Dreams of Spanking and the new UK porn laws

Where I’m starting from

A few of you have written to me to ask my opinion on the new porn rules in the Crime and Policing Act 2026, including members of Dreams of Spanking who are worried that the films they’ve already downloaded could count as possession offences. I’m answering here so I don’t keep having to reply individually.

I’m not a lawyer, this isn’t legal advice, and the official guidance that would make this clearer hasn’t been written yet. All I’ve got behind me is 20 years of making this kind of porn in the UK and a working familiarity with the legislation (I’ve been campaigning around porn and obscenity law for over a decade). There are some things that seem quite clear, and other places where I’m guessing. I’ll be clear which is which.

What the law actually says

From 6 November 2026 it becomes a criminal offence in England and Wales to possess or publish pornographic images that explicitly and realistically depict any of three things:

1. Strangulation or suffocation.
2. Penetrative sex between people a reasonable person would think are close relatives, or pretending to be close relatives (parent and child, siblings, grandparents, aunts and uncles, nieces and nephews), plus step and foster relationships where one person is, or is pretending to be, under 18.
3. Sexual activity between at least two people where a reasonable person would think at least one of them is, or is pretending to be, under 16.

All three only apply where the people shown would look real to a reasonable person. They cover images and video, not written erotica.

Possession carries a maximum of 2 years (strangulation, incest) or 3 years (under-16 roleplay). Publication carries up to 5 years for all three.

The details that matter for our purposes:

• “Penetrative sex”: Spanking scenes and other porn that doesn’t include penetration of the mouth, anus, or genitals, are not covered by the incest clause.
• “At least two people”: Solo “age play” content is not covered by the under-16 clause, only multi-performer scenes.
• “Sexual activity”: We can probably assume that for the purposes of the act, any material created primarily for the purposes of sexual arousal is going to count as depicting “sexual activity” for the purposes of the under-16 clause, not only genital sex.
• “Pretending to be under 16” : The Act says people are not to be taken as pretending to be under 16 if it is fanciful that they actually are under 16, in the way pretended. The government’s memorandum on the Bill explicitly states that an adult in a nappy pretending to be a baby is not covered, because that’s about regression and humiliation rather than the sexualisation of children. It also explicitly states that the offence is not intended to catch someone who is clearly an adult where the only marker of childhood is a school uniform.
• The defences: You can defend possession and publication if you can demonstrate a “legitimate reason” for keeping or disseminating the image (no idea what that means); not having seen the image and having no cause to suspect what it was; or having been sent it unsolicited and deleted it within a reasonable timeframe.
• There’s also a participant defence which is relevant to content creators and online sex workers: you’re allowed to possess an image where you were in the scene yourself, nobody suffered non-consensual harm, and nobody was actually related or under 16. This only covers possession, but it means that sex workers who delete their content from platforms are still allowed to keep it on their hard drives as long as they’re in the scene. You can defend “publication” this way to the extend of sharing it with the other participants in the scene.
• Strangulation and suffocation aren’t defined. The guidance says strangulation will generally mean one person applying pressure to another’s neck, and suffocation means depriving someone of air, for example covering mouth and nose or compressing the chest. Whether a given image depicts either is “a question of fact for the court in each case”, which is a polite way of saying nobody knows until someone is prosecuted.
• Where it applies. These are England and Wales offences. The strangulation offence also covers Northern Ireland, and Scotland has its own version. Possession is about where you are, not where the site is hosted.
• Possession is a continuing act, and there is no amnesty for old files. The government’s own guidance says possession means a file you control: stored on a device, kept in a cloud account, saved anywhere. If you hold something these offences cover, you have to delete it before 6 November to avoid committing an offence from that date.
• Ofcom is not the police. Ofcom has told us that it will consult on guidance for platforms in the first half of 2027, and won’t enforce against porn platforms until that guidance is final. That’s in their remit as enforcers of the Online Safety Act, during which they could be expected to notice if people are breaking these new laws. The criminal offences are enforced by police and the CPS from 6 November, not by Ofcom, so individuals could face possession or publication charges from that date.

What this means for Dreams of Spanking

We’ve been through the catalogue with these three offences in hand. This is our best interpretation of how the law applies to us.

Incest doesn’t apply.

The offence requires explicit, realistic penetrative sex. There are only a couple of penetrative sex scenes on Dreams of Spanking, and none of them involve familial roleplay, so our domestic spanking scenes with implied familial relationships are outside it entirely. In any case, we tend to prefer to keep that stuff suggested rather than stated, and let viewers bring their own interpretation.

Strangulation and suffocation

After chatting to the team, the only scene we can think of that goes hard into breath play is The Morpheus Club: Going Deeper, where Zoe Page puts her hand over Rosie’s mouth and nose while smacking her breasts. That’s going to be a wrench to lose (it’s super hot!) but it’s pretty inarguable.

Otherwise we only have a couple of instances: a hand on Zahra’s neck in Spanking Zahra Stardust, and a whip briefly wrapped round Ron’s neck in The Beastmaster.

In all three cases (and any other we come across), we’ll be re-editing the films to cut out those moments. When the new versions are live I’ll post and ask customers to delete their old copies and download the new version.

