AI | Italian DPA warns against the use of AI systems to generate “deep nudes”

On 18 December 2025, the Italian Data Protection Authority (Italian DPA) issued a warning notice addressed to users of those artificial intelligence (AI) systems that allow the generation of so-called “deep nudes”. Deep nudes are hyper-realistic fake images or videos depicting real individuals in nude or sexually explicit poses. In its provision, the Italian DPA specifically warned data controllers and processors that generating deep nudes using images or voices of third parties without their consent constitutes a breach of data protection law.  In October 2025, following the temporary ban imposed on the deep nude app Clothoff, the Italian DPA launched a formal investigation into so-called “nudifying apps”. According to the Italian DPA, investigations revealed that several AI platforms nowadays enable users to generate deep-nude content with minimal effort, simply by  uploading images to the platform.  The Italian DPA stressed that creating deep nudes of third parties may constitute a criminal offence under Italian law and a serious violation of the fundamental rights of the individuals concerned, potentially giving rise to multiple legal infringements, including breaches of data protection law. The Italian DPA also urged AI platform operators to strengthen their security measures and safeguards to prevent misuse, protect the integrity of their services and uphold users’ rights.  Finally, the Italian DPA announced its active cooperation with the Irish Data Protection Authority, which has launched an investigation into Grok, the AI system operated by X.

Newsletter n. 114 – January 2026