Government VAWG Strategy - Our Response


Introduction

On the 18th December, the final sitting day of Parliament in 2025, the Government announced its long-awaited Violence Against Women and Girls (VAWG) Strategy (“the strategy”). Originally planned to be released in the summer of 2025, the strategy follows from their 2024 Election Manifesto commitment to halve violence against women and girls in a decade.

We are pleased to see the arrival of this necessary strategy and the Government’s commitment to halve violence against women and girls. We are especially pleased to note the Government’s clear acknowledgement and commitment to supporting women who face intersecting forms of abuse and marginalisation, such as the disproportionate impact of VAWG to Black women. We’re glad to see, in writing, a commitment to taking into account the different experiences victims and survivors may have  on the basis of race, disability, age, sex, nationality/status and sexual orientation. 

However, while a solid emphasis on prioritising children’s protection through education is welcome, alongside attention to male loneliness and its resulting relationship to VAWG as the majority of perpetrators, we are concerned that the strategy risks inadvertently sidelining women’s support and protection, which should be the focus of any attempt to tackle gender-based violence.

In the below, we assess the VAWG Strategy against our organisational focus area, the intersection of technology and VAWG and the impacts on Black women and gender-expansive people specifically. 

Tech-Facilitated Gender-Based Violence

AI, Pornography, and NCII

Internet technologies are an accelerator of existing social justice issues. Technologies change the ways these issues are experienced, but they are rarely the originator of these problems. In the VAWG Strategy’s section on online harms, the Government acknowledges this, identifying that “deeply rooted societal attitudes and outdated gender norms which fuel VAWG are being reinforced online.”(1)

However, their focus on sexual violence (‘extreme pornography’ and nudification apps) oversimplifies the scope of the issue. While the Government is right to take data reporting on children’s access and viewership of pornography, the cited data of “10% of children who had ever seen pornography, had done so by age 9,” is based on a small number of respondents (n=100).(2) The Government should get a representative sample to fully understand the scope, and ensure that they do not risk turning the issue into a moral panic. Relatedly, the Government has already announced it will introduce legislation to make it a criminal offence to possess or publish pornography which depicts strangulation, in combination with designating the depiction of strangulation or suffocation in pornography as part of the priority offences in the Online Safety Act.

It can be tempting - because it is more straightforward - to set our sights on something as egregious as dangerous sexual behaviour, but this risks inadvertently further criminalising the environment for sex workers — which is a legitimate form of work — as well as potentially cracking down on sexual freedom, and sexual expression of those who fall outside of societal norms. This includes sex workers, people who are OnlyFans content creators, and queer people in loving relationships that may share consensual sexual content on video platforms. We should also be concerned about the State getting to determine non-normative forms of intimacy. It was not too long ago that Section 28 was repealed, which legitimised homophobic stigma, discrimination and abuse as a matter of policy. Intimacy is a political issue, and we must be careful to ensure those marginalised are not Othered under the guise of VAWG protections. What we see as a more pervasive issue is the ways in which misogynoir and misogyny more generally is normalised throughout society, in acts that are not so tangible or easy to define — both on and offline.

In terms of AI-enabled TFGBV, we are pleased to see a ban on nudification apps and similar tools used to create synthetic non-consensual intimate images (IIA), something we have long called for. We are clear that such a ban would need to extend to the discovery of these apps and tools, which would not only impact search capabilities on social media, but also crucially, app stores.

We wait with interest for further detail about what new legislation to strengthen the safeguards against AI-generated sexual abuse will entail, and are keen to understand how these proposals will embed with and support the Online Safety Act and align with Ofcom’s existing VAWG guidance

In the strategy, the Government states that it awaits further research and the results of their own testing on emerging VAWG risks to improve their understanding of the capabilities and threats posed by AI. In response to this, we would point to the plethora of academic, civil society and victims support groups’ research and policy briefs on existing and emerging AI-generated TFGBV, and call upon the Government to avoid any further delays by waiting on unnecessary new research, covered elsewhere. 

On Non-criminal Redress

The Government acknowledges the need “to support victims and survivor [sic] to get justice and give them the chance to heal.”(3) Crucially, as so much of misogyny is socio-cultural, we would expect the strategy to further outline supportive solutions outside of criminalising behaviour, particularly given what we know about low conviction rates for rape. 

In our position paper, Beyond the Content Takedown, we explore what support and justice for victim-survivors of intimate image abuse (IIA) can look like beyond content removal and carceral systems. Our paper proposes a government-funded, non-criminal redress scheme for victim-survivors of IIA and potentially other forms of tech-facilitated gender-based harm in the UK. We note with interest that the strategy suggests the Government will explore further routes to ensure NCII’s are removed from online platforms, as well as tactics for global cooperation. Content takedown is the number one request from victim-survivors. However, content takedowns - when they happen - is not the same as justice. Our position paper and associated recommendations aligns with the Women and Equalities Select Committee report on tackling non-consensual intimate image abuse:

“The Government should take a holistic approach to legislating against NCII abuse by introducing a swift, inexpensive statutory civil process, as has been established in other jurisdictions such as British Columbia in Canada. Doing so would recognise survivors’ wishes to access redress beyond the criminal law, as well as empower them to take fast and effective action towards having their NCII taken down or blocked. We imagine non-criminal redress as a viable route to facilitating justice, and see it as a requirement to repair and address IIA violations, focusing on victim-survivors’ immediate and long-term needs.”(4)

Glitch looks forward to using the VAWG strategy to work with the Government to provide the resources for Black women and Black gender-expansive victim-survivors to recover from the impact of IIA, so that they can have support in rebuilding a safe and independent life post-abuse.  

