Written evidence submitted by the UK Models Working Group (MISS0018)


1)     Legislate to ensure that mainstream media containing digitally altered images or videos contains a declaration of this.

2)     Legislate to prevent any person below the age of 18 from being able to sign to a model agency that represents adult models at all.

3)     Legislate to require companies provide declarations and additional information to customers on images portraying misleading images, such as non-pregnant models wearing foam bumps, or the pinning back of garments during a photoshoot.

The Models Working Group

1.      The UK Models Working Group is an informal group of models, clients and people with lived experience of the fashion and modelling industry, including those with experience of the protected characteristics described such as disability. We are responding to this inquiry to provide our unique and underrepresented perspective on the production of mainstream media ‘behind the perfect picture’, and how the modelling industry contributes to poor body image within the public. 


Who is particularly at risk of poor body image?

2.      The Mental Health Foundation’s research report on body image[1] found that ‘valuing and holding oneself against an unrealistic, ‘ideal’ body type is often referred to… as an ‘internationalisation of the ideal’ and is commonly linked to the development of poor body image through feeling of shame or distress when this ideal is not met.’ The report also found that ‘exposure to images of ‘idealised’ or unrealistic bodies through the media or social media, and pressure to look a certain way or to match an ‘ideal’ body type’ are contributing factors to perception of body image.

3.      As a result of this, we believe that the people who do not meet the ‘ideal’ body type commonly portrayed via the media are at risk of poor body image. The report states that ‘in Western cultures, it is common for the ‘ideal’ for women to be thin body shapes, but with maintained curves… while for men the ‘ideals’ are being taller and having a muscular body shape.’

4.      As models are typically used to represent the ‘ideal’ body type, we would support this generalisation, along with specific additions commonly required by the modelling industry. For women, these include ‘to be between a size six and eight, unless they are ‘plus-sized’, which starts at a size twelve. They are required to be above 5’8 in height (ideally 5’11”). There are no clear requirements for male models other than to be over 5’11” in height[2].’

5.      In addition to this, our experience has led us to believe that the ‘ideal’ body type would typically contrast with certain protected characteristics under the Equality Act 2010, therefore people who may face discrimination as a result of these characteristics would be at high risk of poor body image. For ease of reference, we will discuss these categories in relation to the modelling industry in further detail.


6.      A survey by the Model Alliance[3] (based in America) found that 1.3% of surveyed models began work aged 12 or under, and 54.7% of models between the ages of 13-16. 37.3% were found to have started their careers between the ages of 17-20, and 6.7% were found to have started at the age of 21 or over. This confirms our experience of the industry in the UK, where the majority of models that members have worked with are extremely young, either teenagers or in their early twenties.

7.      Though a licence[4] must be obtained from a local authority for a child under the age of 16 to be paid for modelling work in the UK, this does not prevent them from doing unpaid work such as fashion magazine editorials. Carole White, director of Premier model agency, has confirmed this, stating that ‘it’s common for girls to be scouted from the age of 13, although they won’t work…until they’re 15[5].’ This arguably has an impact not only on the young models themselves working as self-employed adults, but also on the public perception of body image in believing the models they see in the media are adults.

8.      As teenagers, our members have experience of modelling products and services aimed at adults. If target adult consumers are unaware that models are of a pubescent age, they may be comparing themselves to a literally unattainable body type. This would assume that people of an older age group may be particularly at risk of poor body image.

9.      In contrast to this, we also believe that young people are also particularly at risk of poor body image, due to their impressionability and extensive use of social media. The Mental Health Foundation’s report found that 40% of young people surveyed said that images on social media have caused them to worry in relation to their body image.

10.  We suggest that adults may be able to better identify unrealistic images in the media, whereas young people could be more impressionable and vulnerable to unrealistic as a result of their age. Regardless of the age of the model, this group of people could be affected by images portraying unattainable beauty standards, especially if photoshop has been used to digitally alter the image.


11.  In our experience, there is significant underrepresentation of black, indigenous and people of colour (‘BIPOC’) within the modelling industry, and correspondingly, in the mainstream media. As a result, we believe that BIPOC are particularly at risk of poor body image, due to a lack of true representation and the portrayal of unattainable standards of beauty.  The different aspects of this require extensive consideration to understand the structural, underlying causes.

a) Underrepresentation of BIPOC models and tokenism

12.  Our members have experienced or witnessed racism at work, such as being explicitly rejected from model agencies on the basis of race, being expected to bring their own make up to jobs and consistently being used as a ‘token’ model to fill a diversity quota, as confirmed by model Neelam Gill[6].

