Provision record
OpenAI · Usage Policies · View original document ↗

Mandatory NCMEC Reporting of Apparent CSAM

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Document Record

What it is

The policy states that OpenAI reports apparent child sexual abuse material and child endangerment to the National Center for Missing and Exploited Children (NCMEC). The policy also prohibits any use of OpenAI services to generate, distribute, or facilitate CSAM or grooming of minors.

This analysis describes what OpenAI'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 discloses OpenAI's active reporting practice to NCMEC, which is consistent with obligations established under US federal law for electronic service providers that obtain apparent CSAM. This reporting obligation has implications for any platform operator using OpenAI services in contexts where user-generated content is possible.

Clause Stability Stable

0
Changes
5
Months Monitored
Jul 9, 2026
First Seen
Jul 9, 2026
Last Seen

Consumer impact (what this means for users)

The agreement states that OpenAI reports apparent child sexual abuse material and child endangerment to NCMEC, and prohibits any use of its services for CSAM generation, grooming, or sexualization of minors under 18. Under these terms, such content constitutes a prohibited use regardless of whether any portion is AI-generated.

Cross-platform context

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▸ View Original Clause Language DOCUMENT RECORD
"
Keep minors safe. Children and teens deserve special protection. Our services are designed to prevent harm and support their well-being, and must never be used to exploit, endanger, or sexualize anyone under 18 years old. We report apparent child sexual abuse material and child endangerment to the National Center for Missing and Exploited Children.

Excerpt from OpenAI's Usage Policies

ConductAtlas Analysis

Institutional analysis (regulatory & governance intelligence)

1) REGULATORY LANDSCAPE: US federal law requires electronic service providers that discover apparent CSAM to report it to NCMEC.

Insight

Unlock the full institutional analysis

Enforcement risk, jurisdiction flags, contract triggers, and due diligence action items.

Applicable agencies

  • Federal Trade Commission (ftc)
    Oversees unfair or deceptive business practices and can investigate companies that mislead consumers about data collection, sharing, or use.
    Who can file: Anyone affected by the company's practices (US or international)
    What you need: Your account details, a timeline of relevant events, and a description of the specific issue
    What to expect: Complaints inform FTC enforcement priorities and investigations but do not result in individual resolution or compensation
    File a complaint →

Provision details

Document information
Document
Usage Policies
Entity
OpenAI
Document last updated
March 5, 2026
Tracking information
First tracked
March 10, 2026
Last verified
July 9, 2026
Record ID
CA-P-014910
Document ID
CA-D-00005
Evidence Provenance
Source URL
Wayback Machine
Content hash (SHA-256)
f25b5b6c90b0be7bd1627eb2cc762558d9d70ea2b7bfc1b0f7a1b62abd9883a6
Analysis generated
March 10, 2026 03:28 UTC
Methodology
Evidence
✓ Snapshot stored   ✓ Hash verified
Citation Record
Entity: OpenAI
Document: Usage Policies
Record ID: CA-P-014910
Captured: 2026-03-10 03:28:59 UTC
SHA-256: f25b5b6c90b0be7b…
URL: https://conductatlas.com/platform/openai/usage-policies/provision/CA-P-014910/mandatory-ncmec-reporting-of-apparent-csam/
Accessed: Aug. 18, 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 OpenAI's Mandatory NCMEC Reporting of Apparent CSAM clause do?

This provision discloses OpenAI's active reporting practice to NCMEC, which is consistent with obligations established under US federal law for electronic service providers that obtain apparent CSAM. This reporting obligation has implications for any platform operator using OpenAI services in contexts where user-generated content is possible.

How does this clause affect you?

The agreement states that OpenAI reports apparent child sexual abuse material and child endangerment to NCMEC, and prohibits any use of its services for CSAM generation, grooming, or sexualization of minors under 18. Under these terms, such content constitutes a prohibited use regardless of whether any portion is AI-generated.

Is ConductAtlas affiliated with OpenAI?

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