Source · Select Committees · Women and Equalities Committee
4th Report – Tackling non-consensual intimate image abuse
Women and Equalities Committee
HC 336
Published 5 March 2025
Recommendations
2
Rejected
Criminal Injuries Compensation Scheme's offence list outdated, excludes online harms
Recommendation
The list of offences that are within scope of the Criminal Injuries Compensation Scheme is out of date. Crimes perpetrated online, such as non-consensual intimate image abuse, can be just as damaging to a person as those involving physical violence. …
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Government Response Summary
The government rejects the recommendation to expand the Criminal Injuries Compensation Scheme to include online offences like NCII, stating it would fundamentally alter the scheme's purpose and that its current scope is broad enough for some online exploitation cases involving violence.
Government Equalities Office
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3
Rejected
Amend Criminal Injuries Compensation Scheme eligibility to include online sexual offence claims
Recommendation
The Ministry of Justice must amend the eligibility criteria of the Criminal Injuries Compensation Scheme to bring claims from victims of sexual offences perpetrated online, specifically non-consensual intimate image abuse, within its scope. (Recommendation, Paragraph 26)
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Government Response Summary
The government rejects amending the Criminal Injuries Compensation Scheme eligibility criteria to include online sexual offences and non-consensual intimate image abuse. They state this would fundamentally alter the scheme's purpose, which is for crimes of violence, and believe the current scope is broad enough for cases escalating to violence.
Government Equalities Office
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5
Accepted
Ofcom's powers insufficient for timely removal of individual NCII abuse content
Recommendation
Ofcom’s current enforcement powers, while welcome, are far too slow and not designed to help individual victims get abusive images of themselves on non-compliant websites taken down or have access to them restricted. The duties under the regulatory regime created …
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Government Response Summary
The government offers partial acceptance, stating the Online Safety Act 2023 provides new duties and strong enforcement powers for Ofcom to tackle NCII abuse on online platforms and search services, which it believes will make a real difference.
Government Equalities Office
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6
Rejected
Justification to legally align NCII with CSAM to prompt provider action
Recommendation
For internet infrastructure providers to take the threat of NCII seriously and block access to websites that refuse to take it down, we believe that there is justification in bringing NCII in line with CSAM in law. (Conclusion, Paragraph 56)
Government Response Summary
The government rejects the recommendation to align NCII with CSAM in law, stating it does not believe criminalising possession would be effective due to practical difficulties and existing powers for image removal.
Government Equalities Office
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7
Rejected
Amend the Crime and Policing Bill to make possession of non-consensual intimate images an offence.
Recommendation
The Government should bring forward an amendment to the Crime and Policing Bill to make possession of NCII an offence, in addition to its creation. This will put NCII on the same footing as CSAM in how it is treated …
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Government Response Summary
The government rejects the recommendation to amend the Crime and Policing Bill to make NCII possession an offence, stating that many functions are already covered by the Online Safety Act or existing civil routes, but will consider it further in the upcoming VAWG Strategy.
Government Equalities Office
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8
Accepted in Part
Create guidance for internet providers and web browsers on tackling non-consensual intimate image abuse.
Recommendation
The Government should create guidance for internet infrastructure providers and web browser manufacturers on tackling online non-consensual intimate image abuse, similar to that which already exists for online child sexual exploitation and abuse. This guidance should direct both groups to …
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Government Response Summary
The government partially accepts the recommendation, stating it will explore the feasibility of producing specific guidance for internet infrastructure providers and web browser manufacturers, and notes existing measures under the Online Safety Act and Data (Use and Access) Bill to tackle NCII.
Government Equalities Office
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9
Deferred
Direct user-to-user and search engine services to utilise a registry of non-consensual intimate image content.
Recommendation
In its illegal content Codes of Practice, Ofcom should direct user-to-user and search engine services to make use of a registry of NCII content, compiled by an expert body, on a similar basis to the provisions that exist for child …
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Government Response Summary
The government rejects the recommendation on Ofcom's behalf, stating it cannot direct an independent regulator. However, it notes that Ofcom, under the Online Safety Act, will launch a new consultation on further measures for illegal content duties, including automated content moderation and hash-matching for intimate image abuse.
