DEEPNUDES
AMONG
YOUNG
PEOPLE IN
BELGIUM:
THE NUMBERS, THE
MARKET, THE IMPACT

3

Research team
Nina Dakota Szyf, researcher
Aurélie Gilen, doctoral researcher

Mona Giacometti, prof. dr.

Coordination
Catherine Van de Heyning, prof. dr.
Michel Walrave, prof. dr.

4

Contents
Abbreviations............................................................................................................................. 7
Glossary ...................................................................................................................................... 8
Deepnude figures among young people in Belgium summarised ......................................... 11
An introduction to digital sexual violence: deepnudes ......................................................... 13
1.

2.

3.

4.

The study .......................................................................................................................... 15
1.1

Mission and objectives .............................................................................................. 15

1.2

The survey study ........................................................................................................ 16•

Methodology ............................................................................................................. 16•

The population........................................................................................................... 17

1.3

Analysis of the deepnude market.............................................................................. 18

Deepnudes: origins, concept and impact ....................................................................... 20
2.1

What are deepnudes: origins, technology and definition ......................................... 20•

Deepnude as a form of deepfake .............................................................................. 20•

Different types of deepnudes .................................................................................... 23•

Terminology ............................................................................................................... 25

2.2

Deepfake and gender: an underexposed factor ........................................................ 25

Deepnudes as a form of digital image-based sexual abuse ........................................... 29
3.1

The impact of deepnudes on victims......................................................................... 29

3.2

Perpetrators............................................................................................................... 31

3.3

Legal framework ........................................................................................................ 33•

The image created…………………………………………………………………………………………………33•

Whether or not there is consent ............................................................................... 34•

The technology used.................................................................................................. 34•

Regulation at the EU level ......................................................................................... 35

Deepnudes among young people in Belgium ................................................................. 37
4.1.

Familiarity with deepnudes amoung young people in Belgium ................................ 37•

Have you ever heard of deepnude? .......................................................................... 37•

Have you ever seen a deepnude? ............................................................................. 38•

How did you see these images? ................................................................................ 39•

Through which platform did you see a deepnude? .................................................. 39

4.2.

Deepnudes among young people in Belgium: receiving, possessing and making .... 40•

Have you ever received deepnudes? ........................................................................ 40•

Do you have deepnudes in your possession? ........................................................... 40
5

5.

6.

•

Do you know of an app that can create deepnudes?................................................ 41•

Have you ever used this app to create a deepnude? ................................................ 42•

Why did you create a deepnude?.............................................................................. 42

4.3.

Conclusions: deepnude is making itself known among young people in Belgium ... 43

The deepnude apps market ............................................................................................ 46
5.1

The deepnude apps market ....................................................................................... 46

5.2

Analysis of deepnude apps: words vs. reality. .......................................................... 49•

Whether there are any terms of service and privacy policies................................... 49•

The contents of the terms of service: copyright, CSAM and consent ....................... 49•

Underage users .......................................................................................................... 50•

Liability and waiver of liability of the apps ................................................................ 50•

Words vs. reality: systems analysis ........................................................................... 51•

Conclusions ................................................................................................................ 54

5.3

The legal framework and legal gaps for deepnude apps .......................................... 55•

Criminal liability for deepnuding of adults ................................................................ 55•

Criminal liability for deepnuding of minors ............................................................... 56•

The future: the AI Act of the European Union .......................................................... 58

5.4

The future of deepnudes ........................................................................................... 59

Conclusion and recommendations ................................................................................. 62
6.1

General conclusions................................................................................................... 62

6.2

Recommendations ..................................................................................................... 64

Bibliography ............................................................................................................................. 67

6

Abbreviations
AI

Artificial intelligence

CSAM

Child Sexual Abuse Material

DSA

Digital Services Act

EU

European Union

GAN

Generative Adversarial Networks

GDPR

General Data Protection Regulation

IBSA

Image-based sexual abuse

NCMEC

National Center for Missing and ExploitedChildrenNCII

Non-consensual
dissemination

NSFW

Not Safe For Work

RTA

Parental
control
Parents/Adults)

ToS

Terms of Service (also: Terms of Use or
Terms and Conditions)

intimate(Restricted

imagesto7TermsAI porn app

An app or website that allows users to create a nude image
generated by artificial intelligence

AI Regulation

Proposal for Regulation establishing harmonised rules on
artificial intelligence. This proposed regulation includes
rules for the use of artificial intelligence in the EU.

