At a conference held on November 12-13, 2023, Kerry Smith, CEO of the Internet Watch Foundation (IWF), emphasized the urgent need for regulation concerning AI-generated child sexual abuse material, identifying it as a current and escalating crisis rather than a future risk. Smith stated, “It is gratifying to see the high level of attention being directed towards the risks and harms posed to children from AI in the digital era in which we now live.” However, she cautioned that unless immediate legislative action is taken, the demand for, and output of, such harmful content will only increase as generative AI technologies advance.
The IWF’s findings reveal a disturbing trend: nearly 40% of all AI-generated child sexual abuse material in 2024 was categorized as Category A under UK law, marking it as the most severe classification, which includes depictions of rape or sexual torture of children, as well as abuse involving animals. Alarmingly, 98% of the AI-generated images and videos that recorded the sex of the child depicted only girls.
Smith highlighted that this disturbing data suggests that AI technology is not disrupting existing patterns of abuse but instead is reinforcing and exacerbating them. “This technology is reproducing and amplifying existing gendered patterns of abuse,” she remarked. “It’s embedding misogyny and child sexualization even more deeply into the online ecosystem.”
Moreover, Smith rejected the claim that AI-generated images could serve as a “safe substitute” for offenders, arguing that such use only normalizes abusive behavior and reinforces harmful sexual fantasies rather than mitigating them. “There is no evidence to support the claim that AI-generated imagery could be used as a ‘safe substitute’ that might somehow reduce harm by giving offenders a non-contact outlet,” she asserted.
Calls for Comprehensive Regulation
During the conference convened by Fondazione Child ETS in collaboration with the Child Dignity Alliance, Smith advocated for the criminalization of all forms of AI-generated child sexual abuse material across the EU. This comes in the context of new legislation, particularly the Recast Child Sexual Abuse Directive, currently being negotiated in the EU Parliament. She also called for a ban on ‘nudification’ apps that allow users to manipulate images of real individuals, including children, by removing clothing.
Smith urged, “This is the EU’s chance to update this legislation in line with the current state of child sexual abuse and exploitation across the world. We need a comprehensive EU ban as a minimum standard that includes the creation, possession, and distribution of AI child sexual abuse imagery, with no exceptions.” She reiterated the critical need to restrict nudification apps, stating, “There is no possible justification for the existence of this invasive technology.”
The IWF’s analysis indicates that AI is being utilized not only to create entirely new images but also to reconstruct and reimagine the abuse of existing victims. Fine-tuned AI models can generate an endless number of images of known victims with minimal input, subjecting survivors of child sexual abuse to repeated victimization whenever these models are trained or utilized.
Smith concluded with a stark reminder: “Because these AI systems are often trained and fine-tuned using real, photographic abuse material, they quite literally build on the suffering of real children. The development of AI tools must be regulated to prioritize children’s safety, dignity, and rights.” The conference culminated in a call for participants to sign a declaration aimed at safeguarding children, which was subsequently presented to Pope Leo XIV during an audience at the Apostolic Palace in the Vatican.
The event brought together diverse partners from various faiths, nations, and disciplines to discuss the profound impact of AI on the lives of children, stressing the need for ethical and transparent technology to foster a safer online environment.
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