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Reported The Forgotten Constraint Costly
Ofcom fines Itai Tech £55k for Undress.cc age-assurance and information-notice failures
On 20 November 2025 Ofcom’s Confirmation Decision fined Itai Tech Ltd £50,000 plus £5,000 for Undress.cc Part 5 age-assurance failures (17 Jan–11 May 2025) and a late section 100 response. UK geo-block from 11 May 2025 noted; no findings thereafter.
Generative “undress” tools reachable in the UK without highly effective age assurance under OSA Part 5.
On 20 November 2025 Ofcom issued a Confirmation Decision under section 132 of the Online Safety Act 2023 against Itai Tech Ltd, the limited company registered in England and Wales (company number 15076132) that operates the generative “nudification” site Undress.cc. Ofcom determined that, for the Relevant Period 17 January 2025 to 11 May 2025, Itai failed to comply with Part 5 duties under section 81 — including the duty under section 81(2) to use highly effective age verification or age estimation so children are not normally able to encounter regulated provider pornographic content, and the written-record and public-summary duties under sections 81(4) and 81(5) — and failed to comply by the deadline with a statutory information notice under section 100, contrary to section 102(8)(a). Ofcom imposed a £50,000 penalty for the section 81 failures and a £5,000 penalty for the information-notice failure (£55,000 in total), payable by no later than 31 January 2026, with amounts passed to HM Treasury. From 11 May 2025 Itai geo-blocked users with UK IP addresses as an interim step; Ofcom made no formal findings on compliance from 12 May 2025 onward and reserved its position on ongoing compliance.
The detail most write-ups skip is how thin the age control was against the Part 5 standard. Ofcom's user-journey review on 30 April 2025 found provider-generated sexual imagery reachable on the service; a self-declaration step asking users to confirm they were over 18 before generation options; and sign-up text stating users must be 18+, without age verification or age estimation capable of being highly effective. Ofcom's published guidance lists self-declaration alone as not capable of meeting that standard. No written record of age-assurance methods, and no public summary of such a record, could be located on review. Ofcom had sent an advisory letter on 17 January 2025 and a follow-up on 16 April 2025 without response before opening the investigation on 8 May 2025. A section 100 notice of 24 June 2025 sought qualifying worldwide revenue, UK user numbers since 24 December 2024, and a complete list of other Itai services, with a 2 July 2025 deadline; no response arrived by then. After the Provisional Decision of 17 September 2025, Itai submitted representations stating it operated undress.app, undress.cc and undress.love, confirmed the UK geo-block would remain until a highly effective age-assurance solution was ready, and later supplied the outstanding financial and user figures. Ofcom treated the service as having UK links for Part 5 and treated outputs of the site's automated generation tools as regulated provider pornographic content.
The pattern is forgotten-constraint. A generative undress tool remained reachable in the UK after Part 5 commenced while relying on self-declaration — the exact kind of age check the Act's highly-effective duty was built to replace.
What to sit with
Worth arguing about
- When does blocking a country feel like real safety, and when does it just pause the argument with the regulator?
- What would “strong enough” age checks look like before a tool like this ever opens in the UK?
What’s at stake
- People in the UK could open a tool that undresses photos while only ticking a box to say they were old enough.
- Ofcom also says the company was slow to answer a formal request for basic facts about how age checks worked.
What this gets right
- From 11 May 2025 the site blocked UK visitors, which stopped easy access while stronger checks were promised.
- The decision makes clear that a simple “I am 18” tick is not enough for this kind of tool under UK rules.
What stays messy
- For months the live age gate was still just that tick-box, even after the rules demanded stronger checks.
- Key numbers only arrived after Ofcom had already drafted its provisional decision — not by the deadline.
Easy to miss
- Ofcom did not make findings about what happened after the UK block — so the block is not a full clean bill of health.
One thing to try What if tools like this could not run in the UK until stronger age checks and a clear written record were already in place?