Bot

A 'bot' - short for robot - is a software programme that
automatically performs repetitive and predeterminedtasks. Bots typically mimic the behaviour of a human user.

Caching service

Service consisting of the transmission in a communications
network of information provided by a recipient of theservice, in which this information is automatically,
intermediately, and temporarily stored for the sole
purpose of making the subsequent transmission of thisinformation to other recipients of the service more
effective, if they so request.

Cheap fakeA deepfake which has clearly been manipulated.

Deepfake

An image or video of a person in which their face or bodyhas been digitally altered so that they appear to besomeone else, usually used with malicious intent or to
spread false information.

Deep learning

A form of technology that allows computers to simulate
the workings of the human brain. It instructs computers tolearn and make decisions autonomously, without explicit
programming. Instead of explicitly telling the computer
what to look for, a vast quantity of examples is shown tothe computer, allowing it to learn on its own.

Digital Services Act (DSA).

Regulation on a Single Market for Digital Services andamending Directive 2000/31/EC. The legislation regulates
online intermediaries and platforms such as social
networks, for example. The main goal is to prevent illegal
and harmful online activities and the spread of
disinformation.

8

Doxing

The sharing of information or an image together withpersonal data of a person, so that the person can be
identified by others for the purpose of harming or
humiliating that person or making them a laughing stock.
Doxing is a portmanteau of the term 'dropping dox', with'dox' being an abbreviation of 'documents', and meaning‘to publish documents’.

Exposing

Disseminating private images or personal information
without consent, to harm or humiliate the person
depicted, or make them a laughing stock.

Face swap

Technology that allows an image of a face to be
manipulated onto another image.

Generative Adversarial
Networks (GAN)

A generative model where two networks compete in agame theory scenario. The first network is the generator,
which generates a sample (for example, an image), while
the adversary, the discriminator, tries to detect whether
the sample is real or was 'fabricated' by the generator.

Aggregated data

A process in which information is collected and expressedin summary form, for purposes such as statistical analysis.

Grooming

Grooming involves luring children online. The groomer
often pretends to be a boy or girl about the same age as
the child and tries to contact young girls or boys online ,often trough social media.

Hosting service

Service whereby information provided by the person using
the service is stored, at their request

Mere conduit service

Service that consists of the transmission of information in
a communications network provided by the person using
the service, or the provision of access to a communication
network

Personal data

Any information that allows a natural person to be
identified. For example: national registration number, aphotograph, etc.

Prevalence

How often a particular phenomenon occurs among adefined group of respondents.

9

Prompt

A textual or visual input that instructs the model togenerate a specific type of output

Directive on gender-based
violence

Proposal for a Directive of the European Parliament andthe Council of the European Union on combating violenceagainst women and domestic violence. Among otherthings, this provides for the criminalisation of certain formsof violence against women and domestic violence, thestrengthening of victim support and improved access ofvictims to justice and to appropriate protection.

Sextortion

Extorting a person by threatening to disseminate an
intimate image unless certain demands of the extortionist
are met. Sextortion is a portmanteau of the words 'sex' and'extortion'.

Tubesite

A website for uploading and playing videos.

Undress app

An app or website that allows users to upload a clothedphoto of a person, which is then transformed into a naked
image.

Victim blaming

Victim blaming is when an individual who suffers a
traumatic event is held responsible, in the view of others,
for what happened to them.

