raffaele argues that DNS and related infrastructure blocking are generally the wrong tools and that authorities should focus more on source-level and financial disruption of bad actors [110-125][166-169][304].
Speakers: Miguel De Bruycker, Raffaele Sommese
Belgian anti-phishing shield as a practical protective layer – Miguel De Bruycker The right approach is balance: doing nothing is not acceptable, but interventions must be carefully scoped – Miguel De Bruycker IP and DNS blocking are blunt tools that often affect many unrelated services because internet resources are shared – Raffaele Sommese Better alternatives include follow-the-money investigations, using EU legal tools against hosting providers, and source-level takedowns – Raffaele Sommese
Both agree that safeguards and user protection matter and that interventions need to be bounded rather than arbitrary. Miguel frames this in terms of proportionality, transparency, opt-out design, and DPA oversight for phishing-only measures [40-49][60-64][101-103]. Peter agrees on the need for restraint but argues that this should lead policymakers away from infrastructure-layer intervention and toward more granular user- or application-level tools, while also demanding stronger transparency from state actors [292-297].
Speakers: Miguel De Bruycker, Peter Kovdynik
Transparency, proportionality, and DPA oversight are necessary to avoid turning phishing detection into censorship – Miguel De Bruycker Infrastructure-level mitigation should be questioned when more granular user- or application-level tools may exist – Peter Kovdynik Public authorities have transparency obligations, especially when their interventions affect markets and private protection services – Peter Kovdynik
All three accept the legitimacy of the goal of protecting children and addressing serious harm online, but they differ on the means. Raffaele allows that stricter blocking may sometimes be necessary for universally illegal content like CSAM [264-270], whereas Andre stresses that age-verification and child-protection tools can seriously damage privacy, anonymity, and free expression [280-281], and Olivier warns against simplistic child-safety fixes marketed as silver bullets [312-316].
Speakers: Raffaele Sommese, Andre Melancia, Olivier Crepin Leblond
For universally illegal content such as CSAM, stronger blocking may sometimes be justified, but the existence of bulletproof hosting remains a core problem – Raffaele Sommese Child protection and age-verification measures can create serious harms to privacy, anonymity, and freedom of expression – Andre Melancia Politicians often seek fast “silver bullet” child-safety solutions despite the complexity and side effects of such measures – Olivier Crepin Leblond
There is broad agreement that collaboration across actors and borders is necessary to address evolving online harms [174-180][227-229][333]. The difference lies in the preferred form of collaboration: Miguel emphasizes operational cooperation with platforms and service providers for quick practical mitigation [174-182][271-279], while Raffaele emphasizes technical cooperation, shared detection models, and more appropriate targeting closer to the source [227-229][169].
Speakers: Miguel De Bruycker, Raffaele Sommese, Philip Lucas, Participant
Collaboration with hyperscalers and platforms is improving, leading to faster action such as moving harmful emails to spam or removing malicious ads – Miguel De Bruycker Shared models and cooperation among European registries/CCTLDs have already improved phishing detection – Raffaele Sommese Multi-stakeholder collaboration is needed to tackle evolving online harms effectively – Philip Lucas Collaboration among member states and sector actors can improve phishing detection and response – Participant
Takeaways
Key takeaways
The discussion emphasized that online harms, especially phishing and scams, are evolving rapidly and require practical technical measures combined with multi-stakeholder cooperation. Belgium’s anti-phishing approach was presented as a DNS-based warning system built on crowdsourced user reports, automated analysis, commercial partner review, and voluntary ISP participation, with an opt-out model for users. The Belgian system aims to target only domains judged almost certainly malicious, not content more broadly, and its operators stressed proportionality, transparency, and data protection oversight to avoid censorship risks. Participants agreed that technical protection layers such as spam filters, DNS warnings, and related safeguards can be useful even if imperfect, provided they are narrowly scoped and supervised. At the same time, strong concerns were raised that IP and DNS blocking are blunt tools for content regulation because internet resources are shared, which creates substantial risks of overblocking and collateral damage. The Italian Piracy Shield was discussed as a negative example: it has blocked large numbers of IPs and domains, harmed legitimate services, lacked transparency, and has been easy for targets to evade by rotating domains and IPs. Several speakers concluded that infrastructure-level blocking is often ineffective against piracy and other harms when operators can cheaply switch infrastructure, while legitimate users and businesses bear the cost. Alternative approaches were highlighted, including source-level takedowns, follow-the-money investigations, use of EU legal tools against hosting providers, and cooperation with platforms and service providers. Cross-border enforcement remains technically and legally difficult, especially for