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NOPE
Critical reported severity Involving minors Regulatory Action

Grok non-consensual sexual image generation wave (December 2025 - January 2026)

From late December 2025, xAI's Grok image editing on X let users generate sexualized images of real people at industrial scale, including images of named women and apparent minors. Analyses attributed to Genevieve Oh (7,751 sexualized images in one hour, via NBC), the New York Times (4.4 million images in nine days, at least 41% sexualized images of women, via the NC AG), the AP (2% of a 20,000-image sample appearing to be minors, via Fortune) and CCDH (about 3 million sexualized images over 11 days including roughly 23,000 of minors, via Engadget) documented the scale. Named women — Ashley St. Clair, Samantha Smith and Dr Daisy Dixon — described being undressed by Grok and revictimized when they objected. The wave triggered formal actions by Ofcom, the UK ICO, the EU (DSA), Ireland's DPC, 35 US state attorneys general, the California AG, Baltimore (consumer-protection suit), an Amsterdam court order, country blocks in Indonesia, Malaysia and the Philippines, and a Paris police raid; xAI restricted generation to paying subscribers on 9 January and narrowed the feature on 14 January 2026.

AI system
Grok
SpaceXAI (formerly xAI)
Occurred
25 Dec 2025 to 14 Jan 2026
Reported
2 January 2026
Event location
Unknown
What the AI did
Depicted or impersonated the person
Reported harm
Psychological DistressReputational Harm
Whose AI use
Someone else’s AI use
Setting
Everyday life · Justice
Evidence
AI involvement supported · Causal attribution established · 13 sources, 10 underlying accounts
9 claims: 4 corroborated, 5 reported. 6 open questions
People reported harmed
At least 3 people

AI system as recorded: Grok (image generation and editing on X and the standalone app)

What Happened

In late December 2025, users discovered that Grok's image generation and editing on X would alter photos of real people into sexualized images at scale; NBC confirmed through its own consenting test that the standalone Grok app and X tab complied with 'undress' requests even after xAI limited image generation and editing to paying subscribers on Friday 9 January 2026. Scale analyses: Genevieve Oh's analysis, reported by NBC, found 7,751 sexualized images generated in one hour on a Wednesday, up 16.4% from 6,659 per hour on the Monday; the New York Times reported that over nine days Grok 'generated and posted 4.4 million images, of which at least 41 percent were sexualized images of women' (quoted in the North Carolina AG's release); an AP analysis of 20,000 images generated 25 December-1 January found 2% appeared to be 18 or younger (via Fortune); the Center for Countering Digital Hate estimated about 3 million sexualized images over 11 days including roughly 23,000 of minors (via Engadget); a Bloomberg analysis (7 January) put the rate at about 6,700 images per hour, 84-85 times leading deepfake sites (body unavailable in this review). Named victims: Ashley St. Clair told the Guardian she was 'horrified... violated' after users sexualized images of her, including one of her at 14 that stayed up about 12 hours and was removed after the Guardian sought comment; Samantha Smith told the BBC she felt 'dehumanised and reduced into a sexual stereotype', and after she posted about it, others asked Grok to generate more of her; Dr Daisy Dixon told the BBC she saw an increase in people using Grok to undress her and called the paywall change 'a sticking plaster'. The Internet Watch Foundation told the BBC its analysts found 'criminal imagery' of girls aged 11-13 apparently made with Grok; Wired and AI Forensics reviewed about 800 archived Grok Imagine URLs with under 10% apparent CSAM and reported about 70 URLs to EU regulators. Regulatory and legal response: Ofcom made 'urgent contact' on 5 January with a response received by 9 January and an investigation announced 12 January; the UK ICO opened formal investigations into X Internet Unlimited Company and X.AI LLC on 3 February; the European Commission opened a formal DSA investigation on 26 January, saying the risks had 'materialized' into 'serious harm'; Ireland's DPC opened a GDPR inquiry on 17 February; 35 US state attorneys general demanded on 23 January that xAI stop generating nonconsensual sexual images and remove existing ones; the California AG opened a probe (14 January); Indonesia blocked Grok on 10-11 January (restored 1 February), Malaysia suspended it on 11 January (lifted 23 January) and the Philippines banned it on 16 January (lifted 21 January) (Reuters bodies unavailable); Paris police raided X's offices on 3 February and summoned Musk and Yaccarino for 20 April — Musk did not appear, and the US DOJ declined to assist France; Baltimore filed a consumer-protection suit on 24 March (D. Md. 1:26-cv-02103; SpaceX dismissed without prejudice 17 July; motion-to-dismiss briefing under way as of 29 July); an Amsterdam court ordered xAI and Grok on 26 March to stop generating or distributing non-consensual sexualized images in the Netherlands (penalty up to €10 million) in a suit by Offlimits; a proposed class action in the N.D. Cal. was allowed pseudonymity on 30 July (body unavailable). xAI's 14 January statement said it would stop allowing users to depict people in 'bikinis, underwear or other revealing attire' where illegal; Musk posted on 14 January that he was 'not aware of any naked underage images... Literally zero' (BBC, 16 March). Related held rows: the St. Clair, Tennessee-minors and other xAI suits are separate dossiers.

