EU Moves to Regulate AI Nudification, But Key Challenges Remain
Source: Tech Policy
The recent Grok scandal saw an avalanche of non-consensual sexualized deepfakes of women and girls created and shared directly on X, following the rollout of Grok’s picture-editing capabilities in late December 2025.
This provided a crucial opportunity to test the effectiveness of the existing EU legislative framework to prevent and address non-consensual intimate imagery (NCII) and child sexual abuse material (CSAM). Investigations into X were opened almost immediately under both the Digital Services Act (DSA) and the General Data Protection Regulation (GDPR). At the same time, calls for additional safeguards and protections under EU law echoed across the Union, leading to the European Parliament and the European Council remarkably coming together to introduce a ban on such practices under the AI Act and pushing for additional restrictions against a rising tide of deregulation.
In a recent brief, the Centre for Democracy and Technology Europe explored the merits and gaps of existing legislation to address this issue. Building on that analysis, we reflect on the existing safeguards, the opportunities, and the challenges that a new ban under the AI Act would need to overcome.
The recent Grok scandal saw an avalanche of non-consensual sexualized deepfakes of women and girls created and shared directly on X, following the rollout of Grok’s picture-editing capabilities in late December 2025.
This provided a crucial opportunity to test the effectiveness of the existing EU legislative framework to prevent and address non-consensual intimate imagery (NCII) and child sexual abuse material (CSAM). Investigations into X were opened almost immediately under both the Digital Services Act (DSA) and the General Data Protection Regulation (GDPR). At the same time, calls for additional safeguards and protections under EU law echoed across the Union, leading to the European Parliament and the European Council remarkably coming together to introduce a ban on such practices under the AI Act and pushing for additional restrictions against a rising tide of deregulation.
In a recent brief, the Centre for Democracy and Technology Europe explored the merits and gaps of existing legislation to address this issue. Building on that analysis, we reflect on the existing safeguards, the opportunities, and the challenges that a new ban under the AI Act would need to overcome.