The 90‑Day Playbook: Standing Up NCII and Deepfake Sexual Content Operations

Penalties for failing to control non‑consensual intimate images (NCII) and deepfake sexual content now reach into the high single digits of global turnover in multiple jurisdictions, and systemic duties are in force or phasing in through 2026. Regulators expect provenance signals and labeling for AI‑generated media, rapid notice‑and‑action, targeted staydown using perceptual hashes, and robust age/identity/consent verification where sexual content is involved. The bar is rising: very large platforms face independent audits and detailed transparency reporting, while adult content services must operate rigorous performer‑verification and recordkeeping regimes.

This 90‑day playbook shows exactly how to stand up a compliant, cross‑jurisdictional program—fast. It offers step‑by‑step SOPs, checklists, and tooling patterns to launch reporting, takedown, staydown, age‑assurance, provenance and labeling, transparency reporting, law‑enforcement liaison, and vendor governance. The goal: move from policy intent to operational reality, with audit‑ready artifacts and measurable risk reduction.

By day 90, you will have: an accountable executive and risk register; live victim reporting channels with identity verification and trusted‑flagger intake; published NCII/deepfake policies with regional disclosures; notice‑and‑action workflows (including statements of reasons and appeals); targeted staydown via perceptual hashing; age‑assurance and uploader/performer verification where required; transparency pipelines, DPIA documentation, cross‑border controls, LE playbooks, and vendor SLAs.

Governance and Kickoff (Week 0)

Appoint the accountable executive and steering forum

• Name a senior accountable executive for NCII/deepfake operations with authority across Trust & Safety, Legal, Privacy, Security, and Product.
• Establish a cross‑functional steering group meeting weekly through Day 90, then monthly.
• Define jurisdictional scope: EU (platform obligations and deepfake transparency), UK (Online Safety duties and pornography age‑assurance), US (Section 230 context, state NCII/deepfake statutes, FTC impersonation), Australia (eSafety removal/codes), Canada (NCII criminal prohibitions; privacy law), Japan (NCII restrictions; APPI).

Scope harms and map to legal hooks

• Harms in scope: non‑consensual intimate images, fully synthetic sexual content depicting real people without consent, manipulated sexual images of real persons, and universally prohibited child sexual exploitation.
• Align policy categories to legal frameworks: notice‑and‑action, statements of reasons, trusted flaggers, deepfake labeling and detectability, age‑assurance and performer verification, privacy‑by‑design, cross‑border transfer controls.

Seed the risk register and define success metrics

• Create an NCII/deepfake risk register tied to systemic‑risk and privacy‑impact requirements; track risks, mitigations, owners, and timelines.
• Define measurable objectives (e.g., time to takedown, accuracy targets for hashing matches, appeal resolution times). Where specific metrics are not mandated, set internally reasonable targets and revisit quarterly.
• Identify DPIA triggers for any processing of sensitive data (e.g., biometric/face‑matching for victim verification).

Days 1–30: Channels, Policies, and Triage

Launch victim reporting channels and identity verification

• Stand up in‑product, webform, and email intake tailored for NCII/deepfake sexual content with clear guidance on what to submit (links, screenshots, context). Accessibility is expected across major jurisdictions.
• Offer authenticated victim reporting with optional identity verification to prioritize and reduce abuse. Verification may include government ID checks or face‑matching with explicit consent; implement strict minimization and retention limits consistent with privacy laws.
• Provide emergency triage for urgent harms (e.g., widespread dissemination), with 24/7 on‑call coverage and escalation pathways. Document criteria for acceleration and when to notify or cooperate with authorities consistent with national schemes.

Enable trusted flagger/NGO intake

• Integrate a priority queue for trusted flaggers, regulators, and recognized NGOs. Implement SLAs, feedback loops, and periodic calibration to maintain signal quality.
• Log all submissions for audit and transparency reporting.

Publish clear policies on AI sexual content and NCII

• Publish a standalone policy on: definitions (NCII; synthetic/manipulated sexual content), prohibited content, allowed but labeled content (where appropriate), reporting routes, and appeal rights.
• Specify how labeling for AI‑generated/manipulated content appears to users (e.g., persistent badges with contextual explainer) and when such content is restricted, age‑gated, or removed.
• Regionalize disclosures:
• EU: deepfake transparency for deployers and platform disclosures; no general monitoring, but proportionate proactive measures expected for very large services.
• UK: duty‑of‑care expectations; robust age‑assurance for pornography access; cooperation with illegal content remedies.
• US: truthfulness in claims about detection/labeling to avoid deceptive practices exposure; geofenced labels may be required for synthetic media in political communications in some states.
• Australia: reasonable steps for minimization of harmful content; responsiveness to removal notices; image‑based abuse scheme.
• Canada/Japan: NCII prohibitions and privacy‑law transparency and minimization duties.