10

Deepnude figures among young people in Belgium summarised
Digital sexual violence is a rising phenomenon among young people. This study discusses a
specific variant of digital sexual violence, namely deepnudes. Deepnudes are defined asrealistic but completely fake images or videos of another person, using artificial intelligence.
This study examines to what extent young people in Belgium between the ages of 15 and 25(N=2819) are aware of deepnudes, and how prevalent these images are.
This research provides a detailed look at how deepnudes are part of the lived of young people
in Belgium. For example, 41.9% of respondents were found to have previously heard of thephenomenon of "deepnudes," with striking differences according to gender, age, region andsexual orientation.
Furthermore, 23.1% of respondents have previously seen a deepnude, primarily throughsocial media, with Snapchat, Twitter/X and Instagram being the most common platforms. This
raises questions about how these platforms are regulated, and the need for awarenesscampaigns.
A deeper dive into the behaviour of individuals familiar with deepnude apps (12.8%) reveals
that 60.5% have attempted to create one, with men significantly more likely to engage in such
behaviour. The motivations range from getting revenge to impressing friends, reinforcing callsfor educational programs and regulation.
7.6% of respondents actually have deepnudes in their possession, mostly men and adults.
Raising awareness about the illegal and harmful aspects of possessing deepnudes is therefore
essential. Similarly, 13.8% of young people in Belgium have previously received a deepnude,again with significant differences based on gender, age and region.
The results of the study highlighted significant gender differences in all the variables studied
relating to deepnudes. Men are significantly more likely to be familiar with deepnudes, lookat them, attempt to create them, possess them and receive them. These significant
differences suggest that deepnudes may be a gender-related problem, with men being
overrepresented in all aspects of this digital phenomenon. It is essential to conduct further
research on this finding, as the study population in this study is too small to draw definitive
conclusions.
11Based on the results of the study, various recommendations have been formulated, includingheightened regulation of the platforms, awareness and education, stricter rules for deepnude
apps, as well as legal measures to adequately address this form of digital sexual violence.
Moreover, there is a need for additional research into deepnudes, including on thepsychosocial impact deepnudes have on victims. Monitoring trends and evolutions regarding
deepnude technology is also essential to formulate policy measures.

12

An introduction to digital sexual violence: deepnudes
In 2018, Rana Ayyub, a respected Indian journalist, was invited to share her views on thecurrent political situation in India during a news broadcast. Just two days after her televisionappearance, Ayyub received a link from several friends, which she opened curiously. To her
astonishment, she found a fake sexual video clip in which she was depicted, which went on tohave devastating consequences for her personal and professional life (Ayyub, 2018).
In recent years, we have witnessed a remarkable rise of artificial intelligence (AI) and deeplearning technologies (Albahar & Almalki, 2019). While these developments are promising andhave a wide range of positive applications, such as grief counselling and entertainment, they
have also opened the door to alarming, harmful possibilities (Van der sloot et al., 2021). Oneof the most controversial and disturbing applications of AI is the creation of deepnudes, inwhich artificial intelligence is used to generate realistic-looking sexual videos and images of arandom victim (Floridi, 2018).
Deepnudes can be categorised under the broader heading of image-based sexual abuse(IBSA). This terminology is strictly defined as the unauthorised making, sharing or threatening
to share nude or sexual images of someone (Powell et al., 2020). In a broad sense, thisterminology is used for all forms of digital sexual violence involving images, meaning that, forexample, it also includes sending naked images without consent (cyberflashing) (Walrave etal., 2023). While abuse involving sexual images is unfortunately nothing new, advances intechnology have made it easier than ever for this form of sexual abuse to occur (McGlynn &Rackley, 2017). Today's highly visual culture, in which every moment is shared online, in turnfurther amplifies this phenomenon (Walrave & Gilen, 2024).
The proliferation of this technology is alarming for several reasons. First, the line between'authentic' and 'fake' is extremely blurred, making it very difficult, and sometimes impossible,
to distinguish an authentic image from a fake one (Ahmed et al., 2022). Moreover, thetechnology for creating deepnudes is widely available and easily accessible. A simple searchon online search engines already directs users to various simple websites and downloadable
apps that allow anyone to generate their own deepnudes. Because apps/websites are
removed just as quickly as they are thrown online, it is difficult to effectively keep track of