13.  A model agent at Storm Models, Joey Menson, has highlighted racism in the modelling industry, saying ‘agents and models [hold] black models to ridiculous beauty standards in comparison to their white counterparts[7].’ Storm Models[8] provided data on 22 June 2020 to show that 35% of their women’s board and 45% of their men’s board were BIPOC.

14.  Joey also highlights the lack of knowledge and experience by other professionals involved in the industry, such as hair stylists, who ‘avoid doing black girls’ hair on set/at a show or [do] a crappy job of it with the wrong products.’ This has been experienced by our members, who have regularly witnessed or experienced hair stylists, make-up artists and photographers being ill equipped to work with BIPOC models. We suggest that there may be underrepresentation of BIPOC professionals in the production of such media, combined with an absence of consideration of BIPOC perceptions at the planning stage of such work or within model agencies themselves if agents are mainly white.  Only 17% of Storm’s employees were found to be BIPOC, as opposed to 83% who were white.

15.  The recent increased media coverage of the ‘Black Lives Matter’ movement as a result of the murder of George Floyd in June 2020 has exemplified the systemic problems within the fashion industry’s handling of racial diversity[9]. Brands such as Urban Outfitters and L’Oreal have been accused of hypocrisy[10] in appearing to support the movement, whilst engaging in racially oppressive actions, such as the latter dropping model Munroe Bergdorf from a campaign in 2017 for speaking out about racism on social media.

b) Cultural appropriation and racial ambiguity 

16.  The appropriation of BIPOC cultures by the fashion industry, contrasted by the underrepresentation of such models, is troubling. One example can be seen by Gucci’s ‘blackface’ jumper[11], modelled by a white model.

17.  Tenai Steele has commented[12] on the racial ambiguity of models used by the brand Pretty Little Thing, ‘the majority, if not all, of the models on the website display a look of exoticism… having predominantly lighter pigmented women displaying features that correspond with Western beauty ideals as the representation of your brand is not diversity.’

18.  Tenai suggests that the brand ‘employed an exclusionary tactic to ensure profit, tapping into a socially conditioned sector of our brains… people of solely one race are made to self-reflect in a manner which forces them to question their own beauty and value, while people of multiple races are made to believe that their attraction stems only from this fact.’

19.  Model Jessica Clark[13] explains the prevalence of ethnic ambiguity within the industry, ‘many mainstream advertising companies… felt it was necessary to include a token non-white face in their campaigns. And it was rare that there’d be more than one of us at a time, so it fell on to us to appeal to most, if not all, of the vast range of non-Caucasian Americans. That meant that an "ethnic” model shouldn’t be too ethnically identifiable, and also shouldn’t alienate the traditional Caucasian consumer by being too dark-skinned, and therefore not “relatable”.’

20.  Jessica notes that during her career she has been portrayed as ‘Hispanic, Brazilian, Mixed race, Light-skinned African-American, Puerto Rican, Indian, Moroccan, Arabic, Egyptian, South and Central American, Italian [and] Spanish’, as described by clients at the time of booking as opposed to her own definition. We believe that brands using one person as a ‘catch all’ for the representation of BIPOC is damaging to their perception of body image, as they are not being properly represented in the media.


21.  We believe that people with disabilities are particularly at risk of poor body image due to a lack of representation in the mainstream media. 13.9 million people reported a disability in 2016/17[14], amounting to 22% of the UK’s population. Disabled model Kelly Knox comments that models with disabilities are the ‘most underrepresented group in fashion[15]’.

22.  Keah Brown[16] notes that ‘disabled people and disabled models are still left out of most campaign ads and runway shows. This lack of representation has implications: when you go so long without seeing yourself it is easy to interpret that lack of representation to mean you’re ugly and unworthy, that you deserve to be invisible or even worse, are grotesque. That erasure can have an impact on your mental health.’ 

23.  As Mindy Scheier[17] states, this neglect is partly as a result of a lack of education by brands and a fear of ‘insulting [by] not using the right words as it relates to people with disabilities.’ We believe the below are additional contributory factors:

a) Accessibility of the modelling industry for disabled people

24.  Our members report it being extremely difficult to break into the UK modelling industry, and disabled models are rarely represented by mainstream model agencies. There are a very limited number of agencies that focus wholly on representing disabled talent, although these are subject to difficulties as discussed further below. Our members reported being provided with a list of photographers by such an agency to shoot with in order to build a portfolio, however very few of these had accessible studios and were extremely expensive in comparison to other photographers.

25.  Models are generally expected to travel great distances, including regular international travel, as a part of their job. The location of a job is often not provided in advance of the evening prior to the job, and none of our bodily able members recall the accessibility of a job being discussed with them in advance. Our disabled members report that turning up to a job that they are unable to physically access, is demoralising, humiliating and prevents or discourages them from modelling.

