For Campus Leaders

Image-Based Sexual Abuse and Title IX

A guide to what's actually in effect right now, what changed, and what your office can do today — no new federal rule required.
Read the Full Guide (PDF) →Download the One-Page Overview →

For Campus Leaders

It Starts in a Dorm Room

Two campus cases from 2025 show how fast this moves — and why no policy was ready for it.

In June 2025, a Northern Illinois University student was arrested after deputies searched his dorm room and found more than 20,000 AI-generated sexual images — made from photos of his former classmates and sold through a Telegram channel. Three months later, a lawsuit was filed against a fraternity at Arizona State University after a member allegedly filmed and shared an intimate video as part of a hazing ritual. The university suspended the chapter that October.

Neither case waited for a campus policy to catch up. They didn't wait for a new federal rule, either — and right now, there isn't one to wait for.

For Campus Leaders

What Changed, and What Didn't

The rule that named deepfakes is gone. The older rule that still applies never mentions them. Here's what that leaves you with.

If you remember hearing that Title IX was updated to specifically cover AI-generated sexual images, you're not wrong — you're just remembering a rule that no longer exists. The 2024 Title IX Final Rule, the first to name deepfakes explicitly, was vacated nationwide by a federal court in January 2025. A separate federal guidance document that addressed deepfakes directly was later rescinded. Both are gone.

What's still in effect is the older 2020 Title IX rule, which requires schools to respond to sex-based harassment they have notice of — but it was written before this problem existed, so it never uses the word "deepfake." That doesn't mean the conduct falls outside Title IX. It means your campus doesn't have a rule to point to that names it, which is exactly why we built this guide.

What's current right now

  • The 2020 Title IX rule

    The general sex-based harassment standard, still enforced today.

  • The TAKE IT DOWN Act (2025)

    A federal law giving students a 48-hour platform removal right. It regulates platforms, not campuses, so there's no compliance deadline for your office — but it's a real resource to point students toward.

  • State law layered on top of federal

    This varies by state; loop in your counsel.

For Campus Leaders

What To Do Now, By Role

You don't need a new federal rule to build a real standard.

  1. Title IX Coordinators

    Document how your office currently analyzes whether a deepfake or NCII incident meets the hostile-environment standard, rather than leaving that judgment call improvised in the moment.

  2. Student Conduct

    Know the line between a Title IX matter and a CSAM mandatory-reporting matter before you need it. That line doesn't wait for your normal process.

  3. Residence Life & Resident Assistants

    You're often the first person a student tells. You don't need to resolve the legal question — you need to know who to route the student to immediately.

  4. Greek Life Advisors

    Build image-based abuse explicitly into hazing and conduct education, not as a footnote to a broader sexual misconduct training.

  5. Campus Counsel

    Track the 2024 rule's appeal. A reversal would change these obligations again.

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Download the Full Guide

The complete guide includes five real U.S. campus cases, a detailed breakdown of what's currently in effect versus vacated or rescinded, and a full role-by-role action plan.

Download the Full Guide (PDF) →Download the One-Page Overview (PDF) →

Questions

Frequently Asked Questions

Is my campus required to name "deepfakes" or "image-based sexual abuse" in our Title IX policy?
No federal rule currently requires that specific language. But conduct that meets the general sex-based harassment standard — severe, pervasive, and objectively offensive enough to deny a student equal access to education — is covered whether or not it's named explicitly.
Does the TAKE IT DOWN Act create new obligations for our office?
Not directly. It creates obligations for platforms, not schools, and gives students an enforceable right to request removal within 48 hours. It's worth knowing so you can direct students to use it, not something your office needs to certify compliance with.
What's the single biggest mistake a campus can make here?
Referring a report to police or campus safety and considering the school's obligation finished. Prior federal guidance (since rescinded, but instructive) specifically found that response inadequate — a school that does nothing beyond a police referral can still have failed its own duty to respond to a hostile environment.
Where can I get help building our policy?

Contact us — we offer free training built around what your specific office is seeing, and can talk through your policy language directly.

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