This one is serious, so I'll keep the jokes short. On May 19, 2026, the Federal Trade Commission began enforcing the TAKE IT DOWN Act, the federal law on intimate images shared without consent. It launched TakeItDown.ftc.gov, where people can complain about platforms that ignore valid removal requests, or never set up a way to make one.
The week before, FTC Chairman Andrew Ferguson wrote to fifteen platforms, including Alphabet, Apple, Meta, Microsoft, Reddit, Snapchat, TikTok and X, reminding them to comply. His statement named the reason this belongs on a likeness blog: "In the age of AI, anyone can be targeted."
Why that date? The law, signed May 19, 2025, gave platforms "1 year after the date of enactment" to build a removal process. If you have a public face, you're a target. Here's what the law actually gives you.
Takeaway #1: The 48-hour clock
FROM THE RULE
"Upon receiving a valid removal request from an identifiable individual (or an authorized person acting on behalf of such individual) using the process described in paragraph (1)(A)(ii), a covered platform shall, as soon as possible, but not later than 48 hours after receiving such request— (A) remove the intimate visual depiction; and (B) make reasonable efforts to identify and remove any known identical copies of such depiction."
What it means for you. The law covers real images and AI fakes. Its criminal section defines a "digital forgery" as an intimate image of an identifiable person made "through the use of software, machine learning, artificial intelligence, or any other computer-generated or technological means" that a reasonable person would find "indistinguishable from an authentic visual depiction of the individual."
"Covered platform" means a public site or app that "primarily provides a forum for user-generated content," so most social and video platforms, plus sites built to host this content. Email and internet providers are excluded.
A platform that fails "to reasonably comply" is treated as violating an FTC rule on unfair or deceptive practices. That's what gives the 48 hours its teeth. And a platform that removes something in good faith gets protection from claims over the removal, "regardless of whether the intimate visual depiction is ultimately determined to be unlawful or not."
Your move. If you're talent or a rep, find each major platform's TAKE IT DOWN request page now and save the links. Every platform must post "a clear and conspicuous notice" of its process. Keep a dated copy of every request you send.
Takeaway #2: What a valid request has to say
FROM THE RULE
"a brief statement that the identifiable individual has a good faith belief that any intimate visual depiction identified under clause (ii) is not consensual"
What it means for you. The 48-hour clock only starts on a valid request. The law says it must be in writing and include four things: a "physical or electronic signature" of the person or someone authorized to act for them; enough information for the platform "to locate" the image; that good-faith statement; and contact information.
The devil is in the details. An agent or lawyer can file "on behalf of" the person. So the people who already handle your brand can handle this, fast, if they're set up for it.
The law also makes knowingly publishing these images a federal crime when its conditions are met, such as intended or actual harm. For adults, that's up to two years in prison; where a minor is depicted, up to three. Consent matters, and the statute is precise: agreeing to have a picture taken "shall not establish" consent to publish it.
The platforms that host this content now have a federal deadline instead of a vague promise to look into it.
Your move. Add a TAKE IT DOWN clause to your management or agency agreement: who files, how fast, and who keeps the record of when each request went in.
Sample wording (our illustration): "Manager is authorized to submit removal requests on Artist's behalf under the TAKE IT DOWN Act and shall do so within 24 hours of learning of a nonconsensual intimate depiction."
And always remember, don't sign it till you read it, my friends.
General information, not legal advice. Reading this doesn't create an attorney-client relationship. If you're dealing with a nonconsensual image, talk to a lawyer, and contact law enforcement if you're in danger.
