Crime and Policing Bill

Further written evidence to the Crime and Policing Bill 2025 submitted by CEASE (Centre to End All Sexual Exploitation) (CPB49)

NC5, NC6, NC7

1. CEASE – the Centre to End All Sexual Exploitation – is a UK based charity working to expose and dismantle the cultural and commercial drivers behind all forms of sexual exploitation in the UK. We shine a light on what sexual exploitation is, where it occurs and how it contravenes human rights. We campaign for new and better laws and advocate for policy change to hold the global sex industry to account. 

Summary

2. CEASE, the Centre to End All Sexual Exploitation, strongly supports amendments NC5, NC6 and NC7 to the Crime and Policing Bill to update and strengthen legislation on pornographic content.

NC5: Apply offline pornography safeguards to online pornography

This amendment, tabled by Jess Asato MP, would extend content regulations

that already exist for pornography distributed offline to pornography distributed online. This amendment is necessary to ensure what is illegal offline is illegal online and thereby combat the proliferation of violence against women in online pornography.

The sexualisation of children

3. The current laws regulating pornographic content do not go far enough to protect adults and children from the harms of pornography.

4. Since 1984, legislation has existed to specifically prohibit offline content that the British Board of Film Classification (BBFC) would find unsuitable for classification, including in the R18 category, on videos, DVDs and Blu-Ray. [1] This includes pornographic content which depicts illegal activity such as rape or incest, and any material that is potentially harmful, for example because it depicts and/or promotes child sexual abuse, trafficking, or violent sexual acts. [2]

5. There is no equivalent standard to the BBFC’s regulation for online pornographic content as the internet has evolved largely without regulatory oversight. 

6. This has resulted in mainstream pornography sites hosting a vast amount of content that while it is not strictly illegal is none the less extremely harmful. Of particular concern is content that depicts sexual activity with children. Known as ‘barely legal’ or ‘teen porn’, or ‘incest porn’, this content contains petite, young looking performers made to look underage through props such as stuffed toys, lollipops and school uniforms. This normalises children as objects of sexual desire and drives the demand for child sexual abuse material. [3]

7. Although commercial pornography sites such as Pornhub have banned certain search tags and descriptors that overtly suggest underage sexual activity, such as ‘children’ ‘underage’ and ‘child young’, CEASE has found that content which clearly suggests underage sexual activity remains prevalent. Pornhub search tags including ‘babysitter’, ‘classroom teacher’, ‘young’, ‘virgin’, ‘little’, ‘tiny’, ‘exxxtrasmall’ and ‘barely legal’ are still permitted. [4]

8. In 2019, 39 billion searches were made on Pornhub, with one of the most frequent search terms being ‘teen’. [5] Such depictions of sexual activity with the title ‘teen’ are often particularly violent. According to a study which analysed the content of the three most accessed pornographic websites in the UK (Pornhub, XHamster and XVideos), the three most common words in videos which contained coercion and exploitation were ‘schoolgirl’, ‘girl’ and ‘teen’. [6]

9. Although ‘teen’ could legitimately refer to those over 18, much of the content found in the study did suggest sexual activity with underage girls. Titles include terms such as ‘pigtails’, ‘homework’, and ‘braces’. Examples of titles, of hosted videos on the site include ‘Cute schoolgirl gets f***ed by her English teacher’ and ‘Daddy F**** Me Hard Before School’. [7] The most frequent form of sexual violence found in pornographic content was sexual activity between family members. [8]

10. The extensive experience of those working with adult sex offenders shows that the excessive consumption of content which sexualises children can result in offenders viewing illegal child sexual abuse material. [9] As increasingly extreme pornography becomes available on mainstream sites – including pornography which depicts sexual activity with ‘child-like’ performers – the threshold of what is ‘acceptable’ is lowered, legitimising those who access extreme and abusive content. [10] A user may ‘spiral’, seeking more and more extreme pornography to fulfil them – meaning that the next click could be illegal child sexual abuse material. [11]

11. According to child protection experts, viewing violent pornography is a ‘key risk factor’ for men committing child sexual offences. Men who offend are over eleven times more likely to watch violent pornography than men who don’t. [12]

12. The Lucy Faithful Foundation, a UK-wide charity dedicated to preventing child sexual abuse state that ‘What we are seeing on a daily basis is the conflation of easy access to hardcore and deviant pornography and an interest in child molestation. The link is unambiguous’. [13] Their data shows that the consumption of online legal adult pornography increased during the pandemic. This increase led some people to look for ‘riskier’ material and begin viewing child sexual abuse material. In addition, contact with the Stop It Now! Helpline and online self-help modules to stop viewing sexual images of children also increased by 107%. [14]

13. Research [15] undertaken with 1500 British men, released in 2023 found that:

· 10% of men admitted they had engaged in child sexual offending, either online or offline.