DNS and resolver blocking, because user location cannot be determined reliably enough to avoid extraterritorial effects. Collaboration across actors was identified as essential: between governments and private providers, among member states, among registries/CCTLDs, and with large platforms and hyperscalers. Participants noted that private infrastructure providers often respond more effectively to abuse notifications framed in terms of platform policies than to formal legal citations, which can slow responses. There was broad agreement that there are no silver-bullet solutions to online harms; all interventions involve trade-offs and should be designed with technical expertise and rights safeguards. Child protection and age-verification policies were discussed as especially sensitive, with warnings that blunt technical controls can undermine privacy, anonymity, and freedom of expression. A recurring governance conclusion was that content-level harms should not automatically be addressed at the infrastructure layer when more granular user- or application-level tools may be available. Young people and affected users were encouraged to participate more actively in these policy debates, especially when measures are justified as protecting them.
Resolutions and action items
No formal resolution was adopted during the session. Belgium reported an ongoing project to expand its anti-phishing capability beyond links and websites to additional scam indicators such as phone numbers, WhatsApp accounts, and messaging-related signals, with production targeted by the end of the year. Participants encouraged greater collaboration among EU member states and sector actors to share methods, models, and intelligence for phishing detection and mitigation. Raffaele Sommese suggested greater use of alternatives to blunt blocking, especially follow-the-money investigations, use of EU legal tools against abusive hosting providers, and source-level takedowns. Andre Melancia encouraged stakeholders to coordinate, connect with counterparts across the EU, and build larger collective advocacy efforts so concerns receive more policy attention. Participants pointed to further evidence-gathering and awareness resources, including existing studies on economic harms from network blocking, to inform policymakers and future discussions. A recommendation was made for youth participants to engage actively in these debates and articulate what harms they actually want protection from.
Unresolved issues
How to determine the proper balance between protective technical intervention and risks to freedom of expression, privacy, anonymity, and overblocking remains unresolved. Whether and when infrastructure-level measures such as DNS or IP blocking are justified for different categories of harm was debated but not settled. No clear consensus emerged on the best technical and governance model for protecting minors online without creating disproportionate privacy and free-expression harms. Cross-border enforcement remains unresolved, especially how to apply blocking measures without unlawful or impractical extraterritorial effects. The question of whether rights holders or block requesters should bear liability and compensation obligations for wrongful blocking was raised but not decided. How to ensure adequate transparency in state-linked or regulator-mandated blocking systems without undermining operational effectiveness remains unresolved. The extent to which public authorities should disclose their technical detection methods versus keeping them confidential to prevent circumvention was left open. No definitive answer was given to why policymakers continue to favor quick-fix blocking approaches over technical community warnings, beyond general observations about political incentives and lobbying pressure. The broader question of what the most appropriate, granular alternatives are to infrastructure-level blocking in many policy areas was discussed but not fully resolved. How to address harmful or illegal content hosted by unreachable or non-cooperative providers, including bulletproof hosts, remains an open challenge.
Suggested compromises
Use narrowly scoped DNS warning systems for clearly malicious cybercrime domains while avoiding broader content-based censorship or indiscriminate blocking. Prefer domain-level warning or filtering over IP blocking, since IP blocking was widely seen as causing excessive collateral damage. Adopt opt-out user protection models, as in the Belgian system, so protections are enabled by default but users retain the ability to switch away. Combine technical mitigation with transparency, proportionality, DPA or similar oversight, and user challenge/removal mechanisms to reduce censorship and abuse risks. Frame abuse notifications to platforms in operational or policy terms rather than immediately as legal accusations, to encourage faster voluntary action while still addressing harms. Pursue collaborative, non-binding arrangements with ISPs and platforms where possible instead of relying only on mandatory legal blocking regimes. Reserve stronger blocking measures, if used at all, for narrowly defined categories of universally illegal content and only with recognition of the associated risks. Use infrastructure-level intervention only when more granular user-, application-, or source-level measures are unavailable or ineffective, rather than as a default response. Accept that imperfect protective tools may still have value, but pair them with other approaches such as law enforcement, source takedowns, and financial disruption of abusive actors.
