On May 19, 2026, the Federal Trade Commission (FTC) announced that it will begin enforcing the Take It Down Act (TIDA) immediately. TIDA was made law in May 2025 and requires platforms to remove non-consensual intimate imagery within 48 hours of being notified. It provides criminal penalties for the publication of non-consensual intimate imagery and deepfakes, particularly of minors.

TIDA gave covered platforms until May 2026 “to give people a way to request the removal of intimate photos or videos shared online without their consent and to remove those intimate images, and known identical copies, within 48 hours of a valid request.”

The FTC has provided a clear message that it intends to enforce the law, by:

monitoring compliance, investigating violations, and holding platforms accountable when they fail to protect people—especially children—from this harmful abuse. To assist in investigations and enforcement actions, the agency launched TakeItDown.ftc.gov, where people can tell the FTC about platforms that fail to swiftly take down intimate photos and videos shared without their consent or platforms without a process for requesting removal of these images.

According to the FTC, “Know this: Platforms violating the law may face FTC law enforcement action, including potential civil penalties of $53,088 per violation.” This is a very clear message that enforcement of the TIDA is an FTC top priority.

The FTC has provided guidance for businesses that are subject to TIDA to assist with compliance.

In addition to the TakeItDown.ftc.gov website, the FTC has also published guidance to help consumers who are victims of nonconsensual intimate images posted online, and how consumers can report a platform that does not take down a nonconsensual intimate image within 48 hours of the request. The FTC is urging victims to report incidents, as well as to report “the perpetrator to local criminal law enforcement, as well as the FBI.”

If you are a victim of the posting of nonconsensual intimate images (or a deepfake), take control: request the platform take the images down, report it to law enforcement, the Federal Bureau of Investigation, and the FTC.

Photo of Linn Foster Freedman Linn Foster Freedman

Linn Freedman practices in data privacy and security law, cybersecurity, and complex litigation. She is a member of the Business Litigation Group and the Financial Services Cyber-Compliance Team, and chairs the firm’s Data Privacy and Security and Artificial Intelligence Teams. Linn focuses her…

Linn Freedman practices in data privacy and security law, cybersecurity, and complex litigation. She is a member of the Business Litigation Group and the Financial Services Cyber-Compliance Team, and chairs the firm’s Data Privacy and Security and Artificial Intelligence Teams. Linn focuses her practice on compliance with all state and federal privacy and security laws and regulations. She counsels a range of public and private clients from industries such as construction, education, health care, insurance, manufacturing, real estate, utilities and critical infrastructure, marine and charitable organizations, on state and federal data privacy and security investigations, as well as emergency data breach response and mitigation. Linn is an Adjunct Professor of the Practice of Cybersecurity at Brown University and an Adjunct Professor of Law at Roger Williams University School of Law.  Prior to joining the firm, Linn served as assistant attorney general and deputy chief of the Civil Division of the Attorney General’s Office for the State of Rhode Island. She earned her J.D. from Loyola University School of Law and her B.A., with honors, in American Studies from Newcomb College of Tulane University. She is admitted to practice law in Massachusetts and Rhode Island. Read her full rc.com bio here.