The Government’s Violence Against Women and Girls (VAWG) Strategy has set out a clear ambition to prevent abuse and harness technology to reduce harm. SWGfL welcomes this recognition of the scale and seriousness of violence against women and girls, particularly the acknowledgement that online harms, including intimate image abuse and the misuse of emerging technologies, are a growing and urgent threat.
However, a closer reading of the Strategy raises significant concerns about both balance and delivery. While children and early intervention are described in detail and supported by concrete mechanisms, adult women are far less visible in the operational detail. Analysis of the Strategy and Action Plan shows this is not anecdotal: children are referenced up to 10 times more often than adults, and nearly 40% of all gender-related references in the Action Plan relate to children, despite the policy being framed as Violence Against Women and Girls. This imbalance is especially evident in the Government’s approach to online harms and intimate image abuse, where protections for adult women remain unclear and incomplete.
Ban on Nudification Tools
SWGfL strongly supports the stated ambition to prevent the creation and spread of intimate images involving children and to ban nudification tools. This reflects the reality seen daily across frontline services: intimate image abuse is happening at an unprecedented scale, facilitated by increasingly accessible technologies. However, the focus of these measures is overwhelmingly on children, with far less clarity about how adult victims will be protected from the same harms.
From our work on the Revenge Porn Helpline, we know that intimate image abuse is affecting adults right now at an unprecedented scale. Every delay in implementing meaningful, enforceable solutions leaves victims exposed to abuse that can escalate rapidly into coercion, extortion, harassment and long-term trauma.
The rejection of proposals from Baroness Owen, such as the NCII Register and the Global Clearing Centre for intimate image abuse further underscores this gap. As highlighted through Owen’s amendments to the Crime and Policing Bill, these mechanisms could provide faster, more effective takedowns of harmful content for all victims. Without them, adult women remain reliant on fragmented, voluntary processes that often fail to deliver timely protection or accountability.
Enforcement and Delivery
As with the broader Strategy, the effectiveness of the Government’s approach to online harms will depend not on announcements, but on detail and enforcement. Key questions remain unanswered: how widely will bans on nudification tools apply; whether open-source tools, overseas providers and rapidly evolving AI models will be covered; and how enforcement will keep pace with technological change. Experience shows that abusers adapt quickly. Measures that are narrowly defined or weakly enforced risk displacing harm rather than stopping it.
Technology companies have an important role to play, but voluntary action alone will not be sufficient. Safety measures are most effective when they are mandatory, consistently applied and subject to independent scrutiny. On-device protections, detection tools and platform safeguards must be designed with victims in mind and implemented at scale, rather than offered as optional or partial solutions.
Less Reference to Adults
Throughout the strategy, children are referenced far more frequently than adults, a pattern confirmed by analysis showing mentions of “children” outnumber “adults” by a ratio of 7:1 in the Action Plan and 10:1 in the Strategy. While this emphasis on child protection is understandable and important, it highlights the absence of equivalent clarity for adult women’s support pathways. This is not simply a matter of language, but of policy focus. Adult women, are often referred to collectively as “women and girls”, “victims” or “survivors”, without the same level of clarity about where support will be delivered, how harm will be addressed, or how justice will be accessed.
This imbalance becomes more pronounced in the Action Plan, where many commitments are anchored in education and children’s services. Prevention is framed primarily as early prevention, rooted in childhood and adolescence. While this approach is vital, it risks overshadowing the immediate and ongoing needs of adult women facing domestic abuse, sexual violence, coercive control and intimate image abuse. A strategy that speaks frequently and concretely about children, but more abstractly about adult women, risks sending an unintended message about whose needs are more urgent.
Ready for Contribution
SWGfL supports the Government’s recognition that technology should be used to protect, not harm. To realise this ambition and deliver meaningful, lasting change for women and girls, the Strategy must better align its prevention agenda with more robust protections for adult women. Child-focused prevention is vital and rightly receives strong emphasis in the Strategy.
Our concern is not with these measures, but with the absence of equivalent clarity and urgency for adult victims, who remain largely absent from operational detail. Without defined timelines, mandated processes for NCII removal, and enforcement mechanisms resilient to loopholes, adult victims will continue to face escalating harms. Our analysis shows this gap is systemic, and SWGfL stands ready to help close it.
David Wright CBE, CEO of SWGfL, has said:“SWGfL stands ready to contribute our expertise to ensure this vision is strengthened and delivered as the public would expect and quite rightly deserve. This is an ambitious and necessary step, but ambition must be matched with delivery and acknowledgement of where the gaps are. The safety of women and girls depends on it.”