26.  We advise that discussions about location accessibility are had in advance of confirming work for them, regardless of a model’s physical state. As further discussed, there are a spectrum of disabilities that may not be immediately obvious, which could prevent a person from being able to access a job.

27.  It is worth noting that models often are expected to work in very dangerous conditions with limited supervision. Anecdotally, our members have experienced dangerous situations where serious injury could occur, such as modelling with animals, on construction sites and underwater. As self-employed contractors, there is often no requirement for models to be covered by insurance when they are at work. In a similar vein to models who become pregnant, those who encounter an injury and/or disability are often prevented from working at all, even if they are still physically able to. 23-year-old Michelle Nilhill failed in a lawsuit against her Australian-based model agency when she fell off a cliff during a photoshoot, fracturing her pelvic and heel bones and leaving her in a wheelchair for three months[18]. She was unable to wear high heeled shoes again in the future, significantly impacting her career.

b) Tokenism and a lack of accessible fashion for disabled people

28.  In our experience, the use of disabled models has increased in recent years, though it has often been the focus of marketing in a way so that it ticks a one off ‘check-box’ as opposed to providing true, ongoing representation of disabled people.

29.  Our members report the experience of being highlighted as a disabled model as a morally conflicting scenario, in that they are sometimes asked to live up to an unrealistic image of disability, for example by sitting in a wheelchair that they do not need. Members have also reported being offered work for free that others would normally be paid for, which is discriminatory, yet difficult when they feel they should be ‘grateful’ for the opportunity to be represented.

30.  Tokenism is likely to also be prevalent due to a lack of mainstream representation of clothing for disabled people, as the model would be unable to wear the clothes with an able-bodied target audience.

31.  Stephanie Thomas[19] notes that there are more clothing lines for dogs than there are for disabled people, the latter which does not exist on a large scale. She draws on the differences required in clothes such as deadly body sores caused by pockets for those who spend their days predominantly sitting, sensory sensitivities to different types of fabrics experienced by an autistic person and the difficulties in buttoning a button for a person with dexterity challenges, amongst others. Also highlighted is the differences in sizing that may be required, for example by a person with very small feet, which is discussed in greater detail below.

32.  At the time of Stephanie’s speech (2016), there were fewer than 5 stores in the world with ‘clothing on the floor accessible for people with seated body types.’ Dr Frances Ryan[20] notes that ‘just because someone’s needs may be different does not mean their interests are’ in contrast to the blindness of fashion brands to considering people with disabilities as potential customers. It is notable that ASOS received widespread praise from the media[21] for producing a wheelchair friendly product in 2018. It is unclear whether such products have been produced by ASOS since.

33.  Following an audit into accessibility on the high street, Minister of State for Disabled People, Mark Harper, has called for British retail businesses to improve accessibility for disabled people, who have a combined spending power of over £200 billion[22]. The DisabledGo audit found that a fifth of retailers were inaccessible to wheelchair users, less than a third have accessible changing rooms or bathrooms for these users, and 91% of the 105 leading high street retailers provide no information about the level of accessibility at their stores online.

34.  We suggest that if disabled people are not being accounted for as customers, it proves highly unlikely that they would be represented by mainstream brands as a result, resulting in poor body image. An inquiry into the provision of adaptable clothing brands for people with disabilities in the UK would be highly welcomed.

c) ‘Invisible’ disabilities

35.  Stephanie Thomas notes that her ‘one thumb on right hand, three toes on one foot and four on the other’ means that she lives with what is often referred to as a ‘non-severe disability’. As previously mentioned, our members’ experience with disability modelling has often resulted in them being expected to ‘look’ disabled. We acknowledge the difficulties involved in modelling ‘invisible’ disabilities on a representative scale in the media, and suggest the issue is on a systemic scale, such as a failure to provide different sizes of clothes outside of the commonly accepted sizes 8-16.

36.  This lack of representation and awareness may result in people with disabilities being prevented from entering the modelling industry, due to the lack of accessibility previously described for such people. This has the obvious knock-on effect of customers with ‘non-severe’ disabilities not being represented in mainstream media, which may result in poor body image as they feel that their disability is not accepted. Our members report feeling as though their disability was not accepted as a ‘real’ disability and feeling completely underrepresented in the media.

37.  Furthermore, we believe that people who are susceptible to mental disabilities in the form of mental health conditions, are at risk of suffering poor body image due to the vulnerabilities inherent in such conditions that may distort the way such people consume unrealistic beauty standards portrayed in the media. For example, people who suffer from eating disorders may be negatively impacted by the portrayal of unattainable body types as ‘normal’, which is discussed further below.