Thought Provoking Comments
Miguel De Bruycker argued that governments cannot build a secure online environment without some form of technical protection, comparing DNS warnings to spam filters and saying that ‘not doing nothing is more of a concern than trying to do something.’
This was insightful because it framed blocking and warning measures not as censorship by default, but as baseline safety infrastructure. His analogy to spam filters and warning signs around a hole in the street made a technically and politically sensitive issue easier to grasp, while also acknowledging proportionality, transparency, and the risks of overblocking.
This comment set the initial terms of the debate. It anchored the discussion in a practical cybersecurity mindset and invited later participants to respond to a concrete question of balance rather than a simple pro/anti-blocking binary. Much of the later exchange—especially around transparency, proportionality, and collateral damage—was a direct response to this framing.
Speaker: Miguel De Bruycker
Raffaele Sommese distinguished between blocking aimed at user protection and blocking used to enforce governmental or private-party decisions, arguing that the problems ‘start to rise’ in the second category because IP/DNS infrastructure is ‘not actually the right tool.’
This was a key conceptual intervention because it separated two very different uses of similar technical mechanisms. Instead of treating all internet blocking as one issue, he introduced a more nuanced framework: security-oriented intervention versus content-enforcement intervention. That distinction helped clarify why some measures may be defensible in one context and harmful in another.
This comment shifted the session from a national anti-phishing case study into a broader governance debate about infrastructure-level enforcement. It deepened the conversation by creating a taxonomy participants could use afterward, and it paved the way for later challenges about copyright blocking, child protection, and freedom of expression.
Speaker: Raffaele Sommese
Sommese said that Italy’s Piracy Shield had blocked ‘more than 10,000 IPs and 40,000 domains’ and caused ‘thousands of collateral damage to legitimate websites,’ while also proving ineffective because evasion is cheap and easy.
This was thought-provoking because it replaced abstract worries about overblocking with concrete evidence. By pairing collateral damage with economic details—IP addresses costing cents, domains being cheap, and blocks lasting indefinitely—he showed that the system can simultaneously be harmful and ineffective.
This was one of the biggest turning points in the discussion. It intensified scrutiny of infrastructure blocking and prompted questions about liability, transparency, cross-border enforcement, and alternatives such as ‘follow the money.’ It also sharpened the contrast between narrowly scoped anti-phishing warnings and expansive copyright-driven blocking regimes.
Speaker: Raffaele Sommese
Sommese asked: ‘Do we have a better alternative or not?’ and suggested using legislative tools within the EU to target hosting providers and financial flows instead of relying on broad technical blocking.
This was insightful because it moved the conversation from criticism to solution space. Rather than merely denouncing Piracy Shield, he proposed enforcement against infrastructure providers and payment chains, making the debate more constructive and policy-oriented.
This comment opened a new line of discussion around alternatives to DNS/IP blocking. Later responses from both panelists referred back to complementary strategies such as law enforcement, provider cooperation, and follow-the-money approaches. It broadened the discussion from technical filtering toward systemic enforcement models.
Speaker: Raffaele Sommese
The CleanDNS participant stressed that multiple countries represented in the room were tackling similar problems and asked how stronger collaboration between member states could be pursued, while also asking what more should be done ‘at the infrastructure level’ across the provider chain.
This was thought-provoking because it elevated the discussion from national examples to European coordination. It recognized that phishing, abuse infrastructure, and blocking practices are transnational, and that fragmented national responses may be less effective than shared models, data, and responsibilities.
This intervention changed the scale of the conversation. The moderators and panelists began discussing European-level coordination, shared machine-learning models across ccTLDs, and multi-stakeholder cooperation. It reinforced the idea that these harms cannot be handled effectively by isolated national systems alone.
