Cohere · Cohere Usage Policy · View original document ↗

CSAM Detection and Mandatory Reporting

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Document Record

What it is

The policy prohibits any use of Cohere services to generate, create, share, or facilitate sexually explicit content involving minors and states that Cohere will report CSAM it becomes aware of to competent authorities and other organizations as appropriate.

This analysis describes what Cohere's agreement states, permits, or reserves. It does not constitute a legal determination about enforceability. Regulatory applicability and practical outcomes may vary by jurisdiction, enforcement context, and individual circumstances. Read our methodology

ConductAtlas Analysis

Why it matters (compliance & governance perspective)

This provision establishes Cohere's mandatory reporting commitment for CSAM, which reflects legal obligations under applicable law in multiple jurisdictions and signals active content monitoring or review processes that may apply to user-generated outputs.

Recent Activity

This document changed recently

High May 24, 2026

The updated policy removes all substantive acceptable use requirements that were previously posted and enforceable. Users no longer have a referenced standard defining what conduct is prohibited on the platform. The removal of enforcement procedures means users cannot verify what conduct may trigger access restriction, suspension, or termination. The elimination of the child safety and sexually explicit content prohibitions from the posted policy creates uncertainty about whether these protections remain in effect through other terms or have been abandoned.

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Consumer impact (what this means for users)

Under this clause, any outputs generated through Cohere services that constitute CSAM will be reported to authorities as stated in the policy. This prohibition applies to all users of Cohere services without exception.

Cross-platform context

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▸ View Original Clause Language DOCUMENT RECORD
"
Child Sexual Exploitation and Sexually Explicit Content Involving Minors. Any activity that exploits, abuses, or endangers children, or otherwise compromises the safety of children; or any generation, creation, sharing, or facilitation of sexually explicit content involving minors, including pornographic content or content intended for sexual arousal or gratification. We will report child sexual abuse material that we become aware of to competent authorities and other organizations as appropriate.

Excerpt from Cohere's Usage Policy

ConductAtlas Analysis

Institutional analysis (regulatory & governance intelligence)

1) REGULATORY LANDSCAPE: CSAM reporting obligations are legally mandated for electronic service providers in the United States under 18 U.S.C. Section 2258A, which requires reporting to the National Center for Missing and Exploited Children (NCMEC). Similar obligations exist in EU member states under the proposed EU CSAM Regulation and national implementing laws. The policy's reference to 'competent authorities and other organizations as appropriate' is consistent with these statutory requirements. The FTC and DOJ have enforcement authority in the US context. 2) GOVERNANCE EXPOSURE: High. The existence of a reporting commitment implies that Cohere has or may implement monitoring, detection, or review processes for outputs that could constitute CSAM. Developers building applications on Cohere should assess their own independent CSAM detection and reporting obligations as electronic service providers, which may exist separately from Cohere's commitments. 3) JURISDICTION FLAGS: US-based operators face mandatory CSAM reporting obligations under federal law. EU-based operators face obligations under applicable national laws implementing EU directives on combating child sexual abuse. Customer Application operators in all jurisdictions should assess their independent statutory reporting obligations, which may exist regardless of Cohere's policy commitments. 4) CONTRACT AND VENDOR IMPLICATIONS: Developers building consumer-facing applications on Cohere's infrastructure should evaluate their own CSAM detection and reporting obligations as independent service providers. Reliance solely on Cohere's upstream reporting commitment may not satisfy all applicable legal obligations for downstream application operators. 5) COMPLIANCE CONSIDERATIONS: Legal teams should assess whether their organization's deployment of Cohere services triggers independent CSAM reporting obligations under applicable law, and implement appropriate detection and reporting mechanisms. Organizations operating minor-facing applications should prioritize CSAM prevention controls as part of the child safety requirements also specified in the Customer Application section of this policy.

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Applicable agencies

  • FTC
    The FTC has consumer protection authority relevant to child safety online and coordinates with law enforcement on CSAM-related matters.
    File a complaint →

Provision details

Document information
Document
Cohere Usage Policy
Entity
Cohere
Document last updated
May 5, 2026
Tracking information
First tracked
July 9, 2026
Last verified
July 9, 2026
Record ID
CA-P-015304
Document ID
CA-D-00442
Evidence Provenance
Source URL
Wayback Machine
Content hash (SHA-256)
d54fb0cb544115e31c8ba69f43a76f050bb92af77f6bf7bc14f2f17bca76e972
Analysis generated
July 9, 2026 07:41 UTC
Methodology
Evidence
✓ Snapshot stored   ✓ Hash verified
Citation Record
Entity: Cohere
Document: Cohere Usage Policy
Record ID: CA-P-015304
Captured: 2026-07-09 07:41:41 UTC
SHA-256: d54fb0cb544115e3…
URL: https://conductatlas.com/platform/cohere/cohere-usage-policy/provision/CA-P-015304/csam-detection-and-mandatory-reporting/
Accessed: July 23, 2026
Permanent archival reference. Stable identifier suitable for legal filings, compliance documentation, and research citation.
Classification
Severity
High
Categories

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Frequently Asked Questions

What does Cohere's CSAM Detection and Mandatory Reporting clause do?

This provision establishes Cohere's mandatory reporting commitment for CSAM, which reflects legal obligations under applicable law in multiple jurisdictions and signals active content monitoring or review processes that may apply to user-generated outputs.

How does this clause affect you?

Under this clause, any outputs generated through Cohere services that constitute CSAM will be reported to authorities as stated in the policy. This prohibition applies to all users of Cohere services without exception.

Is ConductAtlas affiliated with Cohere?

No. ConductAtlas is an independent monitoring service. We are not affiliated with, endorsed by, or sponsored by Cohere.