13

them. As a result, the threshold for trying this is particularly low, in part because advanced
digital skills are no longer required to achieve realistic results (Henry et al., 2018).
Moreover, creating and sharing deepnudes has been shown to have a significant impact on
the victim. According to Hao (2021), the mental consequences of deepnudes are comparable
to those of IBSA in its 'traditional' form, as, for example, when transgressive sexting images
are forwarded. We are currently at the point in technological progress where, once an image
is online, it can be reproduced over and over. As a result, there is a real risk that victims will
face the traumatic impact of their experience their whole life, also known as the digital
footprint (Institute for the equality of women and men, 2020).
This report focuses on deepnudes and their prevalence in the lives of 2,819 young people inBelgium between the ages of 15 and 25. A questionnaire was sent out, in which various
questions sought to explore whether respondents were aware of the issue, as well as whether,for example, they themselves had already tried to create a deepnude. Through this report, we
attempt to paint a clear picture of the extent to which this problem is prevalent among young
people in Belgium. Recommendations have also been set out that are not only guidelines on
how to deal with these issues at the policy level, but also how the average citizen can best
approach them. The report can serve as advice for organisations active in the field of media
literacy and online safety for e.g. awareness campaigns.

14

1. The study
1.1 Mission and objectives
At the request of the State Secretary for Gender Equality, Equal Opportunity and Diversity,
the Institute for the equality of women and men funded a research project among young
people regarding deepnudes (IGVM/EDP/2023-32). The overarching goal of the research was
to identify different forms of digital sexual violence through actual numbers and analyses onthese phenomena among young people in Belgium. The results are broken down by gender,
age, sexual orientation and regional distribution of the respondents, and are also
representative. The research was intended to build on research already conducted andongoing into digital sexual violence.
➢ This resulted in 4 specific objectives for the research into deepnudes

Literature review

SurveyLegal framework

Gain insight intoscientific knowledge
about deepnudes

Prevalence researchamong young
people in Belgium(15-25) about
deepnudes

Get an overview of
the current legal
framework andidentify any gaps

Analysis of thedeepnude market
Gain insight into themarket for
deepnude apps, andits legal regulation

The research is being conducted by the University of Antwerp, specifically by the researchteam led by prof. dr. Catherine Van de Heyning and prof. dr. Michel Walrave, a researcher
specifically appointed for the study, Nina Dakota Szyf, doctoral researcher Aurélie Gilen andprof. dr. Mona Giacometti. This study builds on a broader study of online violence, namely the@ntidote study, in the context of the Brain 2.0 projects funded by the Belgian Science Policy
Office. The research team collaborated with Profacts for the online survey of young people.

15

1.2 The survey study•

Methodology

Based on a literature study, a survey was conducted among young people in Belgium between
the ages of 15 and 25 about whether they were aware of, or had experienced deepnudes. It
was examined not only whether respondents had ever heard of deepnudes, but also whether
they had previously attempted to make a deepnude themselves.
In particular, the survey looked at possible differences based on four variables, namely gender
identity, age, sexual orientation and regional distribution. The following subcategories werethen set up within these variables, to be used in the analyses:•

Age: minor versus adult•Sexual orientation: heterosexual versus LGBTQIA+•

Gender identity: male, female, and other categories•

Regional distribution: Flanders, Brussels and Wallonia

It was examined whether there were significant differences at a 95% confidence interval using
chi-square tests on SPSS. The results of the survey were always framed within the existing
research.
The data were collected over two time periods, by the market research agency Profacts. The
first round took place in January 2023 (N=1819). However, to maximize the number of
respondents, the research team decided to send the online survey to an additional 1,000
participants (N=1000) in April 2023. A total of 2,819 respondents participated in the survey.
Since the study examined sensitive topics among young respondents, the team informed
potential respondents about the content and purpose of the study, and requested explicit
consent to participate. Respondents under the age of 16 could not be recruited directly; theirparents were therefore contacted by the market research agency to give informed consent
for their child to participate in the survey. Profacts works with a reward system, where
respondents can earn 'points' that can later be redeemed for a small sum of money or donatedto charity. Due to the sensitivity of the topic, all respondents were given an information leaflet
at the end of the survey with referrals to formal victim support organisations.