Speaker: Participant (CleanDNS representative)
David Frautschy warned that the analogy between IP addresses and telephone numbers can mislead policymakers, because unlike a single home line, blocking an IP can take down many unrelated services; he gave the example of a payment gateway disruption affecting e-commerce during a football match.
This was insightful because it challenged the communicative framing used earlier in the session. He pointed out that even explanatory analogies can distort policy understanding if they understate the scale of collateral impact. His concrete payment-gateway example made the technical stakes intelligible and politically relevant.
This comment deepened the analysis by moving the conversation beyond whether blocking works to how technical metaphors shape policy errors. It also led directly into broader criticism of why policymakers listen more to rights holders than to technical experts, increasing the session’s focus on governance failures and public communication.
Speaker: David Frautschy
Frautschy asked why policymakers are listening more to rights holders than to the technical community, despite repeated evidence that these blocking systems are flawed.
This was thought-provoking because it surfaced the political economy behind the technical debate. It suggested that the persistence of bad policy may not be due to ignorance alone, but to whose voices are institutionally privileged.
This shifted the conversation from technical feasibility to policymaking dynamics. It set up later remarks by Olivier Crepin-Leblond about politicians’ desire for ‘silver bullet’ solutions and helped explain why simplistic blocking proposals continue despite technical objections.
Speaker: David Frautschy
Frautschy also asked whether a liability scheme should require rights holders to compensate websites harmed by wrongful blocking requests.
This was insightful because it converted a technical governance concern into an accountability question. Rather than discussing collateral damage as an unfortunate side effect, he asked who should bear the cost when innocent services are harmed.
This prompted Sommese to emphasize the lack of transparency in current systems and to argue that liability requires public auditability of blocking decisions. The discussion thereby moved into procedural safeguards, due process, and compensation mechanisms—adding legal depth to the technical debate.
Speaker: David Frautschy
Andre Melancia observed that age-verification and similar interventions can undermine freedoms by making anonymous internet use harder and by enabling governments to control populations’ ability to organize and protest.
This was thought-provoking because it connected seemingly narrow technical measures to broader civil-liberties and democratic risks. It reframed online safety interventions as potential tools of social control, especially in non-democratic settings.
This expanded the conversation from anti-phishing and piracy into the rights implications of content controls more generally. It also set up the closing tone of the session, in which broader concerns about democracy, freedom of speech, and authoritarian misuse became explicit.
Speaker: Andre Melancia
Peter Kovdynik said he still did not understand why ‘content mitigation, which is at the application layer or the user level, would have to happen at the infrastructure level,’ and asked for more granular alternatives such as spam folders or browser plug-ins that give users more control.
This was one of the most conceptually important comments because it reframed the issue in architectural terms. Instead of debating only whether blocking is justified, he asked whether the intervention is happening at the wrong layer of the internet entirely. That question goes to the heart of internet governance design.
This comment acted as a late-stage synthesis and challenge. It forced the panelists to clarify transparency, scope, and architectural fit. Miguel defended selective security measures, while Sommese agreed that IP/DNS are ‘the wrong place’ for certain content interventions. The exchange sharpened the distinction between anti-abuse filtering and broad content control.
Speaker: Peter Kovdynik
Olivier Crepin-Leblond remarked that politicians want immediate ‘silver bullet’ solutions because of short political time horizons, and that unless complexity and trade-offs are made clear, harmful quick fixes like age verification will keep recurring.
This was insightful because it explained a recurring pattern in online harms policy: simplistic technical fixes remain attractive not because they are sound, but because they fit political incentives. His comment captured the mismatch between governance timelines and technical/social complexity.
This comment helped tie together several earlier frustrations about policymaker behavior, rights-holder influence, and repeated overreliance on blocking. It gave the discussion a more systemic interpretation of why flawed policies persist, rather than treating each example as an isolated mistake.
Speaker: Olivier Crepin-Leblond
Miguel De Bruycker told youth participants that ‘the Internet is not public space’ but a privately owned ecosystem of devices, ISPs, carriers, and platforms, meaning governments cannot simply impose solutions and must collaborate with private actors in a balanced way.
