Privacy & Cybersecurity Law Blog

Technology companies should prepare for possible enforcement actions by the Federal Trade Commission (“FTC”) under the Take It Down Act (“TIDA”), which took effect on May 19, 2026.  

What is the Take It Down Act?

The TIDA—formally the Tools to Address Known Exploitation by Immobilizing Technology Deepfakes on Websites and Networks Act—was signed into law by President Trump on May 19, 2025. The law bans the nonconsensual online publication of intimate images of individuals, including AI-generated deepfakes, and requires covered platforms to remove such content promptly upon notification from a victim. Notably, the law extends protections to both adults and minors, addressing growing concerns about AI-enabled exploitation of victims of all ages.

Further, Section 3 of TIDA mandates that covered platforms establish a clear, conspicuous process through which victims can request removal of nonconsensual intimate images or videos and grants enforcement power to the FTC. Once a platform receives a valid request, it must take down the content and any known duplicates within 48 hours.

For more information on the TIDA, see here.

Enforcement Stakes

The penalties for non-compliance are significant. A violation of the TIDA is treated as a violation of an FTC rule, exposing platforms to civil penalties of up to $53,088 per violation. For platforms that host and maintain millions of pieces of user-generated content, per-violation fines can accumulate quickly.

Because the law’s definition of “covered platform” broadly includes social media, messaging apps, image-sharing services, gaming platforms, and any site that primarily provides a forum for user-generated content, platforms across the spectrum should be aware of applicable obligations.