Women’s Policy Group NI Welcomes Consultation on Criminalising Sexually Explicit Deepfakes, Urges Stronger Protections for Survivors
7 October 2025 - The WRDA led Women’s Policy Group Northern Ireland (WPG NI) has submitted a comprehensive response to the Department of Justice’s consultation on proposals to criminalise the creation of, or sharing of (including threatening to share) sexually explicit deepfake images.
WPG NI, a coalition of feminist policy experts and practitioners, welcomes the Minister’s commitment to addressing image-based sexual abuse (IBSA), including deepfakes. However, the group calls for stronger legislation, expanded definitions, and more robust sentencing to reflect the serious harm caused to survivors.
Key Recommendations from WPG NI:
Terminology: Replace “deepfake” with “intimate digital forgeries” to better reflect the nature of the abuse.
Motivations: Expand the list of motivations beyond humiliation and sexual gratification to include control, misogyny, financial gain, and more.
Sentencing: Align penalties with the Scottish model—up to 12 months on summary conviction and up to 5 years on indictment.
Standalone Legislation: Introduce a dedicated Image-Based Sexual Abuse Act to consolidate and clarify legal protections.
Gendered Understanding: Recognise misogyny as a key driver and ensure training reflects the gendered nature of IBSA.
Cultural Competency: Address the role of IBSA in honour-based abuse and ensure laws are sensitive to diverse cultural contexts.
Political Impact: Acknowledge the use of deepfakes to target women in politics and consider aggravating factors in such cases.
The WPG NI response draws on extensive research and previous consultation submissions, including evidence from Women’s Aid Federation NI and other member organisations.
A Call to Action
WPG NI urges the Department of Justice to take a bold and evidence-led approach to this legislation. The group emphasises the need for public education, cross-departmental collaboration, and investment in technical expertise to support enforcement.
-ENDS-
For further information, please contact:
Elaine Crory – elaine.crory@wrda.net
Meghan Hoyt – meghan.hoyt@wrda.net