This was a strong closing insight because it reframed governance responsibility. It challenged simplistic assumptions that the state can regulate the internet as if it were a street or square, while also stressing that private providers therefore carry major public-interest responsibilities.
This comment brought the discussion full circle. It connected the earlier themes of voluntary cooperation, platform responsibility, transparency, and multi-stakeholder governance into a broader structural understanding of internet regulation. It ended the session on a collaborative rather than purely adversarial note.
Speaker: Miguel De Bruycker
Overall Assessment

The key comments shaped the discussion by progressively moving it through three levels. First, Miguel De Bruycker grounded the debate in practical cyber-defense, arguing that some technical protections are necessary and legitimate when narrowly aimed at clear cybercrime. Second, Raffaele Sommese and several participants complicated that picture by showing that infrastructure-level blocking becomes far more problematic when used for copyright or content enforcement, especially because of collateral damage, opacity, and ease of circumvention. Third, later interventions from David Frautschy, Peter Kovdynik, Olivier Crepin-Leblond, and Andre Melancia elevated the debate from technical effectiveness to governance, accountability, architecture, and rights. Together, these comments transformed the session from a discussion of tools into a much richer examination of where intervention should occur, who should decide, who should be accountable, and how to balance security with freedom. The overall flow moved from operational examples to systemic critique, and finally to a more mature multi-stakeholder perspective on online harms.

Follow-up Questions
How can anti-phishing systems evolve beyond email/link detection to address newer phishing vectors such as spear phishing, AI-generated content, SMS phishing, phone numbers, WhatsApp accounts, and other scam indicators?
Phishing techniques are changing rapidly, and defenses focused only on email links may become insufficient. Expanding detection to newer channels is important to keep national reporting and protection systems effective against current attack methods.
Speaker: Nenad Bogunovic; Miguel De Bruycker
How does anti-phishing reporting and screening work in environments using end-to-end encrypted messaging systems?
As harmful content increasingly reaches users through encrypted messaging apps, understanding how reporting can work without undermining encryption is important for balancing security, privacy, and feasibility.
Speaker: Participant from Switzerland
Do we have better alternatives than IP/DNS blocking for combating online piracy and other harmful content, such as follow-the-money approaches and direct action against hosting providers within the EU?
The discussion highlighted that network-level blocking can be ineffective and cause collateral damage. Researching and developing more targeted alternatives is important for reducing harm while still addressing illegal activity.
Speaker: Raffaele Sommese; remote participant from a media regulatory authority; Miguel De Bruycker; Peter Kovdynik
What percentage of scams or malicious campaigns can actually be blocked, and how should effectiveness be measured?
Quantifying effectiveness is necessary for assessing whether technical interventions are worth the costs and risks, and for comparing competing approaches such as warning systems, takedowns, or platform moderation.
Speaker: Remote participant; Miguel De Bruycker
How can collaboration between member states, national CERTs/CCB-like bodies, ccTLD operators, platforms, and infrastructure providers be improved to address phishing and online harms more effectively?
Online harms are cross-border, while many responses remain national. Better coordination could improve threat detection, speed response, reduce duplication, and create more consistent protections across jurisdictions.
Speaker: Participant from CleanDNS; Raffaele Sommese; Andre Melancia; Miguel De Bruycker
What additional actions should be taken at the infrastructure level, beyond DNS or IP restrictions, and what roles should different providers in the chain play?
The discussion suggested that current blocking approaches are too blunt. More research is needed into what infrastructure actors can do responsibly and where intervention should occur without overreaching.
Speaker: Participant from CleanDNS; Peter Kovdynik
Why are policymakers often more persuaded by rights holders or vendors offering quick fixes than by the technical community warning about collateral damage?
This question goes to the heart of governance failure. Understanding the policy incentives, communication gaps, and political pressures involved is important for improving evidence-based digital regulation.
Speaker: David Frautschy; Olivier Crepin Leblond
Should there be a liability scheme requiring parties that request blocking to compensate websites and services harmed by wrongful or overbroad blocks?
Without accountability, harmful blocking may continue unchecked. Research on liability models could help create incentives for accuracy, transparency, and due process.
