Image-Based Sexual Abuse: A Global Legal Guide for Survivors

A groundbreaking 2025 study published at CHI (the premier academic conference on human-computer interaction) surveyed individuals across 10 countries and found that 22.6% of respondents had experienced some form of image-based sexual abuse (IBSA) — the non-consensual creation, distribution, or threat to distribute intimate images. That's nearly one in four people.

The scale of IBSA is staggering. The UK's Revenge Porn Helpline reported record numbers of cases in 2024, with a growing proportion involving AI-generated deepfake content. In the United States, the TAKE IT DOWN Act signed in 2025 provided the first federal criminal framework. In Australia, the eSafety Commissioner has emerged as a global model for regulatory response.

If you're reading this because you or someone you know is experiencing IBSA, know this: you are not alone, the law is increasingly on your side, and there are concrete steps you can take right now. This guide covers the legal landscape across major jurisdictions and provides actionable guidance for survivors.

United States: Federal and State Protections

The TAKE IT DOWN Act (signed May 2025) makes it a federal crime to publish non-consensual intimate images, including AI-generated deepfakes. Platforms must remove content within 48 hours of a valid request. Penalties include up to 2 years in federal prison.

Beyond the federal law, 48+ states have their own NCII (non-consensual intimate imagery) statutes. Many of these state laws preceded the federal act and provide additional civil remedies, including the ability to sue for damages. State laws vary significantly — some provide only criminal penalties, others include civil causes of action, and some explicitly cover AI-generated content while others don't.

For US-based survivors: file a removal request with the hosting platform citing the TAKE IT DOWN Act. File a report with local law enforcement. Consider contacting the Cyber Civil Rights Initiative's crisis helpline (1-844-878-2274) for support and guidance. If the perpetrator is known, consult with an attorney about both criminal prosecution and civil litigation for damages.

United Kingdom: The Online Safety Act Framework

The UK has been at the forefront of IBSA legislation. The Criminal Justice and Courts Act 2015 first criminalized revenge porn with penalties of up to 2 years imprisonment. The Online Safety Act 2023 significantly expanded protections, creating new offenses for 'cyberflashing' (sending unsolicited intimate images) and sharing or threatening to share intimate images without consent.

The Online Safety Act also places new obligations on platforms to proactively prevent IBSA content from appearing and to remove it quickly when it does. Ofcom, the UK's communications regulator, is responsible for enforcement and has the power to impose substantial fines on non-compliant platforms.

The Revenge Porn Helpline (revengepornhelpline.org.uk) provides free, confidential support to UK-based victims and can assist with content removal across platforms. The helpline has relationships with major tech companies and can often expedite removal requests.

European Union: GDPR and the Digital Services Act

IBSA survivors in the EU benefit from the GDPR's Right to Erasure (Article 17) — intimate images published without consent are clearly personal data processed unlawfully, giving survivors a strong legal basis for deletion requests. GDPR complaints can be filed with national Data Protection Authorities at no cost.

The Digital Services Act (DSA), which became fully applicable in 2024, imposes obligations on platforms to act quickly on illegal content reports, including IBSA. Very large online platforms (VLOPs) must assess and mitigate systemic risks related to gender-based violence, which includes IBSA. The DSA provides a faster takedown mechanism than GDPR alone.

Individual EU member states also have criminal laws addressing IBSA, with varying penalties. France, Germany, and Italy have particularly robust criminal frameworks. Survivors should check their country's specific criminal provisions in addition to invoking EU-level protections.

Australia: The eSafety Commissioner Model

Australia's approach to IBSA is widely regarded as the most effective regulatory model globally. The eSafety Commissioner has statutory powers to investigate IBSA complaints, order platforms to remove content, and impose civil penalties for non-compliance. The Commissioner can also issue removal notices directly to end-users who have posted IBSA content.

The Online Safety Act 2021 (Australia) established a formal complaints process: survivors submit complaints to the eSafety Commissioner, who assesses them and can issue removal notices within 24 hours. Platforms that fail to comply with removal notices face penalties of up to AUD $555,000 per day.

Australia's civil penalty scheme for IBSA is among the most aggressive in the world. Individuals who post IBSA content can face civil penalties of up to AUD $111,000. The combination of rapid removal mechanisms, significant penalties, and a dedicated regulatory body makes Australia's system a model that other countries are studying.

Universal Steps for Survivors

Regardless of your jurisdiction, certain steps are universally applicable. First, preserve evidence: screenshot the content, the URL, the poster's profile, timestamps, and any accompanying messages. Do not delete any communications with the perpetrator — these are evidence.

Report the content to the hosting platform using their dedicated NCII/IBSA reporting mechanism (most major platforms now have these). Simultaneously, report to any applicable government agencies or regulatory bodies. Seek emotional support from organizations specializing in IBSA — this is traumatic, and professional support matters.

You did not cause this. The responsibility lies entirely with the person who created or shared the content without consent. The legal systems of most developed countries increasingly recognize this, and the tools for holding perpetrators accountable are stronger than they have ever been. No survivor should have to navigate this alone.