Section 138 of the Data (Use and Access) Act 2025 makes it a UK criminal offence to create, or request the creation of, non-consensual intimate images, including AI-generated content. The offence applies regardless of whether the content is shared, closing a gap in earlier legislation that only criminalized distribution.

• Creation of non-consensual intimate images, including fully AI-generated and altered content
• Soliciting or requesting another person to create such content
• “Purported images” — content that depicts a person in an intimate state even where the depicted state never occurred

• Criminal offence regardless of whether the content is distributed
• Designated as a priority offence under the Online Safety Act, requiring proactive platform prevention
• Consent of the depicted individual is a defence
• Penalties under the Sexual Offences Act framework: up to 2 years’ imprisonment and unlimited fine