AI | Italian DPA orders temporary ban on “deep nude” AI app

On 3 October 2025, the Italian Data Protection Authority (Italian DPA) announced a temporary limitation on the processing of Italian users’ personal data by Clothoff, an application powered by generative artificial intelligence that enables users to create hyper-realistic fake images or videos that depict real people, including minors, in nude or sexually explicit poses (known as “deep nudes”) simply by uploading their photos.

The Italian DPA identified several critical issues, notably the absence of any mechanism to verify that consent had been obtained from the data subjects whose images were used, and the lack of a disclosure indicating that the resulting content had been generated using artificial intelligence.

In the same context, the Italian DPA launched a broad formal investigation into the operation of “nudifying apps”, given the serious risks these services pose to individuals’ fundamental rights and freedoms, particularly those of minors.

Newsletter n. 112 – November 2025