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Online Safety Act 2023

AI-Generated Abuse Images: The Law and How to Report

Deepfake CSAM and AI-generated child abuse images are explicitly illegal. What the law says, why the IWF treats them the same as real images, and how to report.

The rise of generative AI has created a new category of child sexual abuse material: synthetic images and videos created by AI tools rather than depicting real children being abused. UK law has been updated to make clear that AI-generated child sexual abuse material (AI CSAM) is illegal regardless of whether a real child was involved in its creation. The Internet Watch Foundation and law enforcement treat these images with the same seriousness as images of real abuse.

The legal position: AI-generated CSAM is illegal

Under UK law, the Protection of Children Act 1978 (as amended) makes it illegal to create, possess, distribute, or view indecent images of children — and this extends to pseudo-photographs, computer-generated images, and AI-generated content. There is no requirement that a real child was abused in the creation of the image. This means that using AI tools to generate sexualised images of children is a criminal offence in the UK, regardless of the prompt used or the claimed fictional nature of the output.

Key takeaway: Creating, possessing, or sharing AI-generated sexual images of children is a criminal offence in the UK — fictional or synthetic origin is not a defence.

How the Internet Watch Foundation responds

The Internet Watch Foundation (IWF) is the UK's specialist body for removing online child sexual abuse material. Since 2023, the IWF has been cataloguing and acting on AI-generated CSAM with the same approach as real CSAM — working with hosting providers to take down URLs, hashing images to prevent re-upload, and reporting to law enforcement. IWF analysis has shown a significant and rapidly growing volume of AI-generated CSAM on the open internet, including detailed realistic images generated using publicly available AI tools.

Key takeaway: The IWF treats AI-generated CSAM identically to real CSAM — report it to them if you encounter it online.

Deepfakes and intimate image abuse

AI tools are also being used to create non-consensual intimate images of real people — including children and teenagers — by mapping their faces onto pornographic content. This is sometimes called 'deepfake pornography' or 'deepfake CSAM'. The Online Safety Act and the Criminal Justice (Sexual Offences and Human Trafficking) Act address intimate image abuse more broadly. Creating a deepfake sexual image of a child is CSAM under existing law. Creating a non-consensual sexual deepfake of an adult is now also a criminal offence following legislative updates.

Key takeaway: Deepfake sexual images of children are CSAM. Deepfake sexual images of adults without consent are also a criminal offence.

How AI tools are being misused

Generative AI image tools — including some accessible to members of the public — can be prompted to produce explicit images of children if their safety filters are bypassed. The IWF has identified 'jailbreak' prompts being shared online to circumvent these filters. Some AI tools specifically marketed for the creation of CSAM exist on the dark web. This is an area of rapid development, and UK and international law enforcement agencies are actively investigating the creation and distribution of AI CSAM.

Key takeaway: Jailbreaking AI tools to produce CSAM is a criminal offence — reports can be made to the IWF and police.

Online Safety Act duties and AI content

Under the Online Safety Act, platforms must treat AI-generated CSAM identically to traditional CSAM — it is priority illegal content that must be proactively detected and removed. Platforms hosting AI-generated content — including image generation tools and sharing platforms — must implement measures to prevent their services from being used to create or distribute AI CSAM. The duty to report discovered CSAM to the National Crime Agency applies to AI-generated images as to any other.

Key takeaway: Platforms must proactively detect AI-generated CSAM and report it to the NCA — the same duties apply as for real CSAM.

What the Act does

Treats AI-generated CSAM as priority illegal content that platforms must proactively detect and remove.

Requires platforms to refer detected AI-generated CSAM to the National Crime Agency.

Applies to AI image generation tools and sharing platforms as regulated services.

What the Act does not do

Understanding the limits of the Act helps you set realistic expectations when using complaint and reporting processes.

Create a separate legal category for AI-generated CSAM — existing criminal law covers it under existing offences.

Guarantee that AI tools cannot be misused — enforcement relies on both platform duties and criminal law.

Restrict the use of legitimate AI image tools that have appropriate safeguards in place.

Practical steps

1

If you encounter what appears to be AI-generated CSAM online, report it immediately to the IWF at iwf.org.uk/report.

2

If you believe a child you know has had a deepfake sexual image created of them, contact the police and CEOP.

3

If a child tells you about this happening to them or a peer, take it seriously — it is a criminal matter and they should be supported, not blamed.

4

Schools should include AI deepfakes in safeguarding training and online safety education, making clear this is illegal and where to report.

Frequently asked questions

Is it illegal to possess an AI-generated child sexual image even if no real child was harmed?

Yes. Under UK law, possession of computer-generated or AI-generated indecent images of children is illegal regardless of whether a real child was involved. The offence is based on the nature of the image, not on whether an actual child was abused in its creation.

Where should I report AI-generated CSAM?

Report it to the Internet Watch Foundation (iwf.org.uk/report) — they have an established process for handling AI-generated CSAM and work with hosting providers to remove content globally. You can also report to CEOP (ceop.police.uk) or directly to the police if you believe a specific child is at risk.

Sources and further reading

Related guides

Last reviewed: 19 April 2026

This is practical educational content to support families. For case-specific concerns about a child's safety, contact the NSPCC helpline on 0808 800 5000 or your local safeguarding team.

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