The UK Government’s forthcoming Violence Against Women and Girls (VAWG) strategy presents an opportunity to address one of the fastest-growing and most devastating forms of abuse in the digital age - non-consensual intimate image (NCII) abuse.
We welcome the progress that has already been made. The Online Safety Act (OSA) marks an important shift in recognising NCII as a serious online harm. By making it a criminal offence to share, or threaten to share, intimate images without consent, the law has made it easier to bring prosecutions and hold perpetrators accountable. This is a necessary and overdue development.
But while the OSA represents progress, it does not go far enough to deliver the immediate protection that victims need. Under the current framework, much depends on the systems and processes of platforms — the law is focused on systemic responses, not individual cases. In practice, this means that if a platform refuses to act on a report, harmful content can remain online, compounding trauma for victims.
For those experiencing NCII abuse, every day that an image remains online is a day too long. The speed at which such content spreads means that traditional takedown requests, even when processed quickly, often fail to keep pace with the harm.
The missing piece: a verified NCII Register
We have long argued for the creation of a verified NCII Register, a mechanism that would enable the blocking, delisting, or disruption of identified NCII content across the internet. Such a register, backed by sufficient legal authority, would make it possible to require platforms, search engines, and other intermediaries to act immediately on verified reports, preventing further sharing and reducing the likelihood of re-upload.
This is not a speculative concept. Through StopNCII.org, we already operate a global, privacy-preserving system that empowers victims to create secure, digital fingerprints of their images, enabling platforms to prevent them from being uploaded again. It is a survivor-centred, technically proven approach that balances safety with privacy and due process.
An NCII Register would build on this foundation, embedding it in law so that its protections could not be ignored or inconsistently applied.
Aligning with the goals of the VAWG strategy
The VAWG strategy aims to prevent violence, protect victims, and pursue perpetrators. NCII sits squarely within this remit. It is a form of gendered abuse that disproportionately impacts women and girls, often as part of wider patterns of coercion, harassment, or exploitation. Its effects are profound and lasting, damaging mental health, relationships, careers, and safety.
Explicitly including NCII in the VAWG strategy would send a clear message: the government recognises the urgency of this harm and is prepared to match that recognition with action.
Moving from recognition to action
Our recent response to the Government’s decision not to adopt all recommendations from the Women and Equalities Committee’s report on intimate image abuse made clear our concern that the current legal framework will not achieve the level of impact victims deserve. While the OSA creates a stronger foundation for prosecutions, it does not make NCII content itself illegal to possess, host, or transmit.
Without that legal clarity, enforcement remains limited and victims are left without a guaranteed means of securing immediate removal of their images. An NCII Register would change that — providing regulators and law enforcement with the tools to act swiftly and decisively, and giving victims a clear pathway to reclaiming their privacy and dignity.
The opportunity in September
The upcoming VAWG strategy is the right place to make this commitment. NCII is not an isolated harm; it is part of a broader pattern of technology-facilitated gender-based violence. By embedding a commitment to a legislative framework for an NCII Register within the strategy, the government can take a decisive step towards eliminating this form of abuse.
We stand ready to support this ambition. StopNCII.org has already proven that the technical capability exists. The survivors we work with every day have made clear the human cost of delay. The VAWG strategy offers a chance to close the gap between legislative progress and real-world impact.
We urge policymakers to seize it.