16

The complete process was submitted to and approved by the Ethics Committee for the Social
Sciences and Humanities (EA-SHW) of the University of Antwerp.
Finally, the current legal framework was also analysed to see how the phenomenon iscurrently criminalised. This was supplemented by a brief discussion of how deepnudes are
currently legally embedded in the European Union.
•

The population

The survey had a total sample of 2,819 respondents between the ages of 15 and 25. The
sample had a comparable representation based on age, from both minors and adolescents.

Chart 1: Age distribution of respondents

As the views of young people in Belgium were being surveyed, there also had to be a good
distribution between the different language groups, so the survey was drawn up by the inboth Dutch and French with a coherence check by the research team. This led to the following
distribution of respondents between Flanders, Brussels and Wallonia.

Chart 2: Regional distribution of respondents

The distribution of respondents according to gender, age and sexual orientation was divided
representatively over the Belgian population based on data from Statbel. This means an equal

17distribution for male and female respondents, with a limited representation of other gender
identities, and an equal distribution of Dutch and French speakers.

Chart 3: Gender distribution of respondents

Chart 4: Sexual orientation of respondents

1.3 Analysis of the deepnude market
To get a better understanding of the position of deepnude apps with respect to potential
malicious applications, the 25 most widely used and popular deepnude apps were analysed.
The so-called walkthrough method was used in this regard, in which sites or apps are analysedand compared systematically for an exploratory view of the market for deepnude apps (Lightet al., 2018).
For an analysis of the framework of deepnude apps, 25 deepnude apps were selected based,
firstly, on the number of users in the month of October 2023, as well as an analysis of 50
review lists based on the most recurring apps. The caveat with this study is that the selection
is a snapshot in time. As such, the objective of the study is not to make an analysis of the 25
largest deepnude apps, but rather to get a better view of the structure of these apps, whereby
the selection offers an overview of the market. Only apps that make it possible to undress real
people were included in this selection, either through Face Swap techniques or Undress
techniques. AI porn apps that create entirely virtual images were therefore excluded.
Similarly, only apps were included that explicitly focus on creating deepnudes, and which
advertise this fact. Apps that make it possible to edit images and could potentially, with theright knowledge and expertise, be used to undress images but are not intended or advertised
for this purpose, were also excluded. This list represented at least 219.826 million visitors in
the month of October 2023. This is only an indication since some apps are not included in theanalysis by the used analysis application app Semrush.

18

These apps were analysed for what content and actions are prohibited by the Terms of Service(ToS), the extent to which consent is emphasised in the ToS and on the app itself as the basis
for deepnuding, the waiver of liability, the policies regarding underage users in the ToS andelsewhere on the app, and finally the way the site is advertised and the role of consent andlegal or ethical use in this advertising and marketing.

19

2. Deepnudes: origins, concept and impact
2.1 What are deepnudes: origins, technology and definition•

Deepnude as a form of deepfake

Manipulating images and sound is as old as media itself, with optical illusions being a classic
example (Kietzman et al., 2019). In recent years, however, technological advances have led to
new forms of image manipulation, deepfakes being one notable example (Albahar & Almalki,2019). Digital technologies, in particular artificial intelligence, are making it increasingly easierto create images that appear lifelike with a few clicks of a computer mouse. This technique iscalled deepfake, a portmanteau of 'deep learning', i.e. a form of artificial intelligence modelledon neural networks to train itself based on previous analysis, experiences and data to makeaccurate predictions (Floridi, 2018; Whittaker, 2020), and 'fake'.
The foundations for this technology were laid by applying Generative Adversarial Networks(GANs) to images (Kalpokas & Kalpokiene, 2023). This technology allows software to train ona vast quantity of images to make estimates of what an image should look like based on aprompt. For example, the prompt may consist of a specific edit of a particular photo ('imagine
my cat as a unicorn'), after which the software will modify the photo based on input fromhundreds of images that are in the database or can be found online using mathematicalformulas. This technological approach makes it possible to digitally manipulate images andgenerates hyper-realistic photographs and videos in which individuals make gestures and saythings that never actually happened (Westerlund, 2019; Chesney & Citron, 2019; Flynn et al.,2022).
These days, there are countless apps online that make it possible to create these deepfakes.
Experts predict that the use of deepfake technology will increase exponentially, with some
expecting that more than 90% of digital content will be manipulated within around five years(van der Sloot et al., 2021). A study by an American privacy company, Home Security Heroes(2023), found that 95,820 deepfakes had already appeared on the Internet by 2023. Although
this figure will already be higher by now, this is a 550% rise compared to 2019. This confirms
the assertion by Maddocks (2020) that there is an urgent need for research and effective
action.

