EU moves to regulate AI undressing images, but key challenges remain

After Grok launched an image editing feature at the end of December 2025 and a large number of non-consensual sexualized deepfake images targeting women quickly appeared on X, the European Commission opened an investigation into X under the DSA and GDPR, while the European Parliament and Council proposed banning AI-generated non-consensual intimate images (NCII) in the AI Act. The article notes that the DSA can only constrain services within the platform and has difficulty covering standalone undressing apps; the AI Act's existing safeguards are limited, and whether to assess NCII and CSAM risks is left to the discretion of general-purpose AI model providers. The proposed ban covers only images that clearly show intimate parts or sexual acts, so bikini-type images generated by Grok may not fall under it, and the ban also needs to address privacy risks arising from the determination of safeguard effectiveness and consent verification.