Chat Control will probably not be implemented at the OS level. It targets the app developers and platforms. So even graphene will not help you, if you use apps that bake in scanning.
However it can still help you installing OSS without scanning and will sandbox scanners into their own apps
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Things are getting more and more complicated...
I know no details of how they want to implement something like this, but it would be easier to target OS than apps, imo.
Targeting Android and iOS you can achieve 99% of mobile users.
OS builders are few and bigger than app builders, so they are an easier target for institutions.
Because how can you target every app to comply?
As I said, dunno their intentions, but this is a recipe for disaster.
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By the way, I hope you are right:
It's easier to change the messaging app than to change the OS.
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Off course it will be implemented in the OS level, iMessage and Airdrop and all native iOS apps and Android apps and services are affected