Owned in the open.

Legal identity

Custorian is a Danish frivillig forening: a non-profit membership association. It has no shareholders and distributes no profit. The standard it maintains is licensed CC BY-ND 4.0 and remains public even if the association dissolves.

How Custorian is governed

The board

Custorian is governed by a Board of Directors. Board seats are filled by resolution of the sitting board and presented to the general assembly for ratification, not by direct membership election. Under the articles (§ 5), the board has three to seven members serving two-year terms, at least two of whom must be independent: in the previous three years, no employment by, fees from, or ownership or management position in the association, any entity it controls, any certification body operating under the scheme, or any platform certified or seeking certification under it, and no close family or close personal relationship with anyone who has (§ 5.5). Each independent director confirms their independence in writing on appointment and annually thereafter (§ 5.6). The founder holds a seat by right (§ 5.2). She serves as managing director on an interim basis, reconfirmed by the board annually, ending no later than 31 December 2029 unless the board extends it by a majority that includes every independent director; if the association does not have at least two independent directors at that point the appointment ends automatically and the general assembly appoints or confirms a managing director (§ 5.3). She chairs the board only until an independent chair is elected, which the articles require the board to seek by 31 December 2028 (§ 5.4). Until then an independent vice-chair leads every decision about the founder’s role, pay or conflicts, and the founder does not vote on them. Protected provisions (§ 10) prevent any majority from changing the association’s purpose, selling or exclusively licensing the standard, or admitting as members platforms that could be assessed under the standard, without the founder’s written consent. Amendments to the articles need two-thirds of the votes cast (§ 4.6). The standard’s technical content sits outside the general assembly’s vote (§ 5.8). Platforms and services that are or may become subject to assessment under the standard, and companies that control or are controlled by them, are not eligible for membership (§ 3.1) and hold no board seats. Other for-profit organisations may join as Support Members. Since Articles v1.7 (19 October 2026) the association has two classes of membership: Support Members, the voting class, and Alliance Members of the Parents’ Alliance, a passive class for parents and others caring for a child, wherever they live, who have no vote at the general assembly and do not count toward its quorum (§ 3.1, § 3.5). The board oversees the association’s operating arms (below) and recuses from the day-to-day decisions of the advisory bodies and the Certification & Impartiality Committee.

The general assembly meets by 30 June each year and is quorate with one third of eligible voting members, and in any case no fewer than five (§ 4.9). Where that quorum is not met the board may reconvene the assembly on no less than seven days’ notice with the same agenda, and the reconvened meeting is validly constituted whatever the turnout, so the quorum delays a decision rather than blocking it. The assembly elects a lay auditor every year who may not sit on the board (§ 7.4), and approves the annual accounts on the board’s recommendation (§ 5.13, § 4.4(c)). Voting requires three months’ continuous membership (§ 4.8). General assemblies may be held online, with electronic voting and written proxies, and no one may hold more than two proxies (§ 4.10).

Who holds these roles

A standard that asks platforms to prove their claims should not be run by people the public cannot name. Every role below is held under the articles cited beside it, and every recusal listed is a rule in those articles rather than a personal undertaking.

The board is actively recruiting independent directors. The articles require at least two, each meeting the independence test in § 5.5 and confirming it in writing on appointment and annually thereafter (§ 5.6). Seats are unpaid. If you are interested, or want to suggest someone, write to info@custorian.org or use the expression of interest form.

Advisory bodies

A single, non-governing Advisory Board of ten to twelve named individual experts, spanning child rights, legal and regulatory, technology, academic and clinical practice, law enforcement, and youth perspectives, feeds independent, ad hoc, non-binding input into the standard, its ethical dimensions, and child-facing content; it holds no vote and cannot bind the board. Members are drawn from that one roster into focused sub-committees as needed: Standards & Technical (technical evolution and peer review of the standard), Certification & Impartiality (protects the certification firewall and arbitrates appeals, with its own independence safeguards, including the founder’s recusal from membership), and Policy & Rights (regulatory, academic and societal grounding).

Advisory Board seats are unpaid, non-voting, and formalised individually by MOU. Four kinds of seat are open now: legal and regulatory, additional technology and security, law enforcement, and youth perspectives. We are approaching people directly and also take suggestions, including self-nominations. Write to info@custorian.org or use the expression of interest form.

Volunteers

Custorian is built mostly by people giving time rather than by staff. Volunteers work on the control set, legal citation checking, translation, research, design and outreach, with a named role brief and a scope agreed in advance rather than open-ended asks. Volunteers hold no governance role and no say over certification outcomes, and anyone working with material covered by the safeguarding or sensitive-information policies is briefed on those before they start.