Perpetrators

We are deeply concerned about the Government’s desire to use facial recognition technology (FRT) to identify and monitor potential perpetrators, especially considering the documented risks to marginalised communities, and Black men in particular. We reject the unmitigated use of surveillance powers to monitor ‘potential criminals’, and the urgency of VAWG to justify such human rights-abusing proposals. We, alongside many other organisations have long called for a ban on these surveillance and biometric  technologies, whether for a VAWG strategy, or ’digital ID.’ 

We await further information about the proposed ‘digital tool’ that aims to enable the police to support better decisions when disclosing information to victims and survivors through the DVDS or the stalking “Right to Know” scheme.  

Police and Criminal Justice System Reform

Black women and Black gender-expansive people are often abused, mistreated, discarded, invisibilised, disbelieved, and rightly, mistrusting of the police, and broader criminal justice system.

As proponents of Black feminisms, we understand justice to require centering the consciousness and lived experience of people “rendered invisible by inequality and injustice.”(5) Consequently, we apply a Black feminist lens to this issue. Taking a restorative/transformative justice approach as we do, is a means to address the root causes of structural violence, choosing not to engage in carceral apparatuses for responding to crime.

We recognise that some women choose to engage with the criminal legal system, and when they do, believe they should be met with a trauma-informed approach. Working with by-and-for organisations who have the expertise to feedback on and inform the aims of the new National Centre for VAWG and Public Protection will be key to the success of this, particularly as re-traumatisation from police is a key risk and barrier for victims who choose to pursue criminal prosecutions.

Similarly, the development of the statutory guidance on release perpetrator information should be informed by victims and survivors and the organisations that support them, in order to prevent perpetrators continuing to hold positions of power over victims.

Support

We are pleased to see a plethora of financial commitments in the VAWG strategy. This includes a commitment to £550 million in victim support services over the next three years, and the maintenance of existing funding with annual uplifts; £5 million each year from the Department of Health and Social Care; and £55.8 million in a new multiple disadvantage programme, a collaboration between the Department for Health and Social  Care, the Ministry of Justice, the Home Office and the Department for Work and Pensions.

We look forward to gaining further clarity about how by-and-for services will benefit from this funding, given the extent to which Black and minoritised women in particular, risk falling through the cracks in the struggles for better state responses to racial and gender equality.(6) We also encourage the Government to explicitly and clearly dedicate ringfenced funding for such services, who remain drastically underfunded, despite saving the state over £18,000 in some individual cases.(7)

We support the proposal to deliver a radical transformation of the commissioning landscape, to ensure that victims and survivors receive consistent, high-quality support, rather than be subject to a postcode lottery as is currently the case. 

The Government states that they recognise how immigration status can affect victims of VAWG and that many migrant and asylum-seeking victims will not come forward to report abuse out of fear about their future. This is an issue that frontline VAWG and migrants’ orgs have long issued concerns about. However, the Government’s solution to this issue, that they will introduce a requirement for police to seek a domestic abuse victim’s consent before sharing their information with Immigration Enforcement, ignores the substance of these concerns. We do not believe it is necessary for data to be collected for the implementation of these programmes, nor that the police should collect this information whatsoever. 

Moving forward

According to Government records, 5.1 million adults were affected by domestic abuse, stalking and sexual assault in the year ending March 2025.(8) This data does not include victim-survivors of other types of VAWG, including tech-facilitated gender-based violence.

Clearly, this issue is as urgent as ever. The success of the strategy will depend on the Government working effectively cross-department, with local councils, with victims-survivors, the frontline organisations supporting them and civil society organisations across the VAWG sector.

We will continue to monitor these efforts and to work with the Government to ensure that implementation of the strategy results in meaningful change for women and girls everywhere, and especially, for Black women and Black gender-expansive people. In particular, we hope to use the strategy as a key mechanism to see our campaign for a non-criminal redress scheme for intimate image abuse to be realised, and will be continuing to advocate for this over the coming year and beyond.

To support Glitch’s work as we hold the Government to account on these commitments, make a donation here. To get updates about our campaigns and research, as well as our analyses on UK, EU and global tech policy and legislation, sign up to our newsletter, The Download.


Endnotes

  1. VAWG Strategy. (2025) Freedom from Violence and Abuse: a cross-government strategy to build a safer society for women and girls Volume 1, https://assets.publishing.service.gov.uk/media/6943d2da9273c48f554cf592/VAWG_01_Strategy_FINAL_171225_WEB.pdf 

  2. VAWG Strategy.

  3. VAWG Strategy.

  4. Women and Equalities Committee. (2025) Tackling non-consensual intimate image abuse. https://publications.parliament.uk/pa/cm5901/cmselect/cmwomeq/336/report.html 

  5. Nwakanma, A.P. (2022) From Black Lives Matter to EndSARS: Women’s Socio-political Power and the Transnational Movement for Black Lives. https://www.cambridge.org/core/journals/perspectives-on-politics/article/abs/from-black-lives-matter-to-endsars-womens-sociopolitical-power-and-the-transnational-movement-for-black-lives/5B65728A08EEE5764326CD180681FCF5 

  6. Southall Black Sisters, in Beyond the Content Takedown. https://glitchcharity.co.uk/our-work/non-criminal-redress  

  7. Sheil, F. (2024) Investing In Safety: The financial case for investing in by and for services supporting victim-survivors with No Recourse to Public Funds. https://southallblacksisters.org.uk/app/uploads/2024/04/investing-in-safety-report-final.pdf

  8. VAWG Strategy.

Next
Next

Protecting Women and Girls’ Online - the Final Guidance from Ofcom - Our Response