· Nearly one in twenty said they had had sexual contact with a child when they themselves were aged 18 or older.

· 5% admitted they had sexual feelings towards children and had acted upon those feelings, while an additional 7% admitted to having sexual feelings towards children but not acting on them.

· The author of this study has stated that "Men who are sexually offending against children are watching a lot more online pornography but also the type of content they are consuming is very deviant." [16]

· According to the Internet Watch Foundation, sexual abuse imagery of primary school children has increased by 1,000 per cent since the Covid19 lockdowns. [17]

Violence against women and girls

14. Evidence also suggests that online pornographic content is impacting the normalisation of violent and abusive sexual behaviours, including non-fatal strangulation during sex. A national probability study in the US found that 21% of women reported having been choked during sex, and 20% of men reported that they had choked their partner during sex. [18] Further, research for BBC Radio 5 Live in 2019 found that a third of UK women under the age of 40 had experienced slapping, choking, gagging or spitting during consensual sex. [19] Research has found that strangulation during sex can increase the risk of stroke and brain injuries, even if the person does not lose consciousness. [20] Of course, strangulation during sex can also result in death, and the Domestic Abuse Act 2021 removed ‘consent’ as a defence if someone is seriously harmed or killed by strangulation. [21]

15. Data from the Devon and Cornwall Sexual Assault Referral Centre (SARC) reported a total of 172 referrals being made to the service over a five-month period in 2023. Of these, 31% (53) were victims who had suffered non-fatal strangulation as part of the sexual violence experienced, averaging at least two to three per week.

16. A deep dive into 44 of these cases, by Louise Barraclough Interim Head of Safeguarding and MCA, and the DASV Lead, found that in 41 of the cases the victims were female, with three being male. 41 reported difficulty breathing, 22 had visible signs of injury, including bruising, redness to neck, petechiae and abrasions, and three were sent to the Emergency Department due to the severity of their symptoms. Methods of strangulation included hands, elbows, legs and belts. In 26 cases the perpetrator was a friend or acquaintance of the victim, in ten cases the perpetrator was a partner, with seven involving a stranger.

17. Other additional violence that was recorded included: headlocks, being tied up, hair pulling, slapping, insertion of objects and threats with weapons.

18. All are common acts of violence found within online pornography. In the cases examined, in addition to the injuries related to non-fatal strangulation there was an average of 11 other injuries reported, and in some cases as many as 46. In all the cases of non-fatal strangulation, it was reported that the victim never gave consent. In six cases, initial consent was given for some sexual acts but not for the subsequent non-consensual sexual acts that the victim was reporting.

19. Despite the offence of strangulation during sexual activity being included in the Domestic Abuse Act 2021, pornographic content which depicts breath restriction still has not been regulated online and is prevalent. [22]

20. The loophole in legislation that allows non-fatal strangulation content and content such as ‘barely legal porn’, ‘incest porn’ and ‘teen porn’ to be prolific online must be closed.

21. Online pornography and social media platforms that host this type of deeply harmful material must be subject to the same laws that govern the offline world, where this material is not allowed. If it is illegal offline, it must be illegal online.

22. Amendment NC5 will help to ensure that the UK government can enforce an equivalent online standard to the BBFC’s regulation for offline pornographic content.

NC6: Verify the age and permission of everyone featured on pornography websites, and enable withdrawal of consent at any time

23. This amendment, tabled by Jess Asato MP, is necessary to safeguard children and adults from sexual exploitation. It would require pornography websites accessed from the UK to:

a) verify that every individual featured on their site is an adult;

b) verify that every individual featured on their site gave their permission for the content to be published there; and

c) enable individuals featured in pornography to withdraw their consent to its continued publication at any time.

24. Most videos on pornography sites operate a User Generated Content (UGC) business model which means uploads appear instantaneously, and there are no controls or verification procedures in place to check that those on camera are consenting adults. This means that pornography sites can and do host footage of trafficking, non-consensual sexual violence, image-based sexual abuse, covert filming ("real spy-cam porn " ), AI generated pornography such as ‘deepfake’ pornography of women and girls , and child sexual abuse material (CSAM). [23] It is this high-risk business model that has enable d the pornography industry to explode in scale and profitability in such a short amount of time.

25. Pornography platforms are effectively complicit in hosting and disseminating various forms of illegal content on a massive scale, including rape, sexual assault and sexual abuse. For example, in 2020, Rose Kalemba shared with the BBC the story of how, at just 14 years of age, she was brutally raped at knifepoint by two men, only to discover a few months later that a video of her attack had been shared on Pornhub and viewed hundreds of thousands of times: "The titles of the videos were ‘teen crying and getting slapped around’, ‘teen getting destroyed’, and ‘passed out teen’. One had over 400,000 views." [24] This is just one of many similar stories.