Minimum policy checklist

• Definitions and scope of NCII and AI‑generated sexual content
• Labeling standards and when labels vs. removal apply
• Minor‑protection measures (age‑gating, parental controls where applicable)
• Trusted‑flagger program terms
• Regional geofenced disclosures and takedown windows where applicable
• Appeals and evidence standards

Days 31–60: Decisions, Staydown, and Verification

Operationalize notice‑and‑action with due process

• Build a triage and decision workflow: intake → initial classification → human review for edge cases → decision issuance → enforcement → logging.
• Issue reasoned decisions with a standardized statement of reasons including: content identifiers, policy/legal basis for action, moderation measures applied, and appeal instructions.
• Provide an internal complaint/appeals process with defined SLAs and a path to out‑of‑court settlement where required.
• Maintain a decisions ledger that supports transparency reporting templates and regulator access requests.

Decision artifacts to pre‑approve

• Decision templates by category (NCII confirmed; AI sexual content labeled; AI sexual content removed; insufficient evidence; reversal on appeal)
• Escalation matrices for high‑risk cases, minors, or widespread virality
• Evidence standards for matching (hash confidence bands; contextual indicators)

Deploy targeted staydown using perceptual hashes

• Generate perceptual hashes (image/video) for adjudicated illegal NCII and confirmed deepfake sexual content that violates policy. Store with strict access controls, purpose limitation, and deletion schedules.
• Enforce targeted staydown: block re‑uploads matching hashes, and log attempts. This is compatible with “no general monitoring” when scope remains targeted to adjudicated content.
• Implement a revocation path: remove hashes on successful appeals or consent changes and propagate revocations quickly.
• False‑positive remediation: monitor precision/recall, allow edge‑case human review, and provide a user path to challenge automated matches.

Implement age‑assurance and uploader/performer verification where required

• For pornography access in the UK, deploy robust age‑assurance proportionate to risk and publish methods and error handling.
• For platforms hosting actual sexually explicit content (US context), implement uploader and performer ID/age verification and maintain accessible records with custodian‑of‑records notices, segregating workflows for purely synthetic content.
• For video‑sharing services and high‑risk features, supplement with minor‑protection measures (e.g., age‑gating and parental tools) proportionate to risk.

Records handling SOPs

• Maintain records securely and separately from general user profiles; restrict access by role.
• Publish retention schedules and deletion processes consistent with privacy laws.
• Ensure auditability for regulators and, where applicable, labeling of content with required custodian‑of‑records notices.

Days 61–90: Transparency, Cross‑Border, LE, Vendors, and Continuous Improvement

Build the transparency reporting pipeline and audit‑ready logs

• Align moderation logs to structured transparency templates including counts of notices, actions taken, average resolution times, and statement‑of‑reasons metadata.
• For very large platforms, prepare evidence of systemic risk mitigation and annual audit readiness; maintain the risk register, rationale for chosen mitigations (e.g., provenance pipelines, proactive detection), and outcomes.
• Balance retention with minimization: keep only what is necessary for legal reporting and appeals; document deletion schedules for perceptual hashes, biometric artifacts, and telemetry.

Complete DPIA documentation and evidence preservation SOPs

• Run DPIAs covering: provenance ingestion and labeling, image hashing and re‑upload scanning, victim identity verification, and age‑assurance/uploader verification.
• Document lawful bases, purposes, data categories, risks, mitigations, and transfer mechanisms. In Japan and Canada, prepare parallel privacy impact materials aligned to national requirements.
• Create evidence preservation SOPs for severe cases and lawful requests: define short‑term preservation, access controls, and timelines that respect privacy law.

Cross‑border processes and geoblocking decisions

• Appoint an EU representative if you target the EU but lack establishment.
• Implement lawful cross‑border transfer mechanisms for EU, Canada, and Japan, and record processor/sub‑processor data flows.
• Build a geoblocking/geo‑labeling decision tree:
• When content is illegal in a given jurisdiction (e.g., NCII), block locally or globally per policy.
• When disclosures are required in specific states or countries (e.g., synthetic media in political contexts), apply geofenced labels and takedown windows.
• When lawful bases differ, default to stricter regional controls and retain documentation for why.