If you want to help, write to info@custorian.org saying what you would like to work on and roughly how much time you have. We reply within five working days.

Five arms, one organisation

The association runs as one organisation. It is organised into five arms so that influence cannot travel between them, not so that each raises its own money. A funder gives to Custorian; what the arms do is decide what that money is allowed to buy, which is never a say over the standard or over any certification outcome.

An Association arm handles membership, fundraising and donor stewardship. A Standards arm owns the standard and control framework and is kept independent of commercial revenue. A Certification arm manages the scheme and professional credentialing, and never audits a platform directly. A Research arm runs studies and corpus validation on grant funding, so that a study is never paid for by anyone with an interest in its result.

The fifth is different in kind. The Commercial arm is a separate limited company majority-owned by the association, and it is where outside capital goes: an investor takes equity there, not in the association, and the association itself cannot be invested in or sold. It licenses finished outputs from the association at arm’s length. The licence conveys no raw or lightly processed personal data; investors gain no rights over the association; no platform that could be assessed under the standard, nor anyone it controls or substantially funds, may hold equity in it; and the licence reverts automatically to the association on insolvency, hostile takeover or material ethical breach. The founder and anyone holding equity in the commercial arm is recused from every decision on its licence, valuation, ownership or sale.

The association does not certify platforms

Platform certification is issued exclusively by independent bodies accredited under ISO/IEC 17065 (or ISO/IEC 17021-1 where applicable), operating under a published scheme; the association maintains the scheme and licenses the “Custorian Certified” trademark to qualifying bodies, and never audits or certifies a platform itself. A separate, in-house professional credentialing track (for auditors and child safety officers) runs under ISO/IEC 17024 through the Certification arm. Credentialing people is not the same activity as certifying platforms, and neither is confused with the other. No certification body is licensed under the scheme yet; the list will appear here when the first is.

The firewalls

A standard is only independent if it cannot be captured. This is the full list of how Custorian stays unbought, not a summary. The Articles of Association that make each of these binding are available on request from info@custorian.org. The Governance Charter that implements them day to day is Custorian’s internal operating document, marked not for public distribution; this page is its public summary.

• Certification independence. Only external, accredited certification bodies decide whether a platform passes. Custorian is structurally unable to certify itself or anyone else.
• No funding from anyone it could assess. Custorian takes no funding, in any form, from a platform or company that is or may become subject to assessment under its own standard, or from anyone that controls or substantially funds one.
• Founder recusal. The founder’s current employer is a major platform company; the conflict is declared in the interests register. She is recused from any decision touching it and from any decision on the commercial arm, and the association makes no editorial statement about that company’s platforms, positive or negative, until two years after the employment ends.
• No shares to sell. The association itself has no shares, and no structure exists that would let anyone buy influence over it. The commercial arm does have shares, on the terms above; none of them carry any right over the association or the standard.
• Independent data protection. The data protection lead reports to the board, outside the revenue-generating arms, and neither the Chair nor the managing director may hold that role, even on an interim basis (Articles § 5.11), a rule required by GDPR Article 38(6), not just house policy. The role is currently vacant and will be filled by board resolution; until then, data requests sent to info@custorian.org are logged and answered within one month, and any determination requiring independent judgement is recorded in the register.
• No pay-to-play on the Certification & Impartiality Committee. No one from the Certification arm or the commercial arm sits on it, and the founder may not sit on or chair it. Professional credentialing is preferred for certification bodies, never a mandatory gate.
• Membership cannot buy influence. No fee tier, at any price, confers a board seat, a vote on board composition, or certification eligibility for a member’s own platform or product.
• Paid work is arm’s-length and capped. Board and Advisory service is unpaid. Where the association separately engages a Board or Advisory member’s professional services, that work is disclosed, priced at market rate, and capped as a share of annual expenditure, both in aggregate and per person.
• Board independence is on a public timeline. The articles require at least two independent directors, an independent vice-chair from the first appointment, and target an independent chair by 31 December 2028. Board appointments are ratified by the general assembly, which may refuse them.
• Advisory, never audit. The association and its commercial arm may advise a platform; neither ever audits one, and the records are kept apart.
• Research impartiality. No money passes between the Research arm and any platform under study.
• Data firewall. Research data is separated from any commercial product telemetry; no raw data crosses the licence to the commercial arm.
• Mission lock. The standard, name and trademarks stay with the association; the licence to the commercial arm terminates on breach and reverts on insolvency or takeover.
• Every board decision is published with its rationale.

