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TAKE IT DOWN Act: what it means for adult sites

Since 19 May 2026, covered platforms in the US must let people ask for removal of intimate images published without their consent, and act within 48 hours of a valid request. The FTC enforces it. Here’s who it covers, what a removal process needs, and how to see whether people can actually reach yours.

Summary of the official sources · checked 14 October 2026 · Not legal advice. · Sources at the end

Applies from19 May 2026

WhoPlatforms with user uploads, or that host intimate images of others

RuleTAKE IT DOWN Act · FTC

Effort to fixAbout 1 hour for the form and notice

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In short

A removal process for people shown in intimate images without their consent.
A clear and conspicuous notice that explains the process in plain language.
Removal within 48 hours of a valid request, plus reasonable efforts to remove known identical copies.
The Act’s definition of a covered platform leaves out sites that mainly publish their own preselected content (TAKE IT DOWN Act § 4(3), note to 47 U.S.C. § 223a). Edge cases are worth checking with your lawyer. Most user-upload sites are not.

Does this apply to your site?

The Act talks about “covered platforms”. These questions help you see whether that’s you.

✓
Users can upload images or videosTube, cam, fan and other user-generated content platforms that are open to the public.
✓
You regularly publish or host intimate images of other peopleThis can apply even without user uploads.
?
You only publish your own studio contentThe Act’s definition of a covered platform (§ 4(3)) leaves out sites that mainly publish their own preselected content; a lawyer can confirm whether that’s you.
?
Your company is outside the USThe Act is about platforms serving the US public. If people in the US use your site, plan for it.

What regulators expect

Publish a removal request form that takes a signature (a typed name is fine), the URL or other details to find the image, a short good-faith statement that it was published without consent, and contact details.
Link it clearly from the footer and the age-check page, with a short notice that explains your responsibilities and how to submit a request.
Keep the form outside the gate so that people who aren’t members, and haven’t passed your age check, can still reach it.
Remove within 48 hours of a valid request, and look for known identical copies on your site.
Keep a simple log of when each request arrived and when you acted. It helps your team and any later questions.

The Act doesn’t prescribe a specific form layout. What matters is that the four elements can be submitted and that the notice is easy to find.

What a good removal process looks like

Your name (signature)URL of the content

Report form, no login

Name as signature, the URL, a good-faith statement and an email. Nothing else needed.

Report content · Removal requestWe act within 48 hours

Clear link in the footer

Plain words, reachable before the age check.

Request received · reviewed within 48 h

Confirmation with the deadline

The requester sees what happens next and when.

How No451 checks your site

We look for a way to request removal on your homepage, footer, age-check page and contact pages, check which fields the form asks for, whether the 48 hours are stated, and whether the page is reachable without passing the age check. We only see what your public pages show, never how fast you actually remove content.

Fix firstMedia files open without the age check (from a related check) Example result

We don’t have a stored real result for removal requests yet, so here is a real one from our age-check checks. We asked for the headers of 10 media files linked from a home page, without passing the age check. All 10 answered “200 OK” to an anonymous visitor.

The fix: serve media only to visitors with a valid, signed proof. Report-page findings will look the same: what we saw, the evidence, the fix.

Report pageCan anyone request removal without logging in?

Request fieldsSignature, URL, statement, contact

48-hour noticeDoes the page say what happens and when?

Reachable before the gateIs the report page behind the age check?

Clear linkFooter or homepage link that explains the process

Common mistakes

Report page behind the age check or a login. The person in the image may not be a member of your site, and shouldn’t have to become one.
A general contact form. It doesn’t ask for the URL, the statement or a signature, so requests arrive incomplete and take longer.
No time stated. Say on the page that valid requests are handled within 48 hours, and plan your team around it, weekends included.
Removing the one URL only. The Act also asks for reasonable efforts to remove known identical copies.
An email address only, with no guidance. People don’t know what to include. A short form with the four elements works better for both sides.

Enforcement

The FTC enforces the platform duties since 19 May 2026. A failure to comply is treated as a violation of an FTC rule. People can report platforms that don’t comply at TakeItDown.ftc.gov.

Questions operators ask

Is my site a “covered platform”?

If it is public and mainly hosts user-generated content, or regularly publishes or hosts intimate images of other people, it probably is. The Act’s definition of a covered platform leaves out sites that mainly publish their own preselected content (TAKE IT DOWN Act § 4(3), note to 47 U.S.C. § 223a). Edge cases are worth checking with your lawyer. For edge cases, the official sources don’t settle this yet.

What does the Act say a removal request must contain?

A physical or electronic signature, enough information to find the image, a short good-faith statement that it was published without consent, and contact details.

When do the 48 hours start?

The Act counts from a valid request. Make it easy for requests to be complete, so the clock and your process line up.

Can I use the same form for the EU Digital Services Act?

Often yes. A “type of report” selector lets one form handle TAKE IT DOWN removal requests and DSA reports of illegal content. Check that each route asks for the fields it needs.

Can No451 check how fast I remove content?

No. We see whether a way to report exists and what it asks for. How quickly you act is something only you can show.

Sources

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: United States overview · Age checks in the US · DSA reporting duties (EU)

See whether people can reach your report page. Then make it easy.

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