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The policy states that Runway will report any CSAM it becomes aware of to NCMEC and will indefinitely suspend all accounts associated with such content.
This analysis describes what Runway'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
This provision establishes a mandatory reporting and indefinite suspension mechanism that engages U.S. federal CSAM reporting obligations applicable to electronic service providers; it also operates as a permanent enforcement consequence with no stated reinstatement procedure for accounts associated with CSAM.
Under this clause, any account associated with CSAM will be indefinitely suspended with no stated appeal or reinstatement process, and the underlying material will be reported to NCMEC and potentially to law enforcement agencies.
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"We report any child sexual abuse material (CSAM) that we become aware of to the National Center for Missing and Exploited Children (NCMEC), which works with global law enforcement agencies around the world, and we indefinitely suspend all associated accounts.Excerpt from Runway's Content Policy
(1) REGULATORY LANDSCAPE: This provision engages 18 U.S.C. 2258A, which requires electronic service providers to report apparent CSAM to NCMEC. The relevant enforcement authority is the U.S. Department of Justice; NCMEC operates as the designated reporting clearinghouse. Failure to report known CSAM by covered providers carries federal criminal exposure. (2) GOVERNANCE EXPOSURE: High. The provision commits Runway to a specific reporting workflow and permanent enforcement action, creating operational compliance obligations that should be documented in Runway's internal trust and safety procedures and verified against its legal obligations as a covered electronic service provider. (3) JURISDICTION FLAGS: The reporting obligation under 18 U.S.C. 2258A applies to U.S.-based providers; international operations may engage equivalent obligations under EU, UK, and other national frameworks. The EU's proposed CSAM regulation and the UK Online Safety Act also impose detection and reporting duties that may apply depending on Runway's user base and infrastructure footprint. (4) CONTRACT AND VENDOR IMPLICATIONS: Enterprise customers should note that accounts flagged for CSAM will be indefinitely suspended with no stated procedural safeguards, which may affect shared organizational accounts or API credentials. Procurement teams should assess whether account-level suspension could affect broader organizational access rather than only the individual user responsible. (5) COMPLIANCE CONSIDERATIONS: Compliance teams should verify that Runway's internal CSAM detection and reporting workflows satisfy applicable statutory obligations, including timeliness requirements under 18 U.S.C. 2258A, and should document those workflows for audit purposes. Organizations deploying Runway in enterprise contexts should consider whether their acceptable use controls adequately prevent CSAM-related account suspension at the organizational level.
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This provision establishes a mandatory reporting and indefinite suspension mechanism that engages U.S. federal CSAM reporting obligations applicable to electronic service providers; it also operates as a permanent enforcement consequence with no stated reinstatement procedure for accounts associated with CSAM.
Under this clause, any account associated with CSAM will be indefinitely suspended with no stated appeal or reinstatement process, and the underlying material will be reported to NCMEC and potentially to law enforcement agencies.
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