Content warning: this investigation addresses sensitive topics related to the sexualization and sexual abuse of minors.
How many times does a TikTok user have to offer or solicit child sexual abuse material (CSAM) to be kicked off the platform? Apparently, more than once. As part of our “Predators on TikTok 2: An Open Buffet for More Than 1,300 Pedophiles” series, we discovered thousands of comments in videos of children that offered to “exchange”, “gift”, or that actively demanded sexual images from children as young as 8. We reported more than a hundred of those comments to TikTok for being illegal: while the platform removed 99%, practically all the accounts behind them (96%) remained active and able to keep doing the same.
While many platforms have strike systems to punish users that repeatedly break their rules, it does not seem reasonable that promoters of illegal child sexual abuse material in particular get second chances. That is something that TikTok itself agrees on: the most popular global platform for teenagers declares that it issues “permanent bans on the first strike for severe violations, including showing or facilitating CSAM”. For some reason, this policy was not followed in this case.
“Rating” and offering sexual images of minors
In videos and comments, our investigation found hundreds of users offering to “rate” sexual images from minors. They often specify that they are looking for nudes from particular age groups such as “men of 12”, “only 13 years old or less”, or “from 8 to 10”. Most of them use slight variations in their writing, likely to avoid TikTok’s automated moderation systems. For example they employ words like “decks” instead of “dicks” to refer to male genitalia, and many messages read like “men of 1.2”, “only 12+1 years old or less”, or “from 8 to 1/0”. However, some users do it in the open.
Some other users do not ask for but offer images that constitute child sexual abuse material. Hundreds of comments offer to “gift” or exchange CSAM of particular types on videos of minors that appear to be under 13 (“I exchange forced”, “I exchange asleep”) and even declare to be producing the content themselves (“I have a niece and I exchange”, “I sell from my little sister”, “I have my own, done at home”).
These users connect with fellow pedophiles in the comments section of TikTok videos depicting minors and then move to private messaging platforms such as Telegram, Signal, or Zangi. Videos and comments offering or soliciting child sex abuse material are often accompanied by QR codes or other means to access those services, despite TikTok’s Community Guidelines banning “invitations to do something sexual, connect off-platform, or share explicit images”.
Another relevant example of this are the TikTok accounts, comments, and videos that promote clickable links and QR codes leading to self-described “hormonal groups”: group chats in encrypted messaging platforms, mostly WhatsApp, where explicit sexual content involving children is shared.
These groups recruit minors to incite them to share sexual images. To test whether TikTok’s ban on off-platform invitations was being enforced effectively, we reported 40 videos that included references to such links or images of QR codes and found that TikTok left 70% of them online after it decided they did not break its rules. Those 40 videos alone accumulated over 290,000 likes and the accounts behind them had more than 70,000 followers.
Dangerous and illegal
The content we found during this investigation is clearly widespread and dangerous for minors. From thousands of videos and comments we identified that asked for sexual images to “rate”, 20 alone accumulated over 1.5 million views and hundreds of comments actively asking for explicit sexual material depicting minors. In 50 videos of minors that appear to be under 13, we found more than 1.300 comments from users that offered or solicited CSAM. This is of course against TikTok’s Community Guidelines but most importantly it is a crime in most jurisdictions, certainly also in Spain where we conducted the investigation.
Article 189 of the Spanish Penal Code establishes prison terms for “anyone who recruits or uses minors to produce any kind of pornographic material” and for “anyone who produces, sells, distributes, exhibits, offers or facilitates the production, sale, dissemination or exhibition by any means of child pornography”. The fact that this content is widely available and popular in the platform interacts with TikTok’s own legal obligations within the European Union Digital Services Act (DSA).
TikTok must act “expeditiously to remove or to disable access” to illegal content after becoming aware of its existence or else become liable for it, and it also has to inform law enforcement or judicial authorities of any suspicion of criminal offence threatening “the life or safety of a person” and provide all relevant information. More importantly, as an officially designated ‘very large online platform’ in the EU, TikTok must have “reasonable, proportionate and effective mitigation measures” against the dissemination of illegal content through its services, something that our findings call into question.
If you are outside Spain and need help or wish to report child abuse, find your local helpline at Child Helpline International or INHOPE. To report online child sexual abuse material (CSAM) anonymously, you can contact the Internet Watch Foundation (IWF). In an immediate emergency, always contact your local emergency services first.
Methodology
For this part of the investigation, we used TikTok’s reporting functionality to flag different contents for being illegal or for violating the platform’s terms of service.
We reported as illegal content 106 comments offering or soliciting CSAM, including:
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60 comments that offered to sell, gift, or exchange material. We reported them using the following route:
Report >>> Report illegal content >>> Child Sexual Exploitation >>> Offering to supply, sell, distribute child sex abuse material
‘Relevant law’: Spanish Penal Code 189
‘Report explanation’: The comment is offering to trade or provide intimate or sexualizing images of minors
TikTok removed 56 comments in the first instance and 3 more after an appeal in which we argued that “The comment is offering to trade or provide intimate or sexualizing images of minors”. All but one of the 56 accounts that had posted the comments were active 72 hours after reporting the content.
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46 comments that offered to “rate” nude pictures of children. We reported them using the following route:
Report >>> Report illegal content >>> Child Sexual Exploitation >>> Content relates to grooming or sexual solicitation of a child
‘Relevant law’: Spanish Penal Code 189
‘Report explanation’: The comment is asking for sexual images of minors
TikTok removed all 46 comments in the first instance. 40 of the 43 accounts that had posted the comments were active 72 hours after reporting the content.
In total, from the 106 comments reported as illegal content for offering CSAM, TikTok removed 105 (99%); and from the 99 accounts that had posted the comments, 95 were still active 72 hours after the reports (96%).
We reported as a violation of TikTok’s terms and conditions 40 videos that invite users to join so-called “hormonal groups” in private messaging platforms, mostly WhatsApp. This is jargon used to describe chat groups set up for minors to share or exchange sexual images and/or videos. A QR code posted either on the TikTok video itself or in the user's TikTok profile image leads to these off-platform chats. In some cases, the video instructs users to click directly on a link posted in the comments or the user’s bio. The videos, evidently catered to minors, have comments of the likes of “someone (1-5 or less)?” that incite certain age groups to join.
We reported the videos using the following route:
Report a video >>> Violence, abuse and criminal exploitation >>> Exploitation and abuse of people under 18
TikTok removed 4 videos in the first instance and restricted 1. It additionally removed 7 more videos after an appeal in which we argued that “This video violates community guidelines on sexual solicitation by inviting to connect off-platform”.
In total, from the 40 videos reported as a violation of TikTok’s terms and conditions on exploitation and abuse of people under 18 and sexual solicitation, TikTok removed 11 (28%).
If you have any questions, you can contact us at [email protected]