Government Equalities Office
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10
Rejected
Expand the Data Bill's solicitation clause to criminalise all image-based abuse offences.
Recommendation
The law on solicitation was unclear, incomplete and open to misinterpretation by law enforcement agencies and others. We welcome the Government’s proposals to introduce a specific offence of solicitation for synthetic content via an amendment to the Data (Use and …
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Government Response Summary
The government rejects expanding the solicitation offence to all image-based abuse, stating that the Serious Crime Act 2007 already covers encouraging or assisting offences in England or Wales. The new Data Bill offence specifically targets requests for synthetic content to creators abroad, where a legal gap was identified, and the government has not seen evidence to justify a broader expansion.
Government Equalities Office
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11
Rejected
Introduce a swift, inexpensive statutory civil process for non-consensual intimate image abuse.
Recommendation
The Government should take a holistic approach to legislating against NCII abuse by introducing a swift, inexpensive statutory civil process, as has been established in other jurisdictions such as British Columbia in Canada. Doing so would recognise survivors’ wishes to …
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Government Response Summary
The government rejects the recommendation for a new statutory civil process due to a lack of evidence on the effectiveness of the British Columbia model and because many functions are already covered by the Online Safety Act or existing civil routes. They consider the RPH and StopNCII to already serve as a dedicated registry for known NCII.
Government Equalities Office
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13
Rejected
Establish an Online Safety Commission to support individuals and oversee non-consensual intimate image content registry.
Recommendation
The Government should set up an Online Safety Commission, similar to the eSafety Commission in Australia, with a focus on support for individuals. The new Commission would act as a trusted flagger of NCII content on behalf of individuals that …
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Government Response Summary
The government rejects the recommendation to establish an Online Safety Commission, arguing that the existing Online Safety Act provides strong user redress mechanisms. It states Ofcom's codes of practice already require service providers to enable reporting and complaints for illegal content, and that trusted flaggers can play a valuable role.
Government Equalities Office
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14
Rejected
Discuss Online Safety Commission proposals with Revenge Porn Helpline for potential collaboration or expanded role.
Recommendation
The UK already has an excellent organisation doing some of this work in the form of the Revenge Porn Helpline. The Government should discuss the proposals set out above with the RPH to determine what relationship the RPH could have …
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Government Response Summary
The government rejects the recommendation, stating that the Online Safety Act provides strong user redress mechanisms, including reporting illegal content and complaints, which Ofcom further details in its codes of practice. It suggests existing support organisations could be designated as trusted flaggers under Ofcom's framework.
Government Equalities Office
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15
Rejected
Explore funding options for the Online Safety Commission, including a levy on relevant bodies.
Recommendation
The Government should explore whether the funding for such a Commission could be generated, at least in part, by a levy on bodies within scope of the OSA on a similar basis to that which exists in other regulated environments. …
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Government Response Summary
The government rejects the recommendation, stating that the Online Safety Act already contains strong provisions for user redress and reporting illegal content, with Ofcom providing guidance and iteratively developing codes of practice. It highlights the role of trusted flaggers and existing support services.
Government Equalities Office
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17
Rejected
Extend legal definition of intimate image to include religious or cultural attire removal.
Recommendation
The Government should extend the legal definition of an intimate image to include images where “because of the person’s religious or cultural background, the person commonly wears particular attire of religious or cultural significance when in public; and the material …
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Government Response Summary
The government rejects the recommendation, citing the Law Commission's conclusion that criminalising such behaviour would cause too much uncertainty for law enforcement and the public, potentially leading to charges without malicious intent. It states that other offences may apply depending on the circumstances.
Government Equalities Office
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18
Accepted in Part
Introduce statutory time limit extension for intimate image abuse, starting from victim awareness.