Donations

Custorian is permitted by Indsamlingsnævnet (the Danish Fundraising Board) under §3 of Indsamlingsloven to collect public donations from 12 August 2026 to 11 August 2027, for project-specific expenses that advance children’s safety online, and operating costs. This channel is for individual donations only. Separately, and regardless of channel, Custorian never accepts donations, grants or sponsorship from a platform or company that is or may become subject to assessment under the standard, or from anyone that controls or substantially funds one, in line with the Funding Policy below. Giving stays separate from influence, the same firewall that shapes membership.

Donate →

Card payment via Stripe, shown above. If you’re in Denmark you can also give via MobilePay (2133), or by bank transfer from abroad (IBAN DK97 0828 0001 1766 17, BIC/SWIFT SWESDK22). Full terms, what your donation funds, and how the collection is accounted for: read the donation agreement.

Policies

Custorian operates under a set of internal policies covering safeguarding, sensitive data handling, conflicts of interest, anti-fraud, data protection, and funding eligibility.

• Child Safeguarding Policy
• Sensitive Information & CSAM-Adjacent Data Handling Policy
• Conflict of Interest Policy
• Anti-Fraud and Anti-Corruption Policy
• Data Protection and GDPR Compliance Policy
• Communications Policy
• Funding Policy
• AI Usage Policy
• Data Handling Policy
• Custorian Data Sovereignty and Ethical AI Principles Policy
• Whistleblowing and Protected Disclosure Policy
• Document Retention and Records Policy
• Standard Publication & Versioning Policy
• Annex A: Gender Equality Plan

Full policy text is available on request: write to info@custorian.org.

Decisions & minutes

The board publishes a summary of every material decision, with the reasoning behind it. We publish approved decisions and their rationale rather than verbatim minutes. This keeps individuals, third parties and unfinished deliberations out of the public record while keeping the association’s choices fully accountable.

• 21 July 2026
  Certification & Commercial Roadmap
  Set the staged path to third-party certification, endorsed a professional credentialing programme for auditors and practitioners, and confirmed commercial activity stays firewalled from standard-setting.
• 21 August 2026, revised 8 and 9 September
  Membership fee tiers
  Set Support Membership fees across the individual, organisation, trust & safety expert and for-profit tiers.
• 7 September 2026
  Statutes v1.4 adopted
  Adopted board expansion, independent directors, conflict-of-interest and signing-authority safeguards, and the domicile move to Copenhagen.
• 15 September 2026
  Statutes v1.6 and Governance Charter v2.3 adopted
  An extraordinary general assembly adopted Articles of Association v1.6, replacing v1.4: a single membership class (Support Membership) with five eligible categories and the express exclusion of platforms subject to assessment and their affiliates; board appointment by the sitting board subject to general assembly ratification; board size of three to seven; a definition of director independence with a minimum of two independent directors; the founder as chair until an independent chair is elected, targeted by 31 December 2028; an interim managing-director appointment ending no later than 31 December 2029; a general assembly quorum; and a founder right to require the board to convene the dissolution process in defined mission-integrity circumstances. Version 1.5 was proposed on 8 and 9 September and was superseded by v1.6 without separate adoption. The board then adopted Governance Charter v2.3 with its appendices, including the Governance Implementation Schedule, and Policies 1 to 14.
• 19 October 2026
  Statutes v1.7 and Governance Charter v2.4 adopted
  A reconvened extraordinary general assembly, the assembly of 11 October 2026 not having been quorate, adopted Articles of Association v1.7 with the founder’s consent: two classes of membership, with Support Membership as the voting class and a new passive class of Alliance Members for parents and others caring for a child, wherever they live, in the Parents’ Alliance; notice, votes and the right to call an extraordinary assembly held by Support Members entitled to vote; and online meetings, electronic voting and written proxies, with no more than two proxies per person. The board then adopted Governance Charter v2.4, adding the Alliance Member definition and the rules on how Alliance Members talk to each other, and resolved that Alliance Members are admitted on payment of the alliance fee. The minutes record that the association is in its founding period, with one seated director: decisions made in this period take effect when signed, and once the board is fully constituted, further decisions, and any change to what was decided in this period, are made by vote under the articles and the charter.

Finances

As a Danish non-profit, Custorian keeps and publishes annual accounts. Funding is capped so that no single source exceeds about 30% of income, with any exception recorded by the board and published. Accounts will be posted here for each financial year.

• Annual accounts (Årsregnskab), 2026
  First financial year. Published after approval at the general assembly.
• Annual activity report, 2026
  Required by the CERV programme; published alongside the annual accounts.

Funders are published here under the Conflict of Interest Policy. Currently: founder contributions and individual donations; no institutional funders.

Publications & press

Standards, guidance and public statements issued by Custorian.

• 7 July 2026 · Tech Policy Press
  Europe Can Protect Children Online Without Surveillance or Age Bans
• 2026
  The Custorian White Paper