20

Deepfake apps are used for legitimate and non-harmful applications, such as entertainment.
Just think of the many popular AI filters to create fantasy images of yourself. However, Albahar
and Almalki (2019) warn that the technology is also increasingly being used for alarming
activities, including cybercrime or grooming young people. Deepfakes are therefore ideal for
facilitating image-based digital abuse and image-based sexual abuse in particular. This
deepfake technology has been further developed to create sexual images, with or without
their consent. What is more, it appears to be one of the most prominent forms of deepfake
images online. As many as 98% of the deepfakes circulating online are sexually explicit andprimarily depict female victims (Home Security Heroes, 2023). Researchers have therefore
been warning for several years that these forms of deepfake and, in particular, deepnuding,
namely the digital undressing of an individual using AI, are reaching alarming proportions(Gieseke, 2020; Maddocks, 2020). From a historical perspective, undressing someone without
their consent is nothing new.
Many painters, illustrators, sculptors and cartoonists have created nude images of individuals
without their consent. Cartoonists often depict figures of authority in the nude, to question
or criticize them. Moreover, with digital apps such as the first generations of Photoshop
software, it became possible to cut and paste faces from photographs onto existing nude
images. The major innovation in deepnude technology is not so much the fact that someone
is depicted naked, but the fact that these images are so believable. Looking at cartoons,paintings or even professional Photoshop images, it was still obvious that it was not a real-life
photograph of a person who was actually naked in the picture. This line with reality is blurredby deepnude technology.
The use of deepfake to create a sexual image was first done by an anonymous user named
u/deepfakes from the social platform Reddit. Under the code name 'deepfake', this user set
up a Reddit group. He shared naked images of famous actresses in the group, which he createdbased on GAN technology. These first images were still easily recognizable as fake. Reddit took
action in 2018 and removed this group from the platform. However, it was the start of a race
toward increasingly realistic naked images. The same year, on another social medium Github(an online platform for software development and release management), an Open Source
deepfake generator was published that allowed all Github users to get started with this21

technology. Once again, it was still rudimentary technology, but because it was open source,
all users could improve the generator.
The next step was in 2018 when "FakeApp" was introduced on Reddit. This app allows users
to easily create deepfakes for free. This easy access to the technology led to a significant risein non-consensual deepnudes. A (now banned) subreddit, a page on Reddit where users cometogether to discuss a specific topic, was dedicated to making deepfakes by inserting the facesof female celebrities into pornographic videos. Within months of its launch, FakeApp had been
downloaded more than 100,000 times, allowing ordinary individuals to create realistic
deepfakes (Hern, 2018).
The major breakthrough and commercialisation of deepnude followed in 2019 with the launchof Deepnude website, with a more professionally developed app that could be used to create
realistic naked images (Cole, 2019). This app runs on both Windows and Linux. The app was
basically free, but premium subscribers could create a photo without a watermark. This meantthat the images were lifelike and without an indication that they were deepfake images.
Protests against this app led to it being taken offline in June 2019 (Cox, 2019). However, thesource code remained on Github for a long time, so it could still be used and further
developed.
In addition to apps, bots were placed on communication apps that can digitally undress
images. From mid-2019 on, bots could be found on the encrypted Telegram. In their report,
the firm Sensity stated that at least 104,852 naked images were taken via these Telegram botsby the middle of 2020 (Sensity, 2020). Whereas the first deepnude apps and bots focused
primarily on creating naked images of famous people, the Sensity study found that 70% of theimages created by these bots were of people who were not famous. These were based on
private, non-publicly available photographs. The report therefore concluded that these bots
were set up to humiliate victims or facilitate sextortion.
In addition to the bots themselves, more and more groups dedicated to creating andexchanging artificial images were popping up on Telegram and as well as other social media.
These groups also regularly shared personal data of the victims, giving them a hybrid characterof deepnude and doxing groups. Furthermore, it appears that an increasingly developed
market has also emerged of individuals offering to create sophisticated deepnudes for others,or deepnude-as-a-service (Gamage et al., 2022; Kikerpil, 2020).
22