Speaker: David Frautschy; Raffaele Sommese
What is the better alternative in cases where harmful content providers and hosting providers cannot be reached, especially for child protection, pornographic platforms, or content harmful to minors?
Some harmful-content cases are harder than piracy because direct enforcement may be impossible. This raises a need for research into lawful, effective, and proportionate fallback measures.
Speaker: Remote participant from a media regulatory authority; Raffaele Sommese
How can freedom of speech and anonymity be preserved while implementing online safety interventions, and what safeguards are needed to ensure technical systems do not become censorship tools?
Many participants raised concerns that blocking and verification systems may restrict expression and privacy. Strong safeguards and oversight are essential to prevent misuse, especially in less democratic contexts.
Speaker: Remote participant; Andre Melancia; Peter Kovdynik; Miguel De Bruycker
What supervised methodology, oversight, or governance model is needed to ensure anti-harm systems preserve freedom of speech and do not turn into censorship arms of governments or private parties?
Even well-intentioned systems can be repurposed or abused. Research into oversight, transparency, auditability, and redress mechanisms is critical for legitimacy and public trust.
Speaker: Remote participant; Peter Kovdynik; Miguel De Bruycker
Why is content mitigation often attempted at the infrastructure layer rather than at the application or user layer, and what more granular alternatives should be developed?
This was one of the central technical-governance questions of the session. More granular approaches may reduce collateral damage, cross-border conflicts, and interference with core internet infrastructure.
Speaker: Peter Kovdynik; Raffaele Sommese
How can the technical reasons that make internet blocking unsuitable for child protection and similar goals be explained clearly to laypeople and politicians?
Several speakers noted that policymakers seek simple solutions and may misunderstand technical limitations. Better communication and educational framing are necessary to support sound policy choices.
Speaker: One participant near the end; Olivier Crepin Leblond
How should cross-border issues be handled when blocking measures are imposed nationally but infrastructure and users are global, especially regarding global resolvers, VPNs, CDNs, and extraterritorial effects?
Cross-border enforcement creates legal and technical conflicts and can affect users outside the regulating country. This is an important area for further legal and technical research.
Speaker: Raffaele Sommese; Petra Arts; Peter Kovdynik; David Frautschy
What are the economic costs and wider impacts of network blocking, including effects on legitimate businesses, payment systems, cloud services, and e-commerce?
The session described real cases of collateral economic harm. Better evidence on these costs is important for proportionality assessments and for informing policymakers about unintended consequences.
Speaker: Raffaele Sommese; Petra Arts; David Frautschy
How effective are voluntary, non-binding collaboration models between governments and private service providers compared with legal mandates?
The Belgian model emphasized voluntary cooperation, while other examples involved mandatory blocking. Comparative research could help determine which model works better under what conditions and with what safeguards.
Speaker: Miguel De Bruycker; Peter Kovdynik
What transparency obligations should apply to public-authority security systems, and how much operational secrecy is justified without undermining accountability?
The discussion exposed tension between transparency and operational security. More work is needed to define what should be public, what can remain confidential, and how to ensure democratic oversight.
Speaker: Peter Kovdynik; Miguel De Bruycker
How can collaboration with major platforms and infrastructure intermediaries such as Meta, Google, Microsoft, and Cloudflare be structured to reduce abuse while respecting rights and avoiding overreach?
Large intermediaries are central to both abuse and mitigation. Clearer models for notification, response, shared signals, and safeguards would improve practical responses to online harms.
Speaker: Remote participant; Miguel De Bruycker; Petra Arts
How can youth and affected users be meaningfully included in discussions about online harms and protection measures, especially when policies are justified as protecting young people?
Policies aimed at protecting minors often proceed without their input. Including affected communities can improve legitimacy, accuracy, and understanding of what harms actually matter.
Speaker: Participant asking for a recommendation for youth diggers; Raffaele Sommese
How can detection systems proactively identify malicious domains targeting governments and critical infrastructure without revealing methods that make evasion easier?
The exchange suggested an unresolved research challenge: designing proactive detection that remains effective even when methods cannot be fully disclosed. This matters for protecting high-value targets while preserving security.
Speaker: Stigl Fernandes; Miguel De Bruycker

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