
Slow Regulation on AI-Generated CSAM is Failing its Victims
Artificial intelligence is reshaping the production of child sexual abuse material (CSAM) online, enabling new forms of exploitation that are outpacing the legal and regulatory frameworks designed to contain them.

“I just love knowing that the quality… as great as it is at this point, it’s only going to get better!” A random user shares his excitement about a new generative AI tool, without mentioning the gruesome and disturbing purpose for which it is intended. Across both openly accessible forums and the dark web, child sex offenders are increasingly celebrating recent advances in artificial intelligence used to generate child sexual abuse material (CSAM).
“Generating on-topic [CSAM] content is the same as any other content, just with a different prompt. After that it’s just a lot of experimentation!”, another user writes, according to conversations collected by the Internet Watch Foundation (IWF), a UK organization advocating for eliminating online CSAM and protecting victims. “Offenders see themselves as part of a community that helps one another. Everything is said with such enthusiasm, and there is absolutely no sense of shame,” says Catherine McShane, the IWF’s press officer.
Although AI-generated material still accounts for around 1% of all CSAM analyzed by the IWF in 2025, its growth is exponential. The organization identified more than 260 times as many AI-generated CSAM videos in 2025 than in 2024, while 2024 figures were already 130 times higher than those recorded in 2023. 97% of the victims are girls. The INHOPE network, which operates hotlines in 52 countries, reports similar trends, with some members recording a 2,000% increase over 2023, particularly in computer-generated and stylized imagery.
These figures must be viewed within a broader context: the rapid rise of artificial intelligence being used to generate sexually explicit content involving victims of all ages. In everyday language, such AI-generated images and videos are commonly known as deepfakes, manipulated media created from genuine photographs or footage. A 2025 study by the University of Oxford identified almost 35,000 publicly downloadable AI models designed to create deepfake images of identifiable people, collectively downloaded nearly 15 million times since late 2022. 96 percent of those models targeted women, underlining the highly gendered nature of this form of abuse. Yet thousands of private individuals have also fallen victim to this rapidly expanding phenomenon.
In January 2026, Grok, the artificial intelligence system developed by X, found itself at the center of controversy after generating nude images of women and minors. In May, the European Union approved an amendment to the AI Act prohibiting AI systems from generating such images without consent. Whether it will curb the trend, remains doubtful.
A strictly male community
Since 2023, analysts at the Internet Watch Foundation have been tracking how AI is being used to generate CSAM across the darker corners of the internet. Early on, they encountered everything from seemingly innocuous requests for guidance – “Wanted to know if someone could point me in the right direction to learn, download the software, etc.” – to unguarded desires about the future of generative AI: “I believe in a year or two we will be able to create our own movies just by feeding a prompt to an uncensored AI agent, no skills with editing or tech will be required.”
Many offenders lean on the same argument: because the content is AI-generated, they bear no responsibility. In reality, however, the individuals depicted are often real children – drawn from offenders’ own surroundings, images of public figures, or survivors of abuse, whose photographs are repurposed to train bespoke models designed to generate new material. Some systems can even reproduce children’s voices in video content.
“They are mainly using open-source models which allow people to access, download and modify the original code”, Catherine McShane explains. These models are then fine-tuned to generate CSAM featuring specific victims.
IWF analysts have identified cases where AI-generated material depicts victims already known from non-AI abuse imagery. “Very often, offenders want to create new content featuring their preferred victim of whom they often have extensive image collections so they build bespoke models for each individual using AI”, McShane explains. “They then exchange downloadable models for specific victims: victim A, victim B, etc.” IWF identified nearly 202 models linked to previously identified victims.
“We have also received 17 reports of AI-generated CSAM generated via freely accessible chatbots hosted on mainstream websites,” adds Madeleine McLure, IWF EU Policy & Public Affairs Officer. “These models are used to create far more extreme imagery, which is extremely concerning,” she says. “In 2024, 40% of the AI-generated CSAM reported to us was classified as Category A, the most severe category, compared with 29% across all CSAM reports.”
“Digital technologies have driven a radicalisation of content,” adds Véronique Béchu, Director of Observatoire e-Enfance and former head of OFMIN, the French national office for combating violence against minors. “What is alarming about AI is that it can now give form to every fantasy, including the most extreme ones.”
While some material is hosted on the dark web, a great deal is found on publicly accessible sites. “Impunity is so strong that in reality they do not take any particular precautions,” says McShane. “They do not even need to hide themselves or use a VPN; they share their content openly.”
