The rapid advancement of artificial intelligence (AI) is transforming how individuals learn, communicate and create content. However, alongside these benefits, there are growing concerns in respect of the use of AI to create, manipulate and distribute child sexual abuse material (AI-CSAM). This has led to recent guidance issued by the National Crime Agency (NCA) and the Internet Watch Foundation (IWF) highlighting the scale of this emerging risk and the safeguarding challenges facing organisations, professionals and families.
AI-CSAM refers to child sexual abuse material that has been wholly generated, manipulated or enhanced using artificial intelligence technologies. This can include:
Importantly, material does not need to depict a real child or a real abuse event to be unlawful. Under UK legislation, AI-generated indecent images of children, including content such as cartoons, illustrations and animations, may constitute criminal offences.
The guidance highlights the increasing prevalence of AI-generated abuse material. According to the IWF's 2025 Annual Data and Insights Report, 8,111 AI-generated child sexual abuse images and videos were identified from 498 reports, representing a 154% increase compared with the previous year. The data reflects growing accessibility to powerful image-generation tools and an evolving threat landscape that is challenging traditional safeguarding approaches. As professionals working with children and young persons, understanding these risks is essential to help protect them from potential harm and to respond effectively to incidents.
Under UK legislation, the creation, possession, and distribution of indecent images or pseudo-photographs of children are criminal offences, irrespective of whether the material is generated using artificial intelligence. The involvement of AI technology provides no defence to criminal liability and does not lessen the harm associated with the production and dissemination of such material.
The NCA and IWF also stress that AI-CSAM can cause significant harm even where no direct contact has occurred. Victims may experience distress, humiliation, loss of control and ongoing anxiety arising from the knowledge that AI-generated sexual images of them exist or may be disseminated online. Additionally, the creation and circulation of such material can contribute to the wider normalisation of child sexual exploitation.
Of particular concern are incidents involving young persons creating AI-generated sexual images of peers. The guidance notes that some children and young persons may view such conduct as a joke, banter or harmless experimentation without appreciating the legal consequences or lasting emotional impact on the victim. Any such incident should be treated as a safeguarding matter and managed in accordance with established child protection procedures.
Professionals are advised that it is not their responsibility to determine whether an image is AI-generated. Where CSAM is identified or suspected, it must be treated as a safeguarding matter. Concerns must be reported immediately through the appropriate safeguarding channels, with referral to the police where necessary and in accordance with applicable legal and regulatory requirements.
The UK Online Harms Early Warning Working Group issued guidance hosted by the UK Safer Internet Centre to protect school images from AI manipulation and abuse. It advises schools and youth organisations to minimize high-risk digital sharing of identifiable children's photos and to manage online media securely.
Further, organisations working with children are encouraged to review image consent processes regularly, ensure parents and carers understand how photographs may be used, and consider whether images featuring children are necessary at all.
The guidance for parents and carers similarly recommends:
Where AI-generated sexual abuse imagery is discovered, the NCA and IWF guidance recommends a prompt and measured response. Key actions include:
For children and young persons who become victims, services such as Report Remove | Childline can assist in seeking the removal of images from online platforms.
For organisations working with children and young persons, the emergence of AI-CSAM reinforces the need for robust safeguarding frameworks, regular staff training and clear reporting procedures. Existing policies concerning image sharing, cyber safety and harmful sexual behaviour should be reviewed to ensure they adequately address AI-related risks.
The guidance also illustrates a broader point relevant to all organisations: the misuse of AI technology is creating new legal, reputational and safeguarding challenges that require proactive governance. Awareness, education and early intervention remain the most effective tools in reducing risk and protecting vulnerable individuals.
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