A Critical Assessment of Pall Mall Code to Regulate Spyware

The University of Minnesota Law School’s Human Rights Center and European Digital Rights (EDRi) jointly hosted a hybrid presentation and discussion of a new policy paper, A Legal and Political Assessment of the Pall Mall Process in Brussels.

The policy paper provides a critical assessment of the British-French-led Pall Mall Process, particularly the 2025 voluntary Code of Practice for States, endorsed by multiple European governments. It is the first systematic analysis of the code’s shortcomings and the broader limitations of “soft law” approaches to regulating spyware technologies.

The assessment shows that policy progress on reining in commercial spyware is largely incremental. It fails to address the core human‑rights risks and accountability gaps connected to the use of spyware that have long been documented by SAI grantees. In the Code of Practice, states resort to decorative language and generic references to international law while remaining silent on concrete accountability mechanisms for spyware use. Without a fundamental shift in state policy real accountability efforts and adequate rights protections will remain marginal.

Read the full assessment here.