Adults in school uniform and playing Big/little scenes

These are the only two categories on the site that could even arguably fall under the under-16 offence. Three things reassure me:

• The offence needs sexual activity between at least two people, so solo scenes aren’t in scope.
• The government has said in plain terms that school uniform on a clearly adult performer isn’t enough on its own to break the law.
• Our performers are adults, and look like adults. Nobody on the site is under 18, and we have the paperwork to prove it.

What concerns me is the gap between “clearly adult” and “fanciful”. A nappy is fanciful. What about a performer in pigtails, a cute dress, or a onesie, holding a teddy?

With performers who are visibly mature – tall, tattoos, piercings, body hair, big breasts, stubble – I’m less worried. But some of our performers who were in their twenties at the time of filming do look younger. Not 15, in my opinion, but I don’t want to take unnecessary risks.

The Act lets the “reasonable person” take into account information published with the image. So we’ll be going back into school uniform and Big/little scenes and asking our more youthful performers to record a short on-camera statement which we can add to the start of their scenes, stating their name, their age now, their age when the scene was shot, and the fact that they’re playing an adult (either an adult in a consensual Big/little roleplay, or character in the sixth form or at university).

What this means for you

Possession means custody or control: the files on your hard drive, in your cloud, in your downloads folder. If a film is up on our site, streaming it doesn’t put you in “possession” of it; only downloading it.

If you want to be as safe as it’s possible to be, here is what I’d do:

1. The three films mentioned above. If you have The Morpheus Club: Going Deeper, Spanking Zahra Stardust or The Beastmaster downloaded, delete them now and replace them with the edited versions once they’re ready (which we’ll do before 6 November).
2. School uniform and Big/little scenes. My personal guess is that these aren’t covered, but if you disagree, go through your downloads and delete anything where you, as a reasonable person, would say the performer is pretending to be a child under 16 rather than a sixth-former or an adult doing age regression roleplay. Keep the rest.

Nothing else on the site is in any of the three categories. Spanking, caning, discipline roleplay between adults, implied family scenes without penetration, solo scenes: none of it is touched by this Act.

If you’re in Scotland or Northern Ireland, only the strangulation offence reaches you. If you’re outside the UK, none of this applies to you at all.

Other sites are a different matter. I can’t speak for anyone else’s catalogue, but it’s worth knowing that the “teen” and “step” categories that fill the tube sites are exactly what this law was written to hit, and penetrative step-family content is squarely inside it.

A word on proportion. When the extreme pornography law came in in 2008 the kink community braced for a wave of prosecutions of consensual BDSM content. But research by Clare McGlynn and Hannah Bows in 2019, using police data, found that 85% of charges under that law related to bestiality images, with images of ‘serious injury’ making up 7% and ‘life-threatening acts’ 6%.

In practice, possession cases under the extreme porn law have mostly arisen when devices were seized for other reasons.

That isn’t a reason for complacency, and new laws attract new enthusiasm from prosecutors. But it’s worth pointing out, because a lot of people are freaking out.

This fucking sucks

Nothing about this covers illegal acts. Two adults can put on school uniform and spank each other – yes, even if one of them is pretending to be 15! A consenting couple can do breath play. You can call your boyfriend “Daddy” while he fucks you. None of that is illegal.

The government has decided it is fine for you to do these things, but a crime to possess a picture of them.

Why? Because the picture might ‘normalise’ abuse? The government’s own memorandum admits the evidence for that theory is “limited” in places.

Look, we’ve been here before. The 2014 regulations tried to ban spanking, caning and face-sitting from British porn on exactly this logic, and in 2015 ATVOD shut Dreams of Spanking down over it. I took that to Ofcom and won. Ofcom haven’t gone after anyone for those things since ATVOD was disbanded.

Eleven years on, we’re circling the same drain: criminalising porn depicting consenting adults doing legal things.

The most stressful thing about all this is the lack of clarity. “Strangulation” is undefined. “Fanciful” is undefined. “Sexual activity” is undefined! The whole structure rests on “what a reasonable person would think”, and you only find out what the “reasonable person” thinks once the jury has delivered their verdict.

Ofcom will consult on guidance next year. The CPS haven’t issued their guidance yet. But this stuff becomes illegal in ten days.

Ethical, consent-led producers and content creators are panicking, worried they’re going to be imprisoned, and scrambling to review our catalogues and make badly-informed legal decisions with insanely high stakes.

Meanwhile, the dodgy porn sites this was supposedly aimed at will carry on until a regulator gets round to them in 2027 or later.

Sources

• Crime and Policing Act 2026: Offences relating to pornography (Ministry of Justice guidance, 16 October 2026): the offences, penalties, possession as a continuing act, definitions of strangulation and suffocation.
• Crime and Policing Bill: ECHR supplementary memorandum, 10 April 2026: the fanciful carve-out, the nappy and school uniform examples, the defences, the evidence base.
• Crime and Policing Act 2026, explanatory notes, from paragraph 964.
• Neil Brown, Brief comments on two proposed new criminal offences relating to pornography (decoded.legal, April 2026).
• McGlynn and Bows, Possessing Extreme Pornography: Policing, Prosecutions and the Need for Reform, Journal of Criminal Law (2019): FOI data on what the 2008 offence has actually been used against.
• Image: I Must Not Impersonate A Schoolgirl