Gender reassignment

38.  We further believe that transgender people are at risk of poor body image due to a lack of representation by the mainstream media, our members having rarely encountered transgender models in the industry. Stonewall[23] estimates there to be approximately 600,000 trans and non-binary people in the UK, around 1% of the population, commenting on the lack of research conducted or mention of this in the census.

39.  The transphobic comments of Victoria’s Secret CMO Ed Razek regarding the casting transsexual models[24] attracted extensive media coverage, (which resulted in his leaving the role and the hiring of a transgender model) demonstrate the underlying resistance towards representing trans people in the mainstream media.

40.  Hanna McDonough[25] notes that ‘transgender people were the least represented group in fashion in 2017, with a mere 12 appearances by trans models in fashion week shows.’ Concerns are further raised that 'the motives behind fashion brands in their inclusion of transgender people are unfortunately not always genuine and in some cases… used to fill a ‘trans quota’. Munroe Bergdorf[26] further adds, ‘it’s important that your team is as diverse as the people you’re putting in front of the camera’.

41.  In addition to this, there may be similar issues as previously discussed with regard to the provision of a range of clothing for transgender people and the intended target audience. Although is positive to see the sale of unisex clothing brands by ASOS[27], it is concerning that the first transgender lingerie line was created as recently as 2019. Carmen Liu[28] was frustrated by the ‘perceived “woke-washing” of brands who tried to appear LGBTQ-friendly while failing to cater to her community’s specific needs.’ She observes that ‘there are many brands out there that will use trans individuals as a selfish marketing ploy, yet they do not cater for us… we have specific design needs and we need to be heard and catered for.'

42.  We further note here the practicalities of the modelling industry that may be a barrier to access for transgender people and those in general who may have sensitives about their body. It is widely accepted by our members that models are expected to change in front of strangers as a normal part of their job, for example at castings and jobs where no changing rooms are provided. Changing rooms were provided at New York Fashion week for the first time in 2018[29], yet no such provisions have been brought into force in the UK[30].

43.  Our members have commonly experienced being photographed whilst changing backstage at jobs and a sense of becoming desensitised to nudity as a result. Individual dressers are often provided for on jobs, which means being in close proximity to a stranger whilst being undressed. Such expectations and experiences within the industry could be extremely damaging for any person. UK law currently requires trans people to live in their chosen gender for two years prior to undergoing transition surgery[31]. This would undoubtedly cause increased sensitives for those whose anatomy does not match their gender identity if they are required to undress in front of strangers.

44.  We strongly advise that the Government consider legislating to ensure that models are provided with changing rooms whilst at work, not only in the context of transgender models as discussed, but to provide basic respect and dignity for all models. 

Pregnancy and maternity

45.  Our members have had experiences modelling maternity wear whilst not being pregnant, which is common practice within the modelling industry. As a result, we believe that pregnant women are at risk of poor body image due to a lack of proper representation and the portrayal of unrealistic and misleading body standards whilst pregnant.

46.  Model Louise Boyce[32] highlights that ‘when a model becomes pregnant, generally her career is over by the time the bump starts to show – and the maternity clothing you see is modelled on a girl with a foam bump’. Following extensive media coverage[33] of non-pregnant model Arabella Chi modelling maternity wear in 2019, ASOS began to provide disclaimers on images depicting non-pregnant models as pregnant.

47.  The provision of such declarations is not mandatory or regular practice for brands, and we strongly recommend that the Government consider legislating to change this. We imagine that pregnant women are highly susceptible to poor body image due to the changes their bodies undergo during pregnancy and potential for post-natal depression to occur. Any measures that could assist with this should be considered by the Government and such declarations would be easily monitorable, effective and proportionate.

What contributes to poor body image?

48.  The Mental Health Foundation’s report suggests a variety of contributory factors we support, including media and social media. Focusing on this, we suggest that a lack of representation in the media of different protected characteristics of a person as discussed above is a contributory factor. For those who are represented to a limited extent, we believe that unrealistic and unattainable standards of beauty portrayed through the media and social media are a significant factor in causing poor body image.

49.  We would like to use this opportunity to demonstrate how these standards are largely unattainable and unrealistic in the context of the models who seem to be perpetuating them.

Body type

50.  As previously mentioned, female models generally are required to be between a size 6-8 or if they are ‘plus-sized’, a size 12 and above, and above 5’8”. Male models are expected to be above 5’11”.