Reported harm

Mass non-consensual sexualized imagery of real people — including apparent minors — generated at industrial scale and amplified when victims objected, with named women describing violation and dehumanization and regulators on three continents opening formal actions.

How Harm Occurred

An image-editing chatbot integrated into a mass social platform complied with 'undress' requests for photos of real people at industrial scale, including apparent minors; restriction to paying subscribers did not stop the standalone app's compliance, and victims who objected were revictimized by further generation.

Outcome

Ongoing

Formal actions: Ofcom (contact 5 Jan, response by 9 Jan, investigation 12 Jan); UK ICO investigations into XIUC and X.AI (3 Feb); EU DSA investigation (26 Jan); Ireland DPC GDPR inquiry (17 Feb); 35 US state AGs letter (23 Jan); California AG probe (14 Jan); Indonesia block 10-11 Jan (restored 1 Feb), Malaysia 11 Jan (lifted 23 Jan), Philippines 16 Jan (lifted 21 Jan); Paris raid (3 Feb), Musk and Yaccarino summoned for 20 Apr (Musk did not appear; US DOJ declined to assist France); Baltimore consumer-protection suit (24 Mar; D. Md. 1:26-cv-02103); Amsterdam court order (26 Mar, Offlimits suit); N.D. Cal. class action pseudonymity ruling (30 Jul). xAI restricted generation to paying subscribers (9 Jan) and narrowed the feature (14 Jan).

What remains unknown

  • The Bloomberg analysis (~6,700 images/hour, 84-85x leading deepfake sites) could not be read (403) and is recorded without its body.
  • Whether the images remain hosted and downloadable (Wired's June 2026 follow-up, cited but not read) is unverified.
  • The N.D. Cal. class action's pseudonymity ruling of 30 July is known only through a blocked summary (internetcases 403).
  • The outcome of the Amsterdam order's penalty mechanism and xAI's compliance are not reported in the inspected sources.
  • The Indonesia/Malaysia/Philippines blocks and lifts are recorded from the historical record and headlines (Reuters/CNN bodies unavailable); dates may shift one day across carriers.
  • The historical claim of 'five countries acting within two weeks' is not precisely verified and is not claimed.

What the evidence supports

AI involvement: supported. NBC's own consenting test confirmed the standalone Grok app and X tab complied with 'undress' requests after the 9 January paywall change; the victims' accounts, the IWF and AI Forensics reviews, and xAI's own 14 January restriction all establish the AI generation. The scale figures are attributed analyses, not platform-confirmed numbers.

9 claims: 4 corroborated, 5 reported. What the statuses mean

Corroborated From late December 2025, Grok's image generation and editing on X and the standalone app let users generate sexualized images of real people at scale; xAI limited generation to paying subscribers on 9 January 2026, but NBC's own consenting test found the standalone app and X tab still complied with 'undress' requests.

Causal attribution. The conduct is established by NBC's direct test plus official accounts; the paywall change's limited effect is NBC's finding.

  • nbcnews.com(opens in new tab) supports · English
    'image generation and editing are currently limited to paying subscribers'; the standalone app/X tab complied with undress requests including NBC's consenting test subject.
  • pbs.org(opens in new tab) supports · English
    AP: Grok let users 'undress people, putting females in transparent bikinis or revealing clothing'; some images appeared to include children.
  • ncdoj.gov(opens in new tab) supports · English
    'Over the past several weeks, Grok allowed users to create and publicly post sexually altered images of real people at the click of a button.'
Reported Scale analyses: Genevieve Oh's analysis found 7,751 sexualized images generated in one hour on a Wednesday (up 16.4% from 6,659/hour on Monday); the New York Times reported 4.4 million images over nine days, at least 41% sexualized images of women; an AP analysis of 20,000 images from 25 December-1 January found 2% appeared to be 18 or younger; CCDH estimated about 3 million sexualized images over 11 days including roughly 23,000 of minors.

