It is far too easy to put sexually violent material online and far too difficult to get it taken down. There is no prior oversight and current enforcement falls short. None of the regulators and enforcement agencies prioritize combating online sexual violence. This is according to joint research by Offlimits Foundation, National Center for Sexual Violence Foundation, Victim Support Fund, Privacy First and Boekx Lawyers.
Online sexual violence is a big problem: big in number and impact for victims. The current approach falls seriously short on certain points. In a letter to all responsible ministers, six recommendations are included that should lead to better and faster help for victims.
"Our analysis is that the regulations on online sexual violence are adequate," said Otto Volgenant of Boekx Lawyers. "There is no need for new regulations. But regulations that exist only on paper and are not enforced in practice do not protect citizens. The fight against online sexual violence is currently not on the list of priorities of the police, the Personal Data Authority (AP), the Consumer and Market Authority (ACM) and the Media Authority (CvdM). Victims of online sexual violence are left out in the cold."
Worldwide, one in eight children is a victim of online sexual abuse. In the Netherlands, one in three girls and 10% of all boys aged 16-17 are victims of online sexual abuse. Online sexual abuse can have the same impact as hands-on abuse, several studies show. "Victims often experience serious mental health problems such as depression, suicidality, self-harm, anxiety and PTSD. There have unfortunately even been cases in recent years where online sexual violence led to adolescent suicide. In addition, processing online abuse is made more difficult as images continue to circulate," said Carlo Contino of Fund Victim Support.
Robbert Hoving of Offlimits Foundation: "Helpwanted reported 12,206 victims of online transgressive behavior in 2024, of which more than 7,400 reports are about sextortion or the unwanted distribution of intimate visual material. We are working quickly and constructively with many online service providers to get this material out. We just need to be able to take tougher action against those parties who do not cooperate, and with this research we want to help the approach further by indicating where we think the gaps are. Because that's what victims of online cross-border behavior deserve."
Despite existing regulations such as the Digital Services Act (DSA), the General Data Protection Regulation (AVG), the Media Act and the Criminal Code, effective oversight and prompt enforcement are lacking. Platforms continue to distribute images with impunity and often refuse removal requests. This lack of enforcement leaves victims powerless and perpetrators free to act.
To better combat online sexual violence, the five organizations call for:
Prioritization: Ensure that relevant regulators and enforcement agencies include online sexual violence in their priorities, at least by Jan. 1, 2026.
Budgetary and organizational implications of prioritization: In the short term, make an inventory of what the relevant supervisors and enforcement agencies need in order to be able to perform their duties properly. What is specifically needed for each organization should be identified, if possible, before the summer of 2025.
Adequate financial resources: All relevant regulators and enforcement agencies receive their financial resources from the government. If additional budget is needed to prioritize the fight against online sexual violence, the cabinet will have to release funding for it by the fall of 2025.
Periodic consultation: Organize consultation on a structural and non-binding basis between regulators and enforcement agencies also at the international level. Involve Offlimits (as trusted flagger in this area) and possibly other parties.
Intensifying cooperation Offlimits: Offlimits wants to reach agreements with supervisors and enforcement agencies on intensifying cooperation. A fact-finding investigation by Offlimits can serve as a basis for enforcement measures, without the regulator or enforcement agency having to set up a new investigation itself. Offlimits has been a trusted flagger for the very largest online platforms for years.
Annual reporting: It is required that starting Jan. 1, 2026, regulators and enforcement agencies report regularly, at least annually, what they have done to protect victims from online sexual violence.
In May 2025, stakeholders will host a roundtable meeting to further discuss the report's findings and recommendations with regulators, policymakers and other stakeholders.
Read HERE the joint research report by Offlimits Foundation, National Center for Sexual Violence Foundation, Victim Support Fund, Privacy First and Boekx Lawyers (pdf).
Read HERE the letter of recommendations to the responsible ministers (pdf).