51.  Our members have experienced significant pressure to lose weight by their agencies, the pressures of which have been well documented in the media. Some models are prevented from working until measurements have been met, whilst others have been told to undertake dangerous practices such as only eating grapes until 3pm[34]. As models are already naturally thin by virtue of their body type, it is extremely difficult for many to lose weight, which is often instructed in terms of specific measurements on the body as opposed to literal weight. They also are more likely to have increased opportunity to exercise and focus on their bodies if modelling is their main career, as opposed to a member of the general public who is not a model. 

52.  The average female dress size in the UK is a size 16[35]. It is therefore highly likely that the majority of people could feel inadequate in comparison to the models they see in the mainstream media. As plus sized modelling typically begins at a size 12, this further arguably distorts the perception of people who are this dress size and above, in addition that of plus-sized females.

53.  Members of the Working Group who own a body-image conscious brand[36] have reported a lack of ability to produce a range of sizes due to factory requirements. The lack of size inclusivity has been reported upon[37], as out of 8367 available products Net-A-Porter was found to offer ‘only 67 products which translates to 0.8% of the total offering… in a size 14 or above, completely excluding at least 45% of British women who wear dress size 16 and limiting the choice to less than 1 in 100 pieces for ‘XXXL’ shoppers who wear a size 14.’

54.  Amelia Curwen[38] further observes that ‘while the high street offers broader ‘plus size’ ranges, it suffers a lack of size standardisation, which when coupled with poor quality mass manufacturing, has led to cripplingly high return rates for retailers and stark inconsistencies in sizing.’ Our members have experienced sample sizes to generally be between a size 8-10, which we recommend could be standardised in the UK to increase certainty and accurate representation for the public.

55.  Our members can confirm the ambiguity regarding sizing, as clothes are often pinned or clipped back on photoshoots to appear differently than how they are in reality. An example of this can be seen in Boohoo’s campaign[39], with a clip visible on a model’s dress. We recommend practices such as this are declared alongside publication of such media. 

56.  The average height of a woman in England is said to be 5’3”, and for men, 5’9”[40]. This provides further distortion in terms of body image, as height is often indistinguishable in media images. Members have further experienced a misrepresentation of their sizes and measurements in statements on clothing websites, for example with a 5’11 model being advertised as ‘petite’. We assume that this directly correlates with consumers feeling negatively if they are purchasing clothes based on misrepresentation of measurements and appearances.

57.  We also have experienced the increased use of cosmetic surgery by models in recent years in response to changing demands by clients. Lottie Moss has spoken publicly[41] about her breast implant and lip filler surgery, which allows her 300,000 plus Instagram followers to be fully aware of the processes she has undertaken to achieve her body type. This is a sensitive issue which requires careful consideration, as models are under no obligation to declare whether they have had cosmetic surgery to a client, who is under no obligation to declare this to their target audience.

58.  We believe that the unrealistic body standards required by the modelling industry has a direct impact on the poor body image in the public. Though these standards are often simply unattainable for the majority of people, this is not made clear to those who are consuming the media and may subconsciously feel that this is how they ‘should’ be.

Digital manipulation of images via retouching

59.  In our experience, retouching of images has been regularly and consistently used in the mainstream media to alter the way that models look, often to perfect ‘flaws’ such as stretch marks and skin blemishes. Our members have experienced their features being digitally altered to the extent that they are unrecognisable, which is not communicated to the target audience and results in negative body image for the models themselves. An example of photoshop can be seen by Boohoo, who digitally altered a size 10 model’s waist to be thinner[42].

60.  This is further exacerbated in terms of social media, as the production of easy to use retouching apps has enabled people to digitally alter their own images[43]. In the pressure to ‘sell’ themselves on social media to clients, some of our members have also used these apps to portray a further perfected image of themselves online which they have reported was addictive, causing them to experience poor body image overall.

61.  We recognise that it is very difficult to regulate user generated content but suggest that the motivation to digitally alter oneself would be reduced if the broader standards of beauty perpetuated by the mainstream media were more honest.

62.  In 2017, France legislated[44] to require declarations on media images which have been changed to reflect a thinner or thicker body than was initially photographed, with potential fines and up to six months in prison. We believe a similar measure in the UK, requiring a declaration when any retouching or digital alterations have been done to an image or video, would have an extremely positive effect on body image for the general public.

What are the long-term effects of poor body image on people?

63.  The Mental Health Foundation’s report provides an excellent summary of the long-term effects of poor body image on people, including a range of mental health conditions. From our experience, we have overwhelmingly experienced and witnessed disordered eating, low self-esteem and body dysmorphia as a result of poor body image.

What is the impact of media consumption on peoples body image, does it impact their mental health?

