On May 31, the Center for Democracy & Technology (CDT) submitted its comments to the National Institute of Standards and Technology (NIST) regarding NIST's draft report titled "Reducing Risks Posed by Synthetic Content: An Overview of Technical Approaches to Digital Content Transparency." The CDT commended the draft for its comprehensive overview of both the risks and benefits associated with current and emerging content-labeling techniques and synthetic content detection methods.

CDT proposed three main suggestions for enhancing the report. Firstly, they recommended that the report more thoroughly address the challenges related to scaling interventions such as synthetic content detection and labeling systems. They suggested that this could be achieved through a multi-stakeholder process aimed at addressing the complexity and coordination required to effectively implement these techniques while safeguarding individual rights.

Secondly, CDT highlighted the ambitious research agenda presented in the report and advised that it should identify entities responsible for providing independent researchers with access to data necessary to accomplish this agenda.

Lastly, CDT provided clarifying suggestions for expanding on the detailed discussion concerning detection and mitigation strategies for Child Sexual Abuse Material (CSAM) and Non-Consensual Intimate Images (NCII).

The full comments are available for further reading.