The TAKE IT DOWN Act requires covered platforms to remove intimate images shared without consent within 48 hours of a valid request; according to the FTC (checked 19 October 2026), this applies from 19 May 2026. What the Act counts as valid, when the clock starts, and how a small team can keep up.
The TAKE IT DOWN Act has two parts. One makes it a crime to knowingly publish intimate images of a person without their consent, including AI-made ones. The other is about removal: according to the FTC, it applies to covered platforms from 19 May 2026, one year after the Act was signed on 19 May 2025 (47 U.S.C. § 223a(a)(1)(A)).
The Act says covered platforms must offer a process that lets people ask for removal of such images, explain that process in a clear and conspicuous notice in plain language, and remove the content within 48 hours of a valid request. The Act also says they must make reasonable efforts to remove known identical copies. The FTC enforces the platform duties.
The Act’s definition (§ 4(3)) covers a website, online service or app that serves the public and mainly provides a forum for user-generated content, or whose regular business is to publish or host nonconsensual intimate images. The FTC’s guidance names social media, messaging, image or video sharing and gaming platforms as examples.
The Act’s definition of a covered platform leaves out sites that mainly publish their own preselected content, where any chat or comment features are incidental to that content (TAKE IT DOWN Act § 4(3)(B)(iii), set out as a note to 47 U.S.C. § 223a). That exclusion doesn’t cover a site whose regular business is publishing nonconsensual intimate images. Edge cases are worth checking with your lawyer.
The Act lists four parts of a valid request (47 U.S.C. § 223a(a)(1)(B)). If your form asks for all four, people can send complete requests the first time, and you don’t lose hours writing back.
The Act counts the 48 hours from receiving a valid request. That is one more reason to ask for all four parts in the form: a complete request starts the clock and your process at the same moment.
The Act says 48 hours, not working days. If your team only reads email on weekdays, a request arriving on Friday evening reaches 48 hours on Sunday evening. Plan for that before it happens.
The person in the image may not be your member and may not even be an adult. The FTC’s guidance says the Act’s protections are not limited to account holders and suggests an easy way to report without an account. We suggest a report page that opens without an account and without passing your age check. Link it from the footer and from the age-check page, and keep it free of previews.
One form can collect both TAKE IT DOWN requests and reports under the EU Digital Services Act: add a “type of report” selector with “intimate image shared without consent” and “other illegal content”.
Do I have to check whether the request is true before removing? The Act asks the requester for a good-faith statement; it doesn’t describe a separate investigation step. The 48 hours run from the valid request, and § 223a(a)(4) limits a platform’s liability for good-faith removal. Disputes with the uploader can follow afterwards.
What if the URL is not on my site? Reply that the content is not hosted by you, and keep the reply in your log. If you can, point the person to the site that does host it, or to StopNCII.org.
What if the request is incomplete? Write back the same day and ask for the missing part. Your form should make that rare: make the four parts required fields.
Do AI-made images count? According to the FTC, the Act covers “digital forgeries”, images created or altered with software, an app or AI, as well as real photos and videos.
Does this apply to me if I am outside the US? The definition of a covered platform in § 4(3) doesn’t mention where a company is based. Whether it reaches your company is a question for your lawyer; if US visitors can upload to and view your site, we suggest setting up the process anyway.
The Act asks for a clear and conspicuous notice that explains your removal process (47 U.S.C. § 223a(a)(2)). Two short paragraphs are usually enough: what people can report, what information the form asks for, that you act within 48 hours and how they hear back. Put it at the top of the report page and link it in the footer.
We look for a report link on your homepage, footer and age-check page, read the form fields, check whether the 48 hours are stated and whether the page opens without the age check. We can’t see how fast you actually remove content; that part only you can show.
Not legal advice. This page summarises and links to primary sources; it does not tell you what the law requires of your specific site. Related: TAKE IT DOWN Act for adult sites · A report page that works · DSA for small adult platforms
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