64.  We would assume that media consumption directly affects people’s body image and mental health, as it is specifically targeted to achieve sales. As a generalisation, if a person is happy with their body image, they would presumably have fewer reasons to purchase products related to their body. By this, the media could be suggested to be creating ‘problems’ deliberately to encourage spending money in the aim of fixing these, which Rose Hackman refers to as ‘body-shaming-for-profit’[45].

65.  Members who own a clothing brand[46] have described the difficulty encountered in marketing their products, as emphasis is typically focused on ‘improvement’ of the consumer. They have reported that their marketing aims to focus on inspiring consumers via the women who wear their clothes, as opposed to ‘fixing’ a problem within themselves.

What is the effect of the following on peoples body image when using social media?


        User-generated content (posts from friends)

        User-generated content (posts from celebrities)

        Content promoting eating disorders and diet culture

        Content promoting cosmetic surgery/interventions

  1. We believe that the underlying effect on body image in this context relates to how achievable an image may appear to the person in question. If an image is clearly unrealistic (such as an obviously fake maternity bump used on a model) or marked as such, this may reduce pressure on the audience of such media. However, if it appears realistic, such as user generated content from friends, this may place more pressure on the viewer to feel that they should be able to achieve the standards met by their peers.
  2. Social media is damaging in this regard as it is easily accessible, addictive and lacks transparency with regard to the declaration of unrealistic or digitally altered content. Even the psychological pressure to be ‘popular’ by virtue of the number of followers can impact body image in this regard, as we note the increase of popularity on social media of content of a highly sexual nature. This can result in exploitation, as seen by the photographer Marcus Hyde, who pressured a model to send nude photographs or pay $2000 in order to do a photoshoot together[47].
  3. It is important for the general public to be made aware that followers and likes can easily be purchased. Some of our members have experienced pressure by their agencies to purchase fake followers in order to portray a sense of popularity in order to book more modelling work. Further to this, images can easily be digitally manipulated, and people may be being paid to promote businesses which is not always disclosed[48]
  4. We suggest that efforts are made to educate the public, especially young people, about the realities of social media. Given the inherent difficulties of regulating user-generated content, we recommend focusing legislation on the mainstream media to portray honest, realistic depictions of beauty as an overarching standard in society.

Has Government policy had an impact on improving body image?

  1. Not in our experience. We would here note the removal of licensing obligations for model agencies with the Deregulation and Contracting Out Act 1994[49]. This deregulation has allowed anybody to set up a modelling agency without Government oversight, which has had knock-on effects for the overall safety and wellbeing of models, many of whom are extremely young. This could be said to have had a corresponding effect on body image in general, as the industry is not regulated to a high standard and so dangerous practices are permitted to happen. Leanne Maskell recorded over 10,000 models represented by London based model agencies in ‘The Model Manifesto’.
  2. Furthermore, as previously mentioned, some models who have been represented by ‘inclusive’ agencies representing disabled models, for example, have experienced discriminatory practices in the industry. Such members have faced significant expectations and pressure to work for free or at largely reduced rates to what is considered ‘normal’ in the industry. Our members have observed the drastic reduction in rates of pay for models over recent years, and experienced significant practices of new, smaller agencies undercutting others in price.
  3. Whilst this is dependent on a number of factors including the structure of a free market, it is worth considering the potential exploitation of those who traditionally have been excluded from the modelling industry at the expense of ‘inclusion’. This could create the anomaly of increased representation and inclusion of diverse models in the industry whilst simultaneously discriminating against these people, resulting in a perverse ‘pay gap’.
  4. Many models are expected to work for free as a normal part of their job, with rates of pay ranging vastly for different models doing the same work. The decision of the Competition and Markets Authority on model agencies[50] has arguably contributed to this as five agencies were fined £1,533,500 for price collusion. Whilst greater transparency and accessibility is welcomed, we suggest this should not be at the expense of vulnerable, new models who may be unaware of standard rates of pay in the industry. The provision of information to the public about standard or minimum rates of pay for models would address this.
  5. Further to the comprehensive problems facing models discussed in this response, we do not believe that self-regulation of the industry is adequate. The British Fashion Model Agents Association[51] represents a very small proportion of agencies and is reportedly unable to represent leading internationally based model agencies operating in the UK. Members have also reported a significant lack of awareness in general by models of the union organisation Equity[52], who offer vital protection to models.
  6. We strongly believe that the modelling industry and overall benefit to the public in terms of body image would be improved with increased regulation of the industry via Government legislation. Given the complications involved in the industry, we would be happy to discuss this further if relevant and believe that models themselves should be involved in any conversation of this kind as opposed to solely model agencies.

What strategy should the Government take to encourage healthy body image for young people?

