New UK Law Tackles AI Generated Intimate Images Without Consent
On 12th January 2026, the government confirmed it will bring into force a law that makes it illegal to create non consensual intimate images, including sexually explicit deepfake style images of adults. This change follows growing concern about how AI image tools can be used to alter or generate sexualised content featuring real people without their knowledge or agreement.
While recent reports have centred on X and its Grok image features, the legal change is much wider than any single platform. The key point is this. The criminal law is now being strengthened so that creation itself can be prosecuted, not just sharing or threats.
At Draycott Browne, we have covered deepfake and intimate image abuse as it has developed. If you are under investigation, invited to a police interview, or concerned an allegation may be made, early legal advice is vital. Cases involving digital content often move quickly, and first decisions can shape the outcome.
Why This Legal Change Matters
Non consensual intimate images can be used to humiliate, control, blackmail, or intimidate. Even when an image is synthetic, the impact on a victim can be severe. Reputations can be damaged overnight, employers may get involved, and police investigations can escalate rapidly once a complaint is made.
Campaigners have argued for some time that the law needed to go further. Sharing intimate images without consent and threatening to share them are already criminal offences in many circumstances. The concern has been that someone could generate an explicit AI image of an adult without consent, keep it private, and potentially avoid prosecution for the act of making it. The new commencement is intended to close that gap.
What Law is Being Brought into Force
The new offences come from the Data (Use and Access) Act 2025, which received Royal Assent on 19 June 2025. The government has now confirmed that the relevant provisions will be commenced this week, making them enforceable in practice.
Section 138 of the Act inserts new offences into the Sexual Offences Act 2003, including provisions commonly referred to as sections 66E and 66F, alongside supporting definitions and time limit rules.
What the New Offences Mean in Plain English
The legal wording uses the phrase purported intimate image. This is designed to capture content that appears to show a real adult in an intimate state, even where the content is AI generated or manipulated.
Creating a Purported Intimate Image of an Adult
The offence focuses on intentionally creating a purported intimate image of another adult without their consent, and where the creator does not have a reasonable belief in consent.
Requesting the Creation of a Purported Intimate Image of an Adult
It is also an offence to request the creation of such an image without consent and without reasonable belief in consent. This matters because it targets conduct where someone prompts a tool or another person to generate the image for them.
This is a significant shift. It recognises that harm can begin at the point of creation, not only when content is circulated.
How this Relates to the Online Safety Act and Platform Duties
The government has also stated that this conduct will be treated as a priority offence under the Online Safety Act, meaning platforms are expected to take stronger steps to prevent and remove illegal material.
Ofcom has confirmed it has opened a formal investigation into X in response to reports connected to Grok and sexualised imagery. Ofcom has said it is investigating whether X complied with its duties to protect UK users from illegal content.
This is important context, but it is not the core legal shift. The main development is that individual conduct relating to creation and requesting creation is now being moved into an enforceable criminal framework.
Alongside commencement of the Data Act offence, ministers have stated they intend to legislate through the Crime and Policing Bill to make it illegal for companies to supply tools designed to create non consensual intimate images, often referred to as nudification apps. This aims to tackle the issue at source rather than only reacting after content is produced.
What to Do if You’re Accused of Creating Non Consensual Intimate Images
If you are facing allegations involving non consensual intimate images or deepfake content, it is vital to get expert legal advice as soon as possible. These cases often involve detailed digital evidence, platform data, device downloads, and messages that can be taken out of context. Acting early helps protect your rights, shape the direction of the investigation, and prevent avoidable mistakes in interview.
At Draycott Browne, our experienced team of Sexual Offence Solicitors provides clear and strategic guidance to clients accused of serious offences, including deepfake creation and intimate image allegations. With over 20 years of criminal defence experience, we act quickly, discreetly, and decisively, focusing on evidence, intent, and the detail that often decides whether a case proceeds.
We also have a dedicated team of Indecent Image Solicitors who specialise in allegations involving the creation, possession, and distribution of unlawful images. Where cases involve AI tools, prompts, or platform features, we will scrutinise attribution, knowledge, and how any content was generated, stored, or shared.
If you need immediate advice, contact us now for a confidential discussion. Our Deepfake Porn Defence Solicitors can advise urgently, represent you at the police station, and build a robust defence strategy designed to protect your future.