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Tech Coalition PhotoDNA sublicensing: delegated access, undisclosed decision terms

9 September 2026. Bounded acquisition closed. This packet owns the Coalition selection/authority lane. It does not determine Microsoft SDK/cloud terms or NCMEC hash access, which are separate lanes. No application, account, software execution, media, hash list, outreach or payment was attempted.

What is established

The Coalition is a publicly acknowledged licensing intermediary. Its [2023 annual report](http[local research file] reproduces a statement attributed to Microsoft describing provision of PhotoDNA for the Coalition to license to its members. This is a counterparty-attributed statement in the recipient's report, not the original interparty agreement.

The [2024 annual report](http[local research file] dates becoming a sublicensor to 2023 and extending sublicenses to qualifying non-members to 2024. PDF13/printed13 separately reports integrating PhotoDNA with open-source Hasher-Matcher-Actioner for already licensed companies, alongside a Microsoft statement attributed to Liz Thomas supporting the licensing arrangement. Thus non-membership access predates the January 2025 announcement below. These are retrospective programme accounts; no individual executed sublicense or exact grant date appears in the acquired passages. Page28 also describes companies acting on content under their own policies and procedures. Neither integration nor access establishes a common removal instruction.

The [27 January 2025 announcement](http[local research file] says the Coalition expanded its agreement for Microsoft's updated technology. It reports licensing scope extended beyond CSAM to terrorist content and adults' non-consensual intimate imagery. Its implementation section invites member and non-member licensing inquiries, offers the code without charge and describes responses as typically arriving within a week. That is a response estimate, not a guaranteed licence award or observed turnaround. It offers implementation assistance and separately ongoing support for members. Compatibility with NCMEC, GIFCT and StopNCII is claimed; access to those bodies' data is not granted by that sentence. This page publishes neither the Microsoft–Coalition agreement nor an applicant contract or approval rubric. Its promotional privacy and effectiveness statements are not treated here as independent technical findings.

The public intake is not the sublicense contract

The [current Pathways page](http[local research file] retained earlier on 9 September 2026 and reread in full, permits employees of technology companies hosting or providing access to user content or communications. It excludes vendors/service providers without that function and staff of existing Coalition members. Staff review submitted information for eligibility. Participation is free and does not require or guarantee later membership. A separate opportunity allows companies to apply for a PhotoDNA sublicense. These are Pathways admission conditions; the acquired page does not establish that every participant receives a licence or that its exclusions govern the separate member licensing route. Intake labels include sector, products, region, company size and confidentiality consent; no form was submitted.

The [nine published non-member account terms](http[local research file] govern the site and mentoring. Clauses1–4 cover discretionary updates, reasonable-effort information responses, accurate registration and a revocable, nontransferable site licence with limited copying permissions. Clauses5–6 cover mentoring confidentiality. Clause7 preserves voluntary use and the participant's decision whether/how to use materials, disclaims creation of a legal/community standard, and recommends the participant's own legal review. Clauses8–9 address severability and dispute rules. These are actual published conditions on resources. Their site-licence revocability cannot be transplanted into PhotoDNA's unknown sublicense withdrawal terms. The published document is not evidence that any particular company assented or was sanctioned. Its current capture has no established publication/revision date.

Authority map and competing interpretations

Typed relationship Supported state What it does not establish
Microsoft → Tech Coalition: sublicensing delegation Coalition's retrospective programme accounts, including attributed Microsoft statements, and January 2025 expansion announcement Full delegated powers, Microsoft reserved approval, revocation, audit or downstream-use clauses
Tech Coalition → applicants: licensing route Member/non-member inquiries, free code, administrative response estimate Named decision-maker, licence guaranteed by eligibility, a particular granted/denied licence
Tech Coalition → Pathways participants: selective resource access Published admission criteria, staff review and site/mentoring terms These conditions are the PhotoDNA contract or admission confers membership/hash access
Tech Coalition → licensed implementers: integration support 2024 HMA integration and 2025 assistance announcement PhotoDNA itself is open source, automatic access to reference hashes, or mandated production configuration
Provider → its content decisions: retained implementation role Reported use under provider policies; voluntary-materials clause Unqualified freedom from separate contracts or applicable law

A concrete intermediary can reduce transaction and engineering costs while retaining an administrative gate. Both features are visible. The currently acquired public evidence cannot distinguish routine eligibility/safety screening from broader discretion in actual licence decisions. It also cannot establish donor or member influence over an individual grant or refusal. The published non-member route is evidence against treating paid membership as universally necessary for access.

Finite search result and discriminating missing records

Six distinct discovery queries were attempted: site:technologycoalition.org "PhotoDNA" license; the same domain with "PhotoDNA" sublicense; the same domain with "PhotoDNA" eligibility; "PhotoDNA" "Tech Coalition" "sublicense" -site:technologycoalition.org; "PhotoDNA" "Tech Coalition" eligibility approval license denied agreement; and "PhotoDNA" "Tech Coalition" ("license granted" OR "sublicensed" OR "denied" OR "rejected" OR "licensing agreement"). The initial three-query response was wholly truncated and not used as evidence; the sublicense query was rerun. Later visible results identified the announcement and annual reports; the last exact decision query returned no results. Not every returned snippet/link was opened. A proxy-hosted OpenAI result and third-party/LinkedIn snippets were not acquired or treated as original records. No licence recipient was inferred from an adoption count, HMA use or membership testimonial.

No public selection rubric, named issued/denied Coalition sublicense, executed applicant agreement, or licence review/revocation procedure was located within this finite scope. This is a bounded search result, not proof that none exists. The decisive next records are the Microsoft–Coalition delegation and current applicant sublicense/template, with any eligibility schedule; these would locate reserved approvals, permitted purposes, term, termination, derivative/code distribution, data access and reporting conditions. A dated executed licence or refusal/appeal correspondence would then establish how those powers were exercised. Likely custodians are Microsoft, the Coalition and the relevant applicant. No request was made.

Custody and exact reading extent

coalition-captures.json records three new successful official originals, plus two reused Pathways originals with verified hashes and prior-manifest ancestry. The 2025 announcement's full substantive body was read through the primary web reader and retained HTML-derived text. Both reports were text-searched in full for PhotoDNA/sublicensing; complete extracted text of 2023 PDF10/20 and 2024 PDF13/28/29/35 was read. Only the licensing/provider-policy passages identified above support this packet; chart graphics and other report pages were not substantively inspected. The Pathways substantive programme/FAQ/intake labels and all nine account terms were reread from retained derivatives. Original HTML/PDF bytes remain distinct from derived text. All three new ordinary public GETs succeeded; no failed access route or known closed source was retried. Acquisition stops here for the combined forest assessment.