  1. Some of our members were involved in the work of the All Parliamentary Group on Body Image in 2015 which discussed monitoring the Body Mass Index or conducting regular health checks of fashion models. We do not support this as a solution to the issues discussed within this response because it is extremely difficult to measure health, particularly for models who vary broadly in age and height. In France, women entering the profession legally require a doctor’s certificate to confirm their good health[53], in response to which members anecdotally report models placing weights in their pockets or binge eating for such assessments. 
  2. A strategy of this kind also focuses on regulating models themselves in practice (despite the potential for sanctions against agents[54]), placing them under additional pressure, as opposed to tackling the broader, structural issues within the industry. Many models find themselves subject to agency debt of unimaginable amounts without their advance permission or knowledge, which then renders them powerless in the face of body-image related pressures.
  3. Though we have made many suggestions within this response (which are annexed for ease of reference), we recognise the difficulties involved in legislating on such matters. Therefore, we have focused our formal recommendations on the below, in light of these being practical, reasonable and effective measures that can be taken by the Government focusing on encouraging healthy body image for young people.

We recommend that the Government legislate to:

We suggest such measures could be incorporated under the Consumer Protection from Unfair Trading Regulations 2008 and/or accompanying guidance.  

  1. We believe that the provision of guidance for stakeholders involved in mainstream media production, such as fashion brands, model agencies and models themselves, would be highly effective as a non-legislative measure. This could focus on body image, whilst tackling the underlying issues discussed in this response, such as the accessibility and safety of modelling jobs, including the provision of changing rooms.
  2. We would welcome further involvement and discussion as to a wider Government strategy on body image and/or the modelling industry, implementing any of our proposed suggestions, recommendations or alternative measures that could be taken.


Annex Summary of Recommendations


        1. Legislate to ensure that mainstream media containing digitally altered images or videos of any kind contains a declaration of this.

        2. Legislate to prevent any person below the age of 18 from being able to sign to a model agency that represents adult models at all.
        3. Ensure that child modelling provisions clearly state that any modelling a child does under the age of 18 is to be specifically targeted at people of the same age range.


        1. Inquire into the provision of adaptable clothing brands for people with disabilities in the UK.
        2. Consider methods for models to be adequately informed about their work in advance, including accessibility of jobs.


Gender Reassignment

        1. Legislate to provide changing rooms for models at work.


Pregnancy and maternity

        1. Legislate to require companies provide declarations when using non-pregnant models to portray pregnant women.

          Body type
        2. Legislate to require companies provide declarations on media where clothes have been materially altered during a photoshoot, such as being clipped back on a model.
        3. Inquire into the production of clothing in the UK, including the provision of differing sizes by factories.
        4. Legislate to standardise the measurements of clothing sizes in the UK to ensure accuracy and confidence in consumers.


        1. Increase regulation of the modelling industry at a Government level.
        2. Consider providing publicly available information about standard or recommended rates of pay for models to ensure transparency and equality for new models.
        3. Consider mandating Equity membership for models who wish to join agencies. 
        4. Consider an education campaign for the public, particularly young people, about the realities of social media use, including the acquisition of fake followers and dangerous effects it can have on their mental health.
        5. Consider producing guidance for stakeholders involved in mainstream media production, such as fashion brands, model agencies and models. This could focus on body image, whilst tackling the underlying issues discussed in this response, such as the accessibility and safety of modelling jobs, including the provision of changing rooms.



June 2020




[1] https://www.mentalhealth.org.uk/sites/default/files/DqVNbWRVvpAPQzw.pdf

[2] page 116, ‘The Model Manifesto’, Leanne Maskell

[3] https://modelalliance.org/industry-analysis

[4] The Children (Performances and Activities) (England) Regulations 2014

[5] https://www.theguardian.com/fashion/2012/jan/21/damaging-child-modelling

[6] https://www.stylist.co.uk/people/neelam-gill-model-interview-racism-fashion-industry/266526

[7] https://www.instagram.com/p/CBBjiYEgBFi/, 5th June 2020

[8] https://www.instagram.com/p/CBu5QS7jYOi/

[9] https://www.dazeddigital.com/fashion/article/49454/1/fashion-brands-black-lives-matter-protest-responses-donations

[10] https://inews.co.uk/news/black-lives-matter-george-floyd-hypocritical-brands-munroe-bergdorf-433188

[11] https://www.bbc.co.uk/news/business-47153413

[12] https://theboar.org/2019/12/pretty-little-thing/

[13] https://modelalliance.org/2012/selling-ethnic-ambiguity/selling-ethnic-ambiguity

[14] https://assets.publishing.service.gov.uk/government/uploads/system/uploads/attachment_data/file/692771/family-resources-survey-2016-17.pdf