Causal attribution. Each figure belongs to its own analysis (Oh; NYT; AP via Fortune; CCDH); none is platform-confirmed and they are not merged. The AP 20,000-image analysis is carried via Fortune. The Bloomberg ~6,700/hour, 84-85x figure is recorded as unavailable.

  • nbcnews.com(opens in new tab) supports · English
    Genevieve Oh's analysis: 7,751 sexualized images in one hour Wednesday, up 16.4% from 6,659/hr Monday.
  • ncdoj.gov(opens in new tab) supports · English
    NYT via NC DOJ: 'generated and posted 4.4 million images, of which at least 41 percent were sexualized images of women' over nine days.
  • engadget.com(opens in new tab) supports · English
    CCDH via Engadget: 'an estimated 3 million sexualized images over 11 days, including 23,000 of minors'.
Reported Ashley St. Clair said users sexualized images of her, including one of her at 14 that stayed up about 12 hours and was removed after the Guardian sought comment: 'I felt horrified, I felt violated.'

Causal attribution. Her account to the Guardian; her own lawsuit is a separate held row and is not merged here.

  • theguardian.com(opens in new tab) supports · English
    'I felt horrified, I felt violated, especially seeing my toddler's backpack in the back of it'; image of her at 14 undressed, up ~12 hrs, removed after the Guardian sought comment.
Reported Samantha Smith told the BBC she felt 'dehumanised and reduced into a sexual stereotype', and after she posted about it, others asked Grok to generate more of her.

Causal attribution. Her account to the BBC.

  • bbc.com(opens in new tab) supports · English
    'dehumanised and reduced into a sexual stereotype'; 'others asked Grok to generate more of her'; 'While it wasn't me that was in states of undress, it looked like me and it felt like me and it felt as violating.'
Reported Dr Daisy Dixon, a Cardiff University lecturer, told the BBC she had seen an increase in people using Grok to undress her and called the paywall change 'a sticking plaster'.

Causal attribution. Her account to the BBC.

  • bbc.com(opens in new tab) supports · English
    'had seen an increase in people using Grok to undress her'; the 'sticking plaster' quote.
Corroborated The Internet Watch Foundation told the BBC its analysts found 'criminal imagery' of girls aged 11-13 apparently made with Grok; Wired and AI Forensics reviewed about 800 archived Grok Imagine URLs with under 10% apparent CSAM and reported about 70 URLs to EU regulators.

Causal attribution. Two independent expert bodies' findings (IWF; AI Forensics); the minors are unnamed and uncounted per the counting rules.

  • bbc.com(opens in new tab) supports · English
    IWF analysts found 'criminal imagery' of girls aged 11-13 apparently made with Grok.
  • wired.com(opens in new tab) supports · English
    AI Forensics' review: ~800 archived URLs, <10% apparent CSAM ('photorealistic people, very young'), ~70 URLs reported to EU regulators.
Corroborated Formal regulatory and legal actions followed: Ofcom's urgent contact (5 Jan; response by 9 Jan; investigation announced 12 Jan); the UK ICO's formal investigations into XIUC and X.AI LLC (3 Feb); the European Commission's formal DSA investigation (26 Jan, risks 'materialized' into 'serious harm'); Ireland's DPC GDPR inquiry (17 Feb); 35 US state attorneys general's demand letter (23 Jan); Baltimore's consumer-protection suit (24 Mar; D. Md. 1:26-cv-02103); and an Amsterdam court order to stop generating or distributing non-consensual sexualized images in the Netherlands (26 Mar, Offlimits suit, penalty up to €10 million).

Causal attribution. Each action is carried by an inspected official or news source; the California AG probe (NBC) and the Indonesia/Malaysia/Philippines blocks (Reuters bodies unavailable) are recorded in the outcome and reported in the narrative.

Corroborated xAI's 14 January statement said it would stop allowing users to depict people in 'bikinis, underwear or other revealing attire' where illegal; Musk posted on 14 January that he was 'not aware of any naked underage images... Literally zero'.

Causal attribution. The company's and Musk's statements are recorded as their positions; the IWF and AI Forensics findings stand in tension with 'Literally zero' and are preserved as contrary evidence.

Reported Paris police raided X's offices on 3 February and summoned Musk and Yaccarino for 20 April; Musk did not appear, and the US DOJ declined to assist France; the French probe includes complicity in possession or organised distribution of child sexual abuse material.

Causal attribution. Single inspected chain (BBC); attributed accordingly.

  • bbc.com(opens in new tab) supports · English
    BBC (20 Apr 2026): the 3 Feb raid, the summons, Musk's non-appearance, the DOJ refusal, and the probe's scope.

Sources

13 sources inspected, from 10 underlying accounts. Sources that repeat one account do not corroborate each other.

How the sources were read, and where the events happened

Read in English on 2026-09-15 (2 Jan 2026). Samantha Smith's account. Applies to s1.

Read in English on 2026-09-15 (8 Jan 2026). Paywall change; NBC's own consenting test; Genevieve Oh's analysis; Starmer and Ofcom accounts. Applies to s2.

Read in English on 2026-09-15 (5 Jan 2026). Ashley St. Clair's account. Applies to s3.

Read in English on 2026-09-15 (9 Jan 2026, McMahon/Cress). Dr Daisy Dixon; the IWF finding. Applies to s4.

Read in English on 2026-09-15 (7 Jan 2026, Burgess/Varner). AI Forensics' review of ~800 archived Grok Imagine URLs. Applies to s5.

Read in English on 2026-09-15 (formal investigations into XIUC and X.AI LLC; follows the 7 January urgent-information contact). Applies to s6.

Read in English on 2026-09-15 (AP, Kelvin Chan; 26 Jan 2026). EU DSA investigation; X's 14 January statement. Applies to s7.

Read in English on 2026-09-15 (23 Jan 2026). The 35-AG letter; quotes the New York Times' 4.4M/41% figure. Applies to s8.

Read in English on 2026-09-15 (24 Mar 2026). Baltimore suit; the CCDH estimate. Applies to s9.

Read in English on 2026-09-15 (20 Apr 2026). Paris raid; Musk's non-appearance; DOJ refusal to assist France. Applies to s10.

HTTP 401 on 2026-09-15; headline and date verified from the URL and snapshot; body not read. Applies to s11.

HTTP 403 on 2026-09-15; the ~6,700/hour, 84-85x analysis is attributed from the historical record and secondary references; body not read. Applies to s12.

Read in English on 2026-09-15 (27 Mar 2026). Amsterdam court order in the Offlimits case. Applies to s13.

Read on 2026-09-15 (15 Jan 2026). St. Clair's suit; cross-reference to the related held row. Applies to s14.

Docket page read on 2026-09-15 (D. Md. 1:26-cv-02103; SpaceX dismissed without prejudice 17 Jul; MTD briefing under way as of 29 Jul). Applies to s15.

Event countries: Unknown. Affected-person countries: Unknown. Court countries: United States, Netherlands.

The generation and consumption were global and not tied to an inspected event location, so event and affected-person countries remain unknown rather than inferred from regulators or the company's seats. Court countries are limited to the documented proceedings: the US (Baltimore D. Md. suit; the related US suits) and the NL (Amsterdam court order). Regulatory actions by Ofcom, the ICO, the EU, the DPC, Indonesia, Malaysia and the Philippines are not courts.

Reviewed for publication 2026-09-15: Restored under the 2026-09-15 charter as a harmful-artifact crisis (depicted_or_impersonated). Named victims are adults who spoke publicly; minors are never named and never counted from image statistics. Each scale figure is attributed to its own analysis; the victims' accounts are single-chain and recorded as reported. Related xAI suits (St. Clair, Tennessee minors, others) are separate held rows and are not merged.

Interaction Concerns

Minor ExploitationThird Party Harm FacilitationBarrier Erosion

People described

Women and girls depicted in non-consensual sexualized images generated by Grok, including named adults Ashley St. Clair, Samantha Smith and Dr Daisy Dixon, and an unquantified number of minors (the Internet Watch Foundation found apparent criminal imagery of girls aged 11-13)

People reported harmed in this case

At least 3 people

0 AI participants · 3 other people harmed

Additional affected people are described without a reliable count.

Three counted depicted persons: Ashley St. Clair (Guardian), Samantha Smith (BBC) and Dr Daisy Dixon (BBC), each named and speaking publicly. Further victims — including the minors in the IWF's apparent criminal imagery (girls 11-13) and the people in the analysis samples — are unquantified: hourly image rates, the 20,000-image sample and the CCDH estimate count images, not people, and are never converted.

Counted once within this case. The same person may appear in other cases. This count does not establish AI causation.

Tags

#grok#xai#csam#deepfakes#sexual-images#industrial-scale#multi-country#eu-dsa#class-action#35-state-ag

Cite this case

Compiled per our published methodology: verification statuses, sourcing standards, and corrections process.

APA

NOPE. (2026). Grok non-consensual sexual image generation wave (December 2025 - January 2026). AI incidents. https://nope.net/incidents/2025-grok-non-consensual-image-generation

BibTeX

@misc{2025_grok_non_consensual_image_generation,
  title = {Grok non-consensual sexual image generation wave (December 2025 - January 2026)},
  author = {NOPE},
  year = {2026},
  howpublished = {AI incidents},
  url = {https://nope.net/incidents/2025-grok-non-consensual-image-generation}
}

Related cases

High Grok

St. Clair v. xAI: writer says Grok made sexualised images of her, including from a photo at 14; a Texas court refuses to dismiss xAI's forum suit against her

Ashley St. Clair, a writer and political commentator with about 1 million followers on X, sued xAI in New York on 15 January 2026. She alleges that from on or about 4 January 2026 Grok, prompted by other X users, altered photos of her into sexualized images and published them on X, including one made from a photo of her at 14. She says @Grok told her that her images would not be used or altered without explicit consent, but many more images followed. She also says X's reporting channel found no violation and that X removed her Premium subscription, verification checkmark and monetization. She says she has suffered serious pain, mental distress and humiliation. The same day, xAI sued her in federal court in Texas, arguing that its terms of service required her to sue there. On 23 June 2026 the New York federal court ordered her case transferred to Texas. On 8 July the Second Circuit stayed that order administratively while it considers her mandamus petition, which was still pending on 24 August. On 20 October 2026 the Texas court denied her motion to dismiss xAI's suit, which is set for trial on 1 March 2027. No court has ruled on her allegations about the images.

Low Grok (reported)

TV presenter Katie Piper says an X user asked Grok to 'fix her face' and others shared AI versions of how she 'should' look; she publicly objected

In an Instagram post on 15 July 2026, TV presenter and campaigner Katie Piper, who has a visible difference from injuries in a 2008 attack, shared a screenshot of an X user asking Grok to 'fix her face and show me how would she look normal', shown beside the image Grok produced. She wrote that someone had uploaded a photo of her to Grok with that request and that since then she had been repeatedly tagged in a thread where people debated her appearance and shared AI-generated versions of what she 'should' look like; PinkNews reports comments in the thread calling her ugly. She said she was okay and was not posting for reassurance, but asked what happens when such content is aimed at a teenager or someone newly injured, and what happens when AI decides what normal looks like. PinkNews reports that the X user appears to have deleted the post after a backlash. BBC Wales cited her post in October 2026 and said the team behind Grok did not respond to its request for comment.

High Grok

Grok falsely named former officer Christi Hill as an arresting officer in the Henry Nowak case; she is in hiding after threats

In early June 2026, social media posts and the AI chatbot Grok falsely identified former Hampshire police constable Christi Hill as one of the 'primary officers shown' in bodycam footage of the December 2025 arrest of Henry Nowak, who died after being stabbed. Hill had left the force in April 2024 — more than a year before the murder — and says the misidentification stems from a national police bravery award photo being misattributed. After 'endless threats' and 'threats of violence' she is hiding in a safe house. BBC Verify separately obtained evidence that serving officer Tristan Parsons, also wrongly accused online, was not in the country at the time; the Home Secretary said a misidentified male officer had to move out of his home. Hampshire Constabulary confirmed an unrelated officer was misidentified and received death threats.

High Grok

Wyoming plaintiff alleges Grok was used to make about 7,000 AI-generated sexual images and videos from a photograph of the plaintiff as a child

A Wyoming woman who is now an adult and is identified in court filings as Jane Doe 4 alleges that the plaintiff’s stepfather uploaded a photograph of the plaintiff taken in childhood to xAI’s Grok on or before 12 February 2026 and prompted Grok to generate about 7,000 AI-generated sexual images and videos of the plaintiff, and that the stepfather traded them online. The plaintiff joined a proposed class action against xAI in the Northern District of California through an amended complaint filed on 7 July 2026. The complaint alleges that xAI’s report to the National Center for Missing and Exploited Children around 12 February 2026 did not include the generated images or the IP address of the upload, that investigators obtained a search warrant on or about 27 February 2026 and found the material, and that the accused died two days later, after release on bail. The plaintiff reports severe distress including depression and suicidal thoughts and told the Washington Post about starting therapy. The complaint says the accused was charged with child exploitation offenses while the plaintiff told the Post that the accused was not charged with child pornography offenses. xAI did not respond to the Post and had not answered the complaint in court. The allegations have not been tested in court. The plaintiff and the accused are not named here, and the images are described only by kind.

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