26. There is also significant evidence of women who are involved in prostitution/commercial sexual exploitation having their sexual acts with sex buyers recorded, either by the sex buying men, or the woman’s pimp, and that footage being uploaded to pornography sites. [25]

27. There is no way for content moderators who are viewing hundreds of videos a day to be able to identify what may be illegal material. There is also evidence from ex-moderators who have spoken out about the pressure they are under to pass as much content as possible and only remove it if it is 100% illegal. [26]

28. Exploitation is commonplace in the production of pornography. Women are often forced or coerced into the pornography industry and once in it, even the most famous ‘pornography performers’ are exploited. [27]

29. Once in the industry, women are coerced and forced to partake in more and more extreme, dangerous and violent sex acts. [28] The violent sex that is shown in pornography is real and there is no way of knowing if the people, mostly young women have consented to take part in this. A lot of the time it is filmed rape. [29]

30. Many pornographers' prey on vulnerabilities, using a woman’s often precarious economic situation to coerce them into pornography and push them into producing increasingly extreme content.

31. Websites that host this material then profit from this coercion. In December 2023, after a federal investigation in the US, Aylo, the owners of Pornhub, publicly admitted it had profited from sex trafficking, agreeing to pay a fine of $1.8 million in order to avoid criminal prosecution for profiting from sex trafficking videos on its site. [30]

32. Due to many people entering the pornography industry at a young age, there is no way of knowing if the people who appear in pornographic content are over the age of 18. According to a report on domestic minor trafficking in the US, the average age of someone trafficked into pornography production was 12.8 years. [31] This is consistent with other studies and testimonies on the age of people being trafficked into sexual exploitation. Jewell Baraka, a survivor leader and author, documents in her book, ‘Coming of Age on a Porn Set’, how after years of sexual abuse, her father first trafficked her into a brothel at the age of 11 and then into what she refers to as "adult hardcore porn" at the age of 14. [32]

33. It is therefore not surprising that a research report from Finland released in 2024, exploring incidences of CSAM on the open web, found that "32% of respondents report that they have encountered CSAM on a pornography website. When asked on which platform they have encountered CSAM, Pornhub was the most cited platform." [33] A separate study from the US found that almost a third of online adult content consumers have unintentionally found CSAM. [34]

34. The simplest way to stem this abuse is to ensure that all pornography sites employ strict age and consent checks for all content that is uploaded to their site, either by a user or by the site itself, or a third party acting on their behalf.

35. Given that this content is then immortalised on the internet and that studies show that rates of post-traumatic stress disorder (PTSD) are higher in women who have been involved in pornography in comparison to other forms of commercial sexual exploitation, [35] it is crucial that any consent that is provided can be rescinded at any time and that pornography sites take active measures to remove content once requested.

36. Amendment NC5 will ensure that children and adults are protected from sexual exploitation through the mandated use of age and consent checks by pornography websites.

NC7: Apply Online Safety Act duties to all pornography websites

37. This amendment, tabled by Jess Asato MP, would extend Online Safety Act duties to combat illegal content to all pornography websites. This amendment is necessary because duties to combat illegal content currently only apply to pornography websites that host user-to-user interactions or user-generated content.

38. As outlined above, pornography sites are littered with illegal content, regardless of whether the site hosts commercially produced pornographic content (Part 5 services under the Online Safety Act 2023) or user uploaded content (Part 3 services under the Online Safety Act 2023).

39. Illegal content featuring trafficked and exploited individuals is camouflaged in a vast ocean of similar-looking content. Victims of abuse rarely turn to the camera and announce that they are being abused, and even videos where individuals register distress, blend in with the plethora of rape and abuse-themed pornography that has become mainstream. [36]

40. Further, illegal content such as child sexual abuse material (CSAM) is prevalent on pornography sites, regardless of the type of pornography site.

41. By not applying illegal content duties to all pornography sites, the UK government is giving Part 5 sites a free pass. The regulator Ofcom cannot take enforcement action against a pornography site hosting commercially produced pornography even if it is hosting and profiting from illegal content. This is a gaping error and loophole in current legislation.

42. Amendment NC7 will remedy this and ensure that all pornography sites, regardless of what material and services they provide, must adhere to illegal content duties and remove all illegal content on their sites.

Contact Details

For more information, please contact:

Gemma Kelly, Head of Policy and Public Affairs, CEASE: gemma.kelly@cease.org.uk

April 2025