[15] https://www.huffingtonpost.co.uk/kelly-knox/fashion-for-all-models-with-disabilities_b_9291520.html

[16] https://www.teenvogue.com/story/cover-story-representation-fashion-industry-jillian-mercado-mama-cax-chelsea-warner

[17] Ibid, 16

[18] https://www.dailymail.co.uk/news/article-8247859/Model-23-plunged-cliff-photoshoot-tries-sue-Double-Bay-agency.html

[19] https://www.youtube.com/watch?v=B_P9pu8gytI&app=desktop

[20] https://www.theguardian.com/society/2018/jun/18/why-are-there-more-clothing-lines-for-dogs-than-disabled-people

[21] https://www.independent.co.uk/life-style/fashion/asos-wheelchair-users-disabled-fashion-jumpsuit-online-shopping-a8432351.html

[22] https://www.gov.uk/government/news/government-concerned-at-shocking-evidence-of-the-inaccessibility-of-the-british-high-street-to-disabled-people-despite-their-200-billion-spending

[23] https://www.stonewall.org.uk/truth-about-trans#trans-people-britain

[24] https://www.vogue.com/article/victorias-secret-ed-razek-monica-mitro-interview

[25] https://mindlessmag.com/2020/02/11/the-representation-of-the-transgender-community-in-fashion/

[26] Ibid, 25

[27] https://www.asos.com/women/a-to-z-of-brands/collusion/cat/?cid=28477

[28] https://www.forbes.com/sites/frankicookney/2019/11/14/the-worlds-first-lingerie-brand-for-transgender-women-is-here/#2006938922a6

[29] https://www.telegraph.co.uk/news/2018/02/08/models-new-york-fashion-week-get-changing-rooms-first-time-metoo/

[30] https://www.dazeddigital.com/fashion/article/41380/1/edie-campbell-urged-fashion-shows-to-provide-changing-rooms-model-lfw

[31] https://assets.publishing.service.gov.uk/government/uploads/system/uploads/attachment_data/file/721642/GEO-LGBT-factsheet.pdf

[32] http://mamastillgotit.com/the-truth-behind-maternity-modelling/

[33] https://www.theguardian.com/fashion/shortcuts/2019/jun/26/love-island-arabella-chi-fake-bump-asos-maternity-wear

[34] Page121, ‘The Model Manifesto’, Leanne Maskell

[35] https://yougov.co.uk/topics/politics/articles-reports/2013/11/20/size-12-britains-ideal-dress-size

[36] https://www.careaux.com

[37] https://www.fashionroundtable.co.uk/news/2019/7/23/sw59k3966v6yxoy6t7fj61f8pas4ed

[38] Ibid, 37

[39] https://www.cosmopolitan.com/uk/fashion/celebrity/a30193897/boohoos-party-campaign-jasmine-tookes-photoshop/

[40] https://www.bbc.co.uk/news/uk-11534042#:~:text=The%20ONS%20said%20the%20average,3in%20tall%20(161.6cm).

[41] https://www.dailymail.co.uk/tvshowbiz/article-7548315/SEBASTIAN-SHAKESPEARE-Lottie-Moss-reveals-boob-job-regrets-getting-lip-fillers.html

[42] https://www.independent.co.uk/life-style/fashion/boohoo-accused-photoshop-model-thinner-size-10-facebook-a8497101.html

[43] https://observer.com/2019/08/photoshop-apps-false-physical-narratives-psychological-effects/

[44] https://www.teenvogue.com/story/photoshop-is-now-illegal-in-france#:~:text=France%20is%20taking%20a%20legal,into%20effect%20officially%20on%20Sunday.

[45] https://www.theguardian.com/us-news/2015/jun/27/beach-body-ready-america-weight-loss-ad-instagram

[46] Ibid, 36

[47] https://wwd.com/fashion-news/fashion-scoops/marcus-hyde-photographer-allegations-sexual-assault-everything-to-know-1203225790/

[48] https://www.bbc.co.uk/news/46945662

[49] http://www.legislation.gov.uk/ukpga/1994/40/contents

[50] https://assets.publishing.service.gov.uk/media/58d8eb1840f0b606e7000030/modelling-sector-infringement-decision.pdf

[51] https://bfma.fashion/

[52] https://www.equity.org.uk/getting-involved/networks/models-network/

[53] https://www.bbc.com/news/world-europe-39821036#:~:text=A%20law%20in%20France%20banning,weight%20in%20relation%20to%20height.

[54] https://www.theguardian.com/fashion/2017/may/06/fashion-models-france-doctors-note-thin-health-photographs