A group of 119 members of the European Parliament is pressing the European Commission and national governments to ensure that a new EU ban on artificial-intelligence ‘Nudifier’systems used to generate non-consensual sexual images can be enforced as soon as it takes effect.
The prohibition on so-called AI “nudifier” systems becomes applicable on 2 December 2026 following changes to the EU Artificial Intelligence Act approved earlier this year.
The legislation prohibits AI systems designed to create child sexual abuse material or realistic images, video or audio depicting an identifiable person’s intimate parts or sexually explicit activity without that person’s consent.
Providers cannot place systems intended for such use on the EU market. Systems capable of producing the material must have adequate safeguards intended to prevent it, while deployers are prohibited from deliberately using AI systems for that purpose.
The final agreement on the AI Act amendments gave companies until 2 December to bring their systems into compliance.
The latest intervention is intended to ensure that regulators are ready to enforce the prohibition rather than simply having the legislation on the statute book.
The letter supported by 119 MEPs was initiated by Green MEP Lena Schilling and Greens/EFA co-president Terry Reintke.
Its signatories include members from several political groups.
They want the Commission and member states to ensure that national authorities are designated to enforce the ban and that people targeted by non-consensual AI-generated sexual imagery know which authority to contact.
The letter also calls for stronger enforcement of the Digital Services Act against online platforms and search engines carrying or facilitating access to such material.
The initiative follows research cited by the organisers which identified 147 European politicians appearing on websites containing sexualised AI deepfakes.
Of those identified, 138 were women.
Schilling was among those affected and has used her own case to argue that the December prohibition needs an operational enforcement system from its first day.
The prohibition emerged during the EU’s broader revision of its AI legislation.
In March, the European Parliament adopted its negotiating position by 569 votes to 45, with 23 abstentions.
Parliament and Council subsequently reached agreement on the revised text, and the measure completed its formal legislative process in June.
EU Today reported at the time that the Council’s final approval combined delays to some high-risk AI requirements with new restrictions on non-consensual sexual imagery.
The issue is distinct from the wider transparency requirements applying to AI-generated content.
Under Article 50 of the AI Act, transparency obligations have applied since 2 August.
Providers of generative systems must in relevant cases make AI-generated or manipulated material machine-readable and detectable, while deployers face disclosure obligations covering deepfakes and some AI-generated material dealing with matters of public interest.
EU Today examined those changes when chatbot and deepfake disclosure rules entered into application in August.
There is, however, a transitional period for some AI systems that were already on the market before 2 August. Their machine-readable marking obligations take effect on 2 December.
That means the same date will bring both the new nudifier prohibition and the end of the transitional period for certain AI-content marking requirements.
Enforcement is divided between national regulators and EU institutions.
National market-surveillance authorities carry much of the responsibility for enforcing the AI Act. The Commission’s AI Office has direct enforcement responsibilities in more limited areas, including certain systems built on general-purpose AI models and systems integrated into very large online platforms or search engines.
The Commission’s guidance on Article 50 is intended to provide regulators and companies with a common interpretation of those transparency requirements.
The nudifier prohibition raises an additional problem because distribution of non-consensual intimate images also intersects with the Digital Services Act, national criminal and civil laws and EU legislation addressing violence against women.
The 119 MEPs are therefore seeking action beyond the AI Act itself.
Their letter asks for stricter use of the Digital Services Act against platforms and search engines, faster implementation of the EU directive combating violence against women and clearly identifiable national authorities able to respond to complaints.
The legal gap surrounding nudifier systems had previously been acknowledged by the Commission.
Its review of prohibited AI practices concluded that the original AI Act’s provisions on manipulation and exploitation of vulnerabilities did not adequately cover systems producing child sexual abuse material and non-consensual sexually explicit images.
That finding contributed to the explicit prohibition subsequently added during the Digital Omnibus negotiations.
The legislation is now settled. The immediate issue before the 2 December deadline is whether regulators across the 27 member states have the mechanisms in place to identify prohibited systems, investigate providers and respond when people report AI-generated intimate material produced without their consent.