These days, there are hundreds of bots and apps that can be easily found through searchengines. The technology has evolved at such a fast pace that the difference between lifelike
and artificial is now indistinguishable. Deepnude is now the most popular application of
deepfake technology, and the moral, ethical, and legal issues associated with developing theseapps and using them does not appear to be an obstacle to their popularity (Gamage et al.,2022).
•

Different types of deepnudes

There are now various techniques for creating deepnudes. In the first technique, it is possible
to replace the face of a naked person with that of another person, with the aim of creating a
deepnude. This technique is called Face Swap (Reehan, 2023). This technology is very easy to
use and is comparable to the common face-swapping filters found on social media (e.g.,
Snapchat). In the first generation of these Face Swap apps, the manipulation was obvious, as
it only used 'face substitution' without taking into account any possible facial expressions. In
her research, Westerlund (2019) refers to these as cheap fakes. Users with limited technicalskills and no artistic expertise are able to process videos, switch faces, change expressions andsynthesize speech. This technology has since evolved to such an extent that the faceseamlessly transitions to the source image that was modified. Below is an example of the app
facechanger.ai that explicitly advertises the fact it creates deepnudes via Face Swap.

The second technique is the Undress technology. This technology uses artificial intelligence topredict how a depicted person would look naked based on just one photo. In this case, no23

additional image is therefore used for the manipulation, but the image of the person is thesource material on which the artificial intelligence is programmed. Below is an example of an
Undress app, where the user simply has to upload an actual photo and then edit it.

The third technique no longer starts from a specific image as the source material to create a
new naked image, but trains through a huge quantity of images to create a completely virtual
naked person. This AI porn technology is therefore not aimed at undressing a real person, butrather at creating a naked image or video of a non-existent person. Through a prompt basedon certain criteria (e.g., hair colour, skin colour or cup size), artificial intelligence will compose
an image. Although this is a completely fictional person, it can be very similar to a real person.
This is the case in particular if there are many public images of this person. For example, inthe prompt, the name of an actress or singer can be entered to develop a new image. Below
is an example from the app Promptchan AI where the prompt consists of creating a naked girlin space.

24

•Terminology

There are currently various apps based on different technologies that make it possible todepict or create a naked person. The question therefore arises as to what deepnude actuallyrefers to in the context of this study. As cited above, the crucial turning point is the use of
artificial intelligence that makes these naked images or images of sexual activity lifelike andbarely distinguishable from reality. As such, for the purpose of this study, a deepnude will bedefined as 'a realistic naked image or image of sexual activity created using artificial
intelligence'.
Several (scientific) articles also refer to pornographic deepfakes. However, we prefer to use
the term 'deepnudes' in this study as the previous term suggests that there is a pornographic
act involved, while this is clearly not always the case. There do not have to be any actual
pornographic acts in order for there to be harmful consequences to the victim (Rigotti &McGlynn, 2022). Moreover, within this category of deepnudes, a distinction must be madebetween legal and illegal images. As will be explained later, images are illegal if they depict
minors and/or if they were taken of a real person without their consent. In the case of theseillegal images, using 'pornographic deepfake' as the terminology would obscure the fact thatthese are indeed harmful images and abuse. By way of analogy with the discussion of childsexual abuse material rather than child pornography, it was decided to use a more neutral
terminology, namely 'deepnude'. Finally, media as well as literature generally refer todeepnudes rather than pornographic deepfakes.
In other literature, the term used is digitally manipulated (sexual) image-based abuse (Flynn,2022). This wording is relevant to encompass the full spectrum of image manipulation. The
focus in this study is on part of this broader group of digitally manipulated (sexual) imagebased abuse, namely the images created and manipulated by AI (deepnuding). Furthermore,this study also further explores the market for apps that use this technique.

