- It assumes that the server would not tamper its dataset (i,e., the list of CSAM). So it is OK to disclose the information if the client has enough matchings. But in reality, nothing prevents a malicious server adding arbitrary content to the list.
- It fails to consider the vulnerabilities of the perceptual hash. This includes false positives and adversarial collision attacks (https://arxiv.org/abs/2011.09473).
Another potential long term issue is that it is unclear how long Apple will store the safety vouchers. As a storage service, Apple may store them forever. The system is based on Elliptic-curve cryptography. Despite it is the current state-of-the-art encryption technique, it will be broken when the quantum computer becomes a reality in the future. So it is possible that every encrypted safety vouchers can be decrypted in the next 50 years.