Law enforcement liaison and safeguarding

• Designate trained LE points of contact with a published intake channel for lawful requests.
• Verify requests’ legality and scope; require appropriate process and only disclose minimally necessary data.
• Prioritize victim safety: provide guidance on evidence capture for victims; coordinate with national NCII schemes where they exist; avoid actions that increase re‑exposure risk.
• Maintain a communications playbook for high‑profile NCII/deepfake incidents: roles, messaging, and timelines.

Vendor management and third‑party assurance

• RFP and contracting criteria for AI and safety vendors:

• Support for content provenance (e.g., C2PA manifest ingestion/verification) and watermark detectability that aligns with state‑of‑the‑art.

• APIs and documentation/system cards for models/features that affect deepfake detection and labeling.

• Measurable SLAs for detection latency, takedown throughput, accuracy ranges, and appeal turnaround.

• Data‑protection commitments: processing purposes, storage location, security controls, retention, and deletion on termination.

• Third‑party assurance or independent testing options; regulator‑facing documentation on request.

• Establish vendor oversight: quarterly performance reviews, periodic privacy/security assessments, and rapid termination pathways with assured data deletion.

Continuous improvement and control testing

• Run red‑team exercises on evasion techniques (e.g., image transformations to defeat hashing, provenance stripping) and update countermeasures.
• Conduct virality tabletop drills simulating widespread NCII or deepfake porn, including escalation, cross‑border geoblocking decisions, and LE engagement.
• Test controls quarterly: sampling audits of decisions and statements of reasons, false‑positive remediation checks, and age‑assurance efficacy reviews.
• Report to executives via KPI dashboards and narrative risk updates; integrate lessons into the risk register and policy revisions. ✅

Jurisdictional triggers: what “good” looks like

Jurisdiction	Key triggers	Must‑have controls (operational translation)
EU	Notice‑and‑action; statements of reasons; trusted flaggers; deepfake transparency; GPAI detectability; GDPR safeguards	Reasoned takedown pipeline; statement‑of‑reasons database; priority queues for trusted flaggers; C2PA/watermark ingestion and labeling; DPIAs and transfer mechanisms
UK	Duty of care; illegal content codes; Part 5 pornography age‑assurance; intimate image offences	Proportionate proactive detection; rapid NCII takedown and targeted staydown; robust age‑assurance; performer age/consent verification; documented risk assessments
US	Section 230 context; FTC Impersonation Rule; §2257/Part 75; state NCII and election deepfake laws	Truthful safety claims; adult‑site records and notices; fast NCII takedown/staydown; geofenced synthetic‑media disclosures where required
Australia	eSafety removal notices; BOSE; industry codes/standards	Rapid response to notices; image‑based abuse workflows; perceptual‑hash staydown; transparency to the Commissioner
Canada	NCII criminal prohibitions; PIPEDA; potential new systemic duties	Robust NCII reporting/removal; privacy‑by‑design controls; readiness for additional transparency/risk duties
Japan	NCII distribution restrictions; APPI; AI governance guidance	NCII takedown/staydown; lawful processing with transfer safeguards; watermark/provenance as good practice

Conclusion

Standing up NCII and deepfake sexual content operations in 90 days is achievable with disciplined sequencing and clear ownership. Begin with governance and policy clarity, then move quickly to victim‑first reporting, trustworthy decisions, and targeted staydown. Layer in age‑assurance and performer verification where required, and finish by hardening your program with transparency pipelines, DPIAs, cross‑border safeguards, LE playbooks, and vendor accountability. The result is an auditable, resilient operation aligned to evolving obligations through 2026—and a safer experience for users.

Key takeaways

• Appoint a single accountable owner and run a cross‑functional weekly program through Day 90.
• Ship reporting channels and clear policies by Day 30; enable trusted flaggers and emergency triage.
• Operationalize statements of reasons, appeals, and perceptual‑hash staydown by Day 60.
• Complete transparency, DPIAs, cross‑border controls, and LE/vendor playbooks by Day 90.
• Iterate continuously with red‑teams, tabletops, and quarterly control testing.

Next steps

• Stand up the steering group and finalize the risk register this week.
• Publish your NCII/deepfake policy with regional disclosures within 30 days.
• Lock SLAs and data‑protection terms with detection and provenance vendors within 60 days.
• Produce your first structured transparency report and DPIA addendum by Day 90.

Looking ahead, deepfake transparency and detectability requirements will continue to harden, and national regulators will expect demonstrable provenance pipelines, targeted staydown, and accurate age/consent verification. Teams that operationalize these controls now will be best positioned for audits, enforcement, and the next wave of standards. 🔒

Sources & References