2.2 Deepfake and gender: an underexposed factor
Research by the Amsterdam-based company Sensity (2019) found that 96% of deepfakes aresexual in nature. Alarmingly, 98% of these deepfakes are of women (Holmes, 2019; Farish,2021). A study by Home Security Heroes (2023) found that by 2023, no less than 98% of25

deepfakes were sexually explicit, and 99% depict women. Not surprisingly, the vast majority
of deepnude apps, freely available through search engines, focus solely on creating deepnudes
of women. Since the technology trains itself on existing images and previously createdanalysis, a deepnude app will not easily produce the same quality of naked images for men as
for women. The analysis (see below under section 4) shows that these companies primarily
focus on creating nude images of women. Based on his research, Öhman (2019) concludes
that:"Deepfakes are arguably enabled by a MAS of male consumers, producers, technology,
and misogyny. Moreover, it arguably plays a role in the machinery which systematicallyreduces women (as a collective identity) to sexual objects, even if none of the individual
instances can be held to cause this. So it should be fair to say that the phenomenon ishighly gendered" (Öhman, 2019).

These disturbing figures highlight the deeper problems and societal implications associatedwith deepnudes. The fact that the vast majority of these fakes are sexual in nature andprimarily involve women highlights the broader issues of gender inequality and sexual
violence in our society. The figures from this study (see below in section 3) also illustrate thisargument. The phenomenon of deepnudes can be seen as a reflection of deep-seateddisrespect for women and the objectification of the female body that has long been prevalentin our society (van der Sloot et al., 2021). This issue is interconnected with the issue of violenceagainst women, where the victims are often trapped in patriarchal structures and entrenchedhierarchies (Maddocks, 2020). Deepnudes are clearly not an isolated phenomenon, but rather
reflect the deeper gender inequalities in our society (van der Sloot et al., 2021). Deepnuding
without the consent of the person depicted in the image, or of a minor, is therefore clearly
regarded as a gender-based form of digital image-based sexual abuse.
By way of illustration, Tim Berners-Lee, the founder of the Internet, wrote a letter to mark the
31st anniversary of the World Wide Web on 'Why the web needs to work for women and girls'.
He expressed serious concerns about the online harms and threats facing women and girls
and their impact on the advancement of gender equality (Sample, 2020). A similar concern
was raised by a researcher from the cybersecurity firm Deeptrace, which conducted a studyof deepfakes in 2019 in which the researchers found that the majority of deepfakes were26

sexual images of women. Whereas in research, policy and media, the dangers of deepfake
techniques are mostly discussed in the context of misinformation and undermining
democracy, in reality it primarily has a huge impact on the sexual integrity, equality andprivacy of women (Etienne, 2021; Gosse & Burkell 2020).
Despite significant progress in gender equality, much of the social, legal, and political power
remains in the hands of men (Citron & Franks, 2014). Women have been sexually objectified
for years, and insufficient action has been taken in this regard (Holmes, 2021). Recognisingdomestic violence, sexual assault and sexual harassment as serious problems has been a longand bitter struggle, and yet there is still a tendency to downplay these problems. IBSA affects
women more often than men and often has more serious consequences for them (Farish,2021). Unfortunately, the willingness of downplaying the harms this problem causes ispredictable (Citron & Franks, 2014).
Images of female bodies distributed online are often associated with promiscuity, while
images of naked men are given a different status. This gender bias, combined with risk-taking
behaviour online, often leads to victim blaming. Although gender inequality has largely been
reduced, this finding shows that there is still an existing paternalistic and punitive system thatseeks to protect women while seriously restricting their sexual freedom (Lageson et al., 2018).
This raises important questions, such as: "To what extent does the fact that victims areprimarily female affect the legal approach?" or "Does the gender of the victim affect their
credibