The rise of artificial intelligence is creating a new frontier in child sexual exploitation, with law enforcement agencies struggling to keep pace with offenders using AI to generate sexually explicit material involving minors.
The National Center for Missing and Exploited Children reported receiving over one million CyberTipline reports related to AI-generated child sexual abuse material (CSAM) in just nine months of 2025. Experts warn that the technology’s realism and accessibility are enabling offenders to produce both identifiable and entirely synthetic depictions of minors, complicating investigations and prosecutions.
“We often see bad actors at the forefront of leaning into those types of advancements in order to sexually exploit children online,” said Fallon McNulty, executive director of the center’s exploited children division. “The almost indistinguishable nature of the content makes victim identification extremely difficult.”
How AI Is Used to Create Exploitative Material
Offenders are exploiting a combination of public photographs, open-source AI models, and specialized platforms to generate explicit imagery of children. In some cases, entirely new images are created with no real child involved, producing deepfakes that are increasingly realistic.
Law enforcement officials, including Michael Prado of Homeland Security Investigations’ Cyber Crimes Center, report that AI-generated CSAM is frequently mixed with traditional material, challenging investigators who must distinguish between virtual and real victims. Reports of such material surged over 600% in the first half of 2025 compared to 2023–24 combined.
Cases highlight the role of smaller AI platforms, including Bashable.art, undress.ai, and Faceswapper.AI, which may have limited moderation. In one federal case, a registered sex offender allegedly used Bashable.art’s unrestricted mode to generate over a thousand images depicting children under 13. Open-source models like Stability AI’s Stable Diffusion have also been misused to create photorealistic CSAM.
Experts note that even when AI-generated content involves no real child, it can be prosecuted under federal obscenity laws, and individuals possessing AI-generated CSAM often possess real CSAM as well.
Legal and Legislative Efforts
Lawmakers at both federal and state levels are responding to the crisis. Forty-five states have enacted legislation addressing intimate AI deepfakes, many with specific protections for minors. At the federal level, the TAKE IT DOWN Act and the ENFORCE Act provide mechanisms to criminalize the creation and distribution of nonconsensual AI-generated content and require platforms to remove such material promptly.
Policy experts emphasize the need for both state and federal action. “State and local prosecutors are essential for addressing these cases,” said Ilana Beller of Public Citizen. “Federal authorities alone cannot handle the volume and complexity of AI-related CSAM.”
As AI technology continues to evolve, investigators and lawmakers face mounting challenges in keeping pace. “There’s often a lag between laws being enacted and their enforcement,” Prado said. “The rapid advancement of generative AI makes this a persistent and growing concern.”