Recommendation
The Government should introduce an extension to the statutory time limits that apply to current and forthcoming intimate image abuse offences, such that the time limit begins only once the victim(s) is/are aware of the abuse. (Recommendation, Paragraph 93)
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Government Response Summary
The government partially accepts, stating it is extending the statutory time limit for the new 'creating' and 'requesting the creation of' intimate image offences in the Data (Use and Access) Bill. It is considering the issue very carefully for other intimate image abuse offences.
Government Equalities Office
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19
Accepted in Part
Police treatment of intimate image abuse victims demonstrates lack of understanding and misogyny.
Recommendation
Every victim of a sexual offence deserves to be treated with respect and have their case investigated promptly and effectively by the police. However, in many cases police treatment of victims of intimate image abuse has been characterised by a …
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Government Response Summary
The government partially accepts, outlining new College of Policing guidance on online image offending, existing core learning for officers, and over £13m funding for a new National Centre for VAWG and Public Protection. This Centre will develop and deliver improved training for police officers, including a focus on non-consensual intimate image abuse.
Government Equalities Office
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20
Accepted in Part
Produce joint guidance to improve police response and content takedown for intimate image abuse.
Recommendation
The College of Policing, Ofcom, and the Revenge Porn Helpline should work together to produce guidance to improve the police response to reports of non-consensual intimate image abuse. That guidance should include the steps police officers need to take to …
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Government Response Summary
The government partially accepts, noting the College of Policing has already issued new guidance on online image offending. They are providing £13m funding for a new National Centre for VAWG and Public Protection, which will develop and deliver improved training, engaging with the RPH to inform it.
Government Equalities Office
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22
Accepted in Part
Increase courts' use of deprivation orders to prevent perpetrators retaining intimate images.
Recommendation
The Sentencing Council must take steps to increase awareness of the ability of the courts to ensure that those charged with NCII offences forfeit all right to continued possession of that material, including both the physical removal of devices on …
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Government Response Summary
The government partially accepts, committing to continue reviewing data on deprivation orders in NCII cases, which it already collects. However, it cannot comment on the recommendations for the independent CPS and Sentencing Council, though it notes their updated guidance and ongoing review.
Government Equalities Office
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23
Accepted
Include non-consensual intimate image abuse in VAWG definition and identify prevalence data.
Recommendation
The Government should ensure that NCII abuse is included when creating a common definition of VAWG, as part of its mission to reduce it by 50% within the next decade. It should also identify what data can be used to …
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Government Response Summary
The government accepts the recommendation, confirming that non-consensual intimate image abuse is included in its definition of VAWG and will be part of the new cross-Government Strategy. It is also working with the ONS to improve the Crime Survey for England and Wales to include data on intimate image sharing.
Government Equalities Office
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25
Accepted in Part
Accept StopNCII.org hash matching technology as a matter of priority.
Recommendation
Google should accept the StopNCII.org hash matching technology as a matter of priority. (Recommendation, Paragraph 125)
Government Response Summary
The government partially accepts, stating Google is able to consider adopting StopNCII.org hash-matching technology and the government would support its use. It notes that Ofcom, the online safety regulator, has powers to set out steps for search services and will consult on automated hash-matching tools for intimate image abuse.
Government Equalities Office
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26
Rejected
Ofcom's proposals should require companies to accept non-consensual intimate image hash matching.
Recommendation
It is clear that some companies require further persuasion to accept NCII hashes. We welcome Ofcom’s plans to launch a consultation in spring 2025 on expansions to its Codes of Practice that would include proposals on the use of hash …
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Government Response Summary
The government rejects the recommendation, stating it cannot accept it on behalf of Ofcom, which is an independent regulator for Online Safety Act duties. It notes Ofcom's draft guidance already recommends hash matching and other measures for preventing NCII.
Government Equalities Office
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27
Accepted in Part
Mandate consent-based offence for deepfake creation, including cultural intimate image abuse.
