Enforcement programme into measures being taken by services to prevent users from encountering or sharing non-consensual intimate imagery (NCII)

Background

Part 3 of the Act imposes duties on providers of regulated user-to-user services to use proportionate:

1. measures to prevent individuals from encountering priority illegal content – including NCII – by means of the service;
2. measures to effectively mitigate and manage the risk of the service being used for priority offences or harm to individuals arising on the service as identified in the most recent ‘Illegal Content Risk Assessment’; and
3. systems and processes designed to minimise the length of time for which any priority illegal content is present and swiftly take it down when they are made aware of its presence.

Protecting women and girls from online harms is a key strategic priority for Ofcom.  In November 2025, Ofcom published guidance aimed at online services to help make their platforms safer for women and girls’.  In May 2026, we stated in Ofcom’s online safety priorities  that we would build on enforcement action we are already taking in this area and take action against services that fail to ensure proactive protections are in place to identify and swiftly remove NCII. To achieve this, Ofcom also issued a statement in May 2026 in which we announced new measures in our Illegal Content Codes of Practice. These measures recommend that those service providers that fall within scope use hash matching technology to detect NCII, for the purpose of then making an illegal content judgement. They come into force on 30 September 2026.

Services in the adult and instant messaging sectors are at a particularly high risk of being used for the upload and dissemination of NCII and, so they will be the focus of this enforcement programme. We have already written to some of these relevant services to outline the measures and remind them of their duties to comply when the duties come in.

Enforcement Programme

Today, 9 September 2026, Ofcom is opening an enforcement programme to assess the measures being taken by services that present particular risks of harm to UK users to meet their Illegal Content Duties in respect of NCII. The programme will focus on services’ implementation of new hash matching measures recommended in the Codes of Practice, or any alternative measures implemented to comply with their duties.

As part of the Programme, we will:

• identify services that present particular risks of harm to UK users through the presence or dissemination of NCII;
• assess the measures being taken by providers of such services to comply with the Illegal Content Duties in respect of NCII; and

• where potential non-compliance is identified, determine whether formal enforcement action may be appropriate.

• drive compliance with these measures across the sector, by using a mix of supervision engagement, wider industry communications and formal enforcement investigations.

The new measures in the Illegal Content Codes of Practice will come into force on 30 September 2026, and we expect services in scope of the measures to have brought themselves into compliance by this date, or to be taking steps to come into compliance shortly thereafter.

Services who are not compliant, or are not taking steps to come into compliance, may be subject to formal enforcement action.

We will provide further updates in due course.