Nigeria Model Seeks Six-Hour Deadline for Takedown of Non-Consensual Intimate Images
By Editor 
A national policy framework for tackling the non-consensual sharing of intimate images in Nigeria has proposed a six-hour deadline for technology companies to remove verified abusive content, alongside tougher legal sanctions, specialised cybercrime investigations and expanded support for victims.
The proposed measures are contained in the National Model of Response to Non-Consensual Sharing of Intimate Images, which calls for a coordinated national response to the unauthorised dissemination of intimate photographs and videos, including sexually explicit material generated or manipulated using artificial intelligence (AI).
The document recommends that Nigeria strengthen its legal framework to address the creation and distribution of intimate images without consent, clarify the responsibilities of digital platforms, and establish more accessible channels through which victims can report abuse and seek justice.
It also proposes that platforms face clearer accountability requirements, including proportionate sanctions for non-compliance, while government agencies, civil society organisations and the private sector develop coordinated mechanisms for preventing abuse and removing harmful content.
Under its recommendations for the technology industry, the model proposes a specific six-hour compliance timeframe for content removal, in line with the standards it seeks to draw from the United Nations Convention against Cybercrime.
It further recommends a memorandum of understanding between relevant government agencies, law enforcement bodies and internet service providers to establish an effective system for taking down abusive content.
The framework also proposes direct access for the Nigerian Communications Commission (NCC) to report non-consensual intimate images to internet service providers, as well as improved local-language moderation to make online platforms more responsive to reports from Nigerian users.
Beyond removing offending material, the document calls for stronger legislation to address the evolving nature of image-based abuse, particularly the use of AI to generate synthetic intimate images or manipulate existing photographs.
It recommends amending the Cybercrimes Act to strengthen the definition of the offence, clarify the criminal implications of creating AI-generated intimate material, and establish appropriate and proportionate punishments, including for repeat offenders.
The model also proposes amendments to the Violence Against Persons (Prohibition) Act and the Evidence Act to address technology-facilitated abuse and strengthen the authentication and integrity of electronic evidence.
It urges the National Assembly to consider a statutory right to identity protection in digital spaces, which would enable individuals, particularly public-facing professionals and content creators, to take legal action when their likeness is used without consent in intimate or sexualised contexts.
The document further recommends that Nigeria ratify the UN Convention against Cybercrime and use it to strengthen international cooperation among criminal justice institutions.
Victim support, legal assistance
The proposed response places considerable emphasis on the support available to victims, recommending the expansion of free, specialised helplines and victim-support services, as well as simpler online and offline reporting channels accessible to people with disabilities and speakers of Nigeria’s various languages.
It calls for increased government budgetary allocations for cybercrime and violence against women, with dedicated funding for services supporting victims of non-consensual intimate-image sharing.
The framework also proposes the establishment of a legal assistance fund specifically for victims or the formal designation of such cases as a priority under existing legal aid schemes administered by the Legal Aid Council of Nigeria.
Under the proposal, access to justice should not depend on a victim’s ability to pay for legal representation.
The document also recommends stronger referral systems connecting victims to law enforcement, legal aid and psychosocial support, alongside free and continuous psychological services.
It urges institutions, educational establishments, community organisations and religious bodies to disseminate information about available support services and strengthen public awareness of image-based abuse.
The model further calls for the creation of a forum of survivors to help identify their needs, share experiences and inform the continuous improvement of the national response.
It also recommends that compensation mechanisms recognise the reputational and economic damage victims may suffer when intimate images are circulated without their consent.
Employers and institutions are encouraged to adopt non-discriminatory policies to prevent victims from suffering adverse professional consequences because of intimate material exposed without their permission.
Stronger investigations and prosecution
On criminal justice, the document proposes a more specialised approach to investigating and prosecuting cases, including improved digital forensic capacity, better evidence management and training for investigators, prosecutors and judges.
It recommends the development of standard operating procedures for investigating and prosecuting non-consensual intimate-image sharing, distinguishing the offence from related crimes such as sextortion and obscenity.
These procedures, it says, should cover the preservation of digital evidence, the securing of electronic crime scenes and the maintenance of an unbroken chain of custody.
The framework also calls for stronger digital forensic infrastructure within the Office of the National Security Adviser and other relevant agencies, with services decentralised to improve access and efficiency.
It proposes expanding the Joint Case Team on Cybercrime’s case-management system to accommodate such cases, including a database of digital image hashes that could help identify and respond to the circulation of previously reported material.
Image-hashing technology can help platforms and relevant organisations identify matching copies of known images without requiring victims to repeatedly circulate or submit the intimate material itself.
The document recommends expanding the use of tools such as StopNCII.org across institutions and civil society organisations supporting survivors, while strengthening cooperation between these organisations and law enforcement agencies.
It also proposes a single official reporting channel for victims, including a telephone number for immediate assistance, and the creation of a database of offenders modelled on the National Sexual Offenders Database established under the Violence Against Persons (Prohibition) Act.
To improve accountability, the framework recommends collecting and publishing statistics on the prevalence of non-consensual intimate-image sharing at national, federal and local levels.
It further urges the establishment of an inter-agency working group or task force involving relevant government institutions and civil society organisations to coordinate responses.
AI-generated abuse, platform accountability
The document warns, through its proposed measures, that the national response must account for the growing technological challenges associated with intimate-image abuse.
It recommends universal invisible-watermarking standards for AI-generated content and clearer liability frameworks for creators, distributors and platforms that facilitate the production or circulation of deepfake intimate images.
AI developers are also urged to maintain adequately resourced safety teams capable of conducting human-led reviews to detect non-consensual intimate imagery and other forms of image-based sexual abuse.
The framework calls for stronger transparency from technology companies, including public reporting on content-removal procedures, average response times and the volume of verified non-consensual intimate images detected and removed.
It also recommends safety and privacy measures built into the design of digital products, alongside efforts to address systemic bias in technology development and governance.
For Nigeria’s creative and media industries, including music, film, fashion, sports and influencer sectors, the model proposes sector-specific awareness and response frameworks.
It also encourages telecommunications companies to use short codes, caller tunes and other accessible communication channels to raise awareness, particularly among people in rural communities.
The proposed measures assign responsibilities across the National Assembly, relevant ministries, the NCC, the Nigeria Data Protection Commission, the National Information Technology Development Agency, law enforcement agencies, the judiciary, civil society organisations and private-sector operators.
The framework presents the response as a shared responsibility, combining legal reform, institutional coordination, platform accountability, victim support and public education.
It recommends integrating education on consent, online safety, cyber hygiene and image-based sexual abuse into school programmes, including at primary, secondary and tertiary levels.
Media organisations, content creators, community leaders and religious institutions are also identified as important partners in sensitising the public and promoting respect for privacy.
The proposed national model ultimately seeks to move Nigeria’s response beyond the removal of abusive images towards a broader system of prevention, accountability, victim rehabilitation and access to justice.
Its recommendations, however, are proposals for strengthening the national response; their inclusion in the document does not, by itself, establish that the suggested six-hour deadline, new offences or other measures have been enacted into law.