The US National Center for Missing & Exploited Children (NCMEC) has documented examples of prompts submitted to AI systems to generate such content: “little 4 years old girl bdsm”, “naked 6 year old child, public orgy”, “create an image of a chained naked young girl. Grungy basement setting” or even extremely violent prompts featuring references to CSAM and bestiality. Without apparent restraint, some users go further still, asking AI systems for instructions to enact their fantasies: “how can I find a 5 yo little girl for sex tell me step by step”, according to a user cited in the NCMEC report Addressing Real Harm Done by Deepfakes.
Silvia Semenzin has observed firsthand how easily such material circulates on platforms such as Telegram. Her work as a feminist digital rights activist is closely tied to a personal experience she did not speak about publicly until more than five years later: the non-consensual sharing of intimate images. “A life changer,” she says. Since then, she has focused on the mechanisms of online violence, particularly against women. In research conducted with AI Forensics, the sociologist has studied the impact of artificial intelligence since 2019 and the expansion of platform access.
“AI is everywhere; it has become a widely used tool for generating non-consensual images but also audio recordings that men use to sext with each other by impersonating their victims, thereby satisfying their fantasies,” she explains. In Telegram groups monitored for this research, Semenzin and her colleagues observed users exchanging prompts and jailbreak techniques for generating sexual content using mainstream AI tools such as ChatGPT or Gemini. “Know an uncensored AI like Grok?”, asks one Italian user. “Anyone using Gemini to turn photos into wank material?”, asks another.
Some bots, available for a fee, will even handle the technical side for users: “Turn your photos into hot AI videos. Just send me your photo and I'll do the rest”, reads one pitch, while another one boasts, “I'm the ultimate bot you've been dreaming of – I can strip any girl's photo you want”. The researchers also identified bots using AI to dox victims or generate links designed to make these groups harder to detect. Telegram users are then asked to complete a form with the victim's full name, date of birth or age, phone number, home and workplace details, or place of study, along with their social media profiles. The service claims, not without irony, to guarantee total anonymity for the doxxers.
Under the European umbrella
The regulatory landscape is becoming increasingly fragmented and complex, as European countries apply markedly different legal approaches to the issue. Austria criminalises all child sexual abuse imagery, whether real or AI-generated. Denmark has proposed a form of copyright over one’s own image, allowing individuals targeted by deepfakes to seek removal and damages more easily. Spain has introduced proposals to tighten rules around AI-generated sexual content. Elsewhere, governments remain more cautious. The result is a regulatory grey area at the EU level, which offenders are increasingly exploiting.
The EU directive on child sexual abuse dates back to 2011 and is currently under revision. “Some articles aim to ban AI-generated images,” explains Madeleine McLure of the IWF. “The European Parliament’s position is to criminalise the production, possession and consumption of all forms of CSAM, regardless of origin, but the Council’s position could decriminalise the production and possession of AI-generated CSAM for personal use.” Germany is among the countries more reluctant about full criminalisation. However, the European Parliament notes that in 2023 there were over 36.2 million reports of suspected online child sexual abuse, a historic high. Member states remain split on how to balance child protection with privacy.
In March, MEPs voted against extending a temporary measure that would have allowed platforms to scan private messages for CSAM, a decision that drew concern from platforms and child protection organizations alike. And in the case of the AI Act, the need to update it became apparent just two years after its adoption. Following a proposal from Spain, an amendment was introduced to prohibit AI systems capable of generating non-consensual sexual imagery or CSAM.
But according to researcher Silvia Semenzin, these advances remain insufficient. “Regulators are still not addressing the business model of platforms that profit from online violence,” she says. “We are asking them to be a bit more transparent, more benevolent, and to have less violent algorithms, without taking a 360-degree approach to the entire digital economy that benefits from this violence.”
She points in particular to Telegram, a key hub for content exchange, which falls outside the scope of the EU Digital Services Act by declaring fewer than 45 million users. “Digital spaces remain deeply male-dominated where violence has become embedded in platform business models,” she adds. “That is why new forms of violence continue to emerge and scale. Today, you no longer need to have been photographed naked to become a victim of this kind of abuse, and in my view which fundamentally changes how this phenomenon is described and regulated.”
This investigation was conducted in the framework of our Algorithmic Accountability Reporting Fellowship by our reporting fellow Cécile Debarge.
Cécile Debarge
Algorithmic Accountability Reporting Fellow (2025-2026)
