Why We Funded the Landmark Super-Complaint into Police Failures on Image-Based Abuse
Image-based abuse is a growing threat across the UK, disproportionately targeting women and girls—who account for 98.9% of reported cases. With rapid AI innovation enabling new ways to create and spread non-consensual intimate content, referrals to the Revenge Porn Helpline exploded by over 4,000% between 2015 and 2025.
Yet, despite this surge in criminality, the policing response remains severely fragmented and ineffective.
At Law For Change, we are proud to have funded the critical legal and investigative groundwork behind a new landmark police super-complaint. Submitted by #NotYourPorn and the Centre for Women’s Justice, with legal representation from Leigh Day, this complaint exposes systemic policing failures that leave survivors without justice or protection.
What the Research Reveals
Drawing on testimony from over 100 survivors, police force data across England and Wales, frontline insights, and academic research, the super-complaint demonstrates that survivors are being routinely let down at every stage of their interaction with law enforcement:
Abysmal Charging Rates: Across 39 police forces analysed, the charging rate for image-based abuse offences under s.66B was just 4.5% in 2025. In several force areas—such as Avon and Somerset, Cleveland, and North Yorkshire—the charging rate fell below 2%, with some recording only a single charge in the entire year.
Declining Protections: Despite the introduction of new offences under the Online Safety Act 2023, charging rates in force areas like Derbyshire, Norfolk, and Suffolk actually decreased year-on-year.
Severe Evidence and Investigative Failures: In 23 detailed case studies, nearly 80% of survivors reported severe issues with evidence gathering—including failures to interview suspects, seize digital devices, or understand digital platforms. Many were forced to ask friends or family to screenshot humiliating images themselves due to police inaction.
Lack of Support and Secondary Trauma: Of those surveyed, 65% faced evidence-gathering issues, and only 15% reported that police took action to remove non-consensual content. Alarmingly, 48% said they would not report image-based abuse to the police again.
As survivor Juliet* shared: "Police involvement has not alleviated the harm caused by this offence; instead, it has intensified my distress and left me feeling powerless and completely unsupported as a victim."
The Path to Systemic Reform
Law For Change exists to back strategic legal actions that hold public institutions accountable and drive systemic reform. New legislation on paper is meaningless without proper enforcement on the ground.
The super-complaint calls on police forces across the UK to adopt urgent reforms, including:
Creating unified national guidance and clear standards for handling image-based abuse.
Streamlining the reporting process for survivors.
Conducting swift, technologically competent digital investigations.
Using protective orders and bail conditions to prevent ongoing harm.
Significantly improving communication, signposting, and trauma-informed care for survivors.
The complaint is now submitted to the investigating bodies (HMICFRS, the College of Policing, and the IOPC). We look forward to seeing this process drive national policy changes, ensure police forces are properly trained, and guarantee that all survivors receive access to meaningful justice.
(Note: Pseudonyms were used in survivor accounts to protect identities.)
Full complaint: https://drive.google.com/file/d/1FlSw_kyYpsf8E2dUP3uutA0fUgga_gMe/view?pli=1
Executive summary: https://drive.google.com/file/d/1yjScPg_TMmq9blyYTiECu-4FzzOSJ84V/view
Link on #NotYourPorn's website: https://notyourporn.com/our-work/police-super-complaint-for-image-based-abuse