TAKE IT DOWN Act compliance checklist for forums and communities

1. Check whether your site is covered

The Act applies to "covered platforms": public websites, apps and online services that primarily provide a forum for user-generated content, such as posts, messages, images, videos or games, or that regularly host intimate images shared without consent.

• Usually covered: forums, community sites, social apps, image and video hosts, dating apps, gaming communities, creator platforms.
• Excluded: broadband providers, email services, and services that mainly show content the provider picked itself, where user interaction is only incidental.
• No size exemption. The FTC says it will act against platforms of all sizes, not only big ones.

2. Publish a clear, plain-language notice

The FTC expects a clear and conspicuous explanation of how to ask you to remove intimate images.

• ☐ Link it from your homepage or site footer, and wherever intimate content could appear.
• ☐ Write it in plain language: what people can report, how, and what you will do.
• ☐ Let people report without an account. Victims often are not members of your site.
• ☐ Ideally, add a report option directly on posts, images and videos.

Need wording? Use our free takedown policy template.

3. Collect the four elements of a valid request

Your request form should capture everything the Act lists for a valid request:

1. A physical or electronic signature of the person shown, or someone authorized to act for them.
2. Identification of the content and enough information to find it, such as links.
3. A brief good-faith statement that it was published without consent.
4. Contact information for the requester.

Give every request a reference number. The FTC recommends it, and it makes follow-ups and records much easier.

4. Remove within 48 hours, including copies

• ☐ Make sure someone is alerted immediately, including weekends. The clock does not pause.
• ☐ Remove the reported content within 48 hours of a valid request.
• ☐ Make reasonable efforts to find and remove known identical copies, without waiting for new reports.
• ☐ Tell the requester what you did, or why you did not remove it.

Our step-by-step 48-hour takedown process shows how to run this with a small team.

5. Stop the content coming back

The FTC suggests hashing: store a fingerprint of removed images so re-uploads can be caught automatically. You can also share hashes with StopNCII.org (adults) and NCMEC's Take It Down service (minors), so other platforms can block them too.

6. Handle reports involving minors separately

If a report may involve someone under 18, remove it fast, and remember that US providers have separate legal duties to report apparent child sexual abuse material to NCMEC's CyberTipline. Do not download or forward the content. Get legal advice.

7. Keep records

• ☐ When each request arrived and when you acted, with timestamps.
• ☐ What you decided, and what you told the requester.
• ☐ Who handled it.

If the FTC asks how you comply, these records are your evidence.

8. Know the protections and the penalties

• Safe harbor: platforms are protected from liability for removing content in good faith when it appears to be non-consensual, even if it later turns out not to be.
• Penalties: the FTC treats non-compliance as a violation of an FTC rule, with civil penalties of up to $53,088 per violation.

Frequently asked questions