Ofcom faces judicial review over ‘failure to act’ on intimate image abuse

Ofcom has been warned it could face a judicial review over its alleged failure to act against platforms hosting non-consensual intimate images and child sexual abuse material on forums which group images by location.

Intimate images are posted of women and girls online which are arranged by area as specific as their town, village or university halls of residence, presenting serious risks to victims on top of the harms of image-based abuse.

The End Violence Against Women Coalition (EVAW) and Jane*, a survivor of intimate image abuse on these forums, are taking first steps in legal action against Ofcom, supported by law firm Leigh Day.

‘Failure to act’ on location-based intimate image abuse forums

Last year, Jane formally asked Ofcom to exercise its enforcement powers against platforms which hosted non-consensual explicit images of her and other women and children, urging the regulator to open a formal investigation into the platforms and to consider using its powers of investigation and enforcement.

Ofcom has previously said it is aware of Jane’s case and that it was “considering any appropriate next steps”, adding it has “a broad range of enforcement powers to hold tech firms accountable” and that it “won’t hesitate to use them where necessary”.

Leigh Day human rights solicitors Tessa Gregory and Claire Powell have now sent Ofcom a formal ‘Pre‑Action Protocol’ Letter on behalf of Jane and EVAW setting out their intention to seek a judicial review. This letter is the formal first step advising Ofcom of our intended legal action.

Together with Jane, EVAW is clear that Ofcom has failed and is failing to intervene against platforms hosting non‑consensual intimate images and child sexual abuse material and is contravening its own guidance on when it should act.

The letter warns that one of these forums hosts thousands of intimate images, including child sexual abuse material; advising that the images form part of a “collector culture” in which images are traded and collected, and that this fuels misogynistic abuse.

Jane’s case demonstrates Ofcom’s ongoing failings to act on these sites and shows that these are systemic issues impacting women and girls and their safety both online and offline.

Jane first raised these issues with Ofcom in February 2025 but has had no substantive response from Ofcom or information on what they are doing to tackle these sites. EVAW has engaged with Ofcom for many years, including during the drafting of the Online Safety Act 2023, and the duties and powers provided to Ofcom under the Act. Along with Jane, we are clear that Ofcom is not living up to its commitments to protect women and girls and that the failure in this case demonstrates that urgent, systemic action must be taken.

The letter draws on evidence provided to Ofcom by EVAW and other expert organisations in the VAWG sector, highlighting the consequences of failing to act against ‘collector culture’ sites, the importance of prompt and decisive enforcement action and the impact their silence has on the safety of women and girls.

EVAW successfully lobbied for the Online Safety Act to include women and girls, after the first draft of this law failed to mention women and girls a single time. We have a long history of engagement with Ofcom and advocating on the importance of better protections and swift action against these sites.

In failing to act to protect women and girls from intimate image abuse, Ofcom places a burden on individual women, as well as support services such the Revenge Porn Helpline and #NotYourPorn, which assist in the rapid removal of non-consensual content from the internet.

Jane and EVAW’s case against Ofcom’s is that:

1. By not acting, Ofcom is failing to comply with the intention of the Online Safety Act 2023, which is intended to protect women and girls.
2. Ofcom’s approach fails to follow its own policies, which prioritise taking action against sites such as these under its established regulatory framework.
3. Ofcom’s failure to act breaches Jane’s human rights, including her rights under Articles 3 (inhuman and degrading treatment), 8 (right to private and family life), and 14 (freedom from discrimination).
4. Ofcom has acted irrationally in deciding which sites to investigate, for example investigating X and Grok but not these sites, without a coherent justification.

Jane and EVAW are calling on Ofcom to confirm whether an investigation has been opened, to disclose its decision‑making documents, or to explain why no action has been taken. We believe that Ofcom has allowed “collector culture” image boards to operate with impunity, despite having the regulatory power to stop them.

Jane is also receiving assistance from legal firm Mishcon de Reya who have been corresponding with Google to demand that these sites are urgently delisted. So far Google has failed to remove many of the iterations of this site, despite them clearly violating Google’s own policies and terms of service.

Jane said:

“Responsibility for overseeing these sites and ensuring they comply with their legal duties under the Online Safety Act 2023 rests with Ofcom, yet their repeated inaction makes it feel like they are turning a blind eye to the abuse I have experienced.

“Like thousands of other women, I had my intimate images and personal information shared without my consent on a forum named after the place where I grew up. These platforms facilitate a particularly harmful form of degradation and humiliation, where women’s images are exchanged like trading cards – traded for sexual gratification, peer networking, and the social status derived from their abusive context.

“Despite repeated attempts to report and flag these harmful sites to Ofcom, these sites have continued to operate. The burden has fallen on me, someone directly affected by this abuse, to push for stronger regulation. I struggle to see how this reflects any meaningful commitment by Ofcom to tackling online harms against women and girls.”

Janaya Walker, Interim Director of the End Violence Against Women Coalition (EVAW), said:

“Image-based abuse is a violation of women and girls’ rights, and the existence of ‘collector culture’ is a particularly horrible example of misogyny and violence against women. Tech platforms have responsibilities to prevent this abuse, rather than enable it. And where they fail to do so, the burden should not rest on survivors like Jane to force the regulator’s hand. We are supporting Jane because we expect Ofcom to take proactive action against sites who cause this harm, and to ensure that all women and girls’ rights are upheld.”

Claire Powell, solicitor at Leigh Day, said:

“Collector culture sites are vile and misogynistic. They place women and girls at harm, both in the online and offline world. Despite its public commitments, our clients allege that Ofcom is failing to tackle these sites and failing in its obligations to protect women and girls like Jane who are left without the support and resources of the regulator. Ofcom and the UK government must live up to their promises to tackle violence against women and girls and must exercise their powers of enforcement without further delay. 

ENDS

Notes

• Jane is a pseudonym to protect the survivor’s identity

• We have not named the site in question to avoid diverting further traffic to the website and to minimise the risk of further dissemination.