Recommendation
The Government’s plans to criminalise the creation of sexually explicit deepfakes/NCII, even if they are not shared, are very welcome and worthy of praise. However, the Government must ensure that the offence is consent- based and does not require the …
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Government Response Summary
The government has introduced a consent-based offence for non-consensual sexually explicit deepfakes without requiring a motivation element, with amendments tabled to the Data (Use and Access) Bill. However, they have not included culturally sensitive images in this offence.
Government Equalities Office
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28
Rejected
Require tech companies to cleanse datasets of NCII and source data responsibly.
Recommendation
The private sector has innovated to create AI technology. It does not need to wait for legislation to catch up in order to safeguard individuals from harmful AI-generated content. As a starting point tech companies involved in AI content creation …
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Government Response Summary
The government rejects the recommendation for tech companies to cleanse datasets and commit to responsible data sourcing, arguing that existing regulatory requirements under the Online Safety Act and data protection framework already apply. They state their approach is to regulate AI systems at the point of use through existing expert regulators, while continuing to engage with the tech sector on safety.
Government Equalities Office
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29
Accepted
Criminalise use of nudification apps as synthetic NCII and hold platforms accountable.
Recommendation
There is no legitimate reason whatsoever for the use or existence of nudification apps. The Government should ensure that the use of such an app is considered creation of synthetic NCII and therefore also a criminal offence and Ofcom should …
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Government Response Summary
The government states that creating or requesting non-consensual purported intimate images, including those from nudification apps, is a criminal offence as of January 2024, and the Online Safety Act regulates harmful deepfake content on in-scope services. They are actively considering further options to address these tools and will provide an an update.
Government Equalities Office
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Conclusions (5)
4
Conclusion
Acknowledged
We welcome the inclusion in the Crime and Policing Bill of the new offences of taking an intimate image without consent and of installing equipment for the purposes of enabling the commission of those offences. We also welcome the Government’s recognition that the definition of what constitutes an image for …
Government Response Summary
The Government will explore the feasibility of producing specific guidance for internet infrastructure providers and web browser manufacturers, and continues to identify areas where it can build on existing legislation and initiatives relating to online safety.
12
Conclusion
Rejected
There is a gap in the UK’s online regulatory framework for a statutory body to support and champion the rights of individuals affected by non- consensual intimate image abuse, and to work alongside the courts in the civil regime. Such a body is required to help ensure victims are able …
Government Response Summary
The government rejects the need for a new statutory body, stating that the Online Safety Act already contains strong provisions for user redress through mandated reporting and complaints systems for online services. They add that Ofcom has the scope to designate support organisations as 'trusted flaggers' to improve detection of illegal content, including NCII.
16
Conclusion
Deferred
Non-consensual intimate image abuse is not always limited to sexually explicit content. For example, in some cultures, countries, or religions, sharing a photograph of someone without their religious clothing—or with their arm around another person—can be disastrous for the victim. (Conclusion, Paragraph 85)
Government Response Summary
The government partially accepts the conclusion but largely deflects responsibility by stating that Ofcom, as the independent regulator, has powers under the Online Safety Act and will consult on further measures, including automated hash-matching tools.
21
Conclusion
Accepted in Part
Cases have been drawn to our attention where, at the end of the criminal justice process, perpetrators have had the devices containing the NCII content returned to them—even in cases where the perpetrator has been 55 served with a restraining order. It is needless for us to say how harrowing …
Government Response Summary
The government partially accepts the implied recommendation to address perpetrators retaining NCII content. It confirms the Ministry of Justice already collects and will continue to review data on deprivation orders in NCII cases, and notes the CPS has updated guidance to prosecutors and the Sentencing Council is reviewing its guidance on ancillary orders.
24
Conclusion
Deferred
Hash matching technology is a crucial tool in preventing non-consensual intimate image abuse. It is unacceptable that so few platforms receive NCII hashes, not least when they are already able to incorporate similar technologies for preventing the sharing of child sexual abuse material. It is obvious to us that accepting …
Government Response Summary
The government states that Google can consider adopting hash-matching technology if it wishes, and they would support it. Ofcom, as the independent regulator, will consult on additional measures for online platforms' safety duties, including automated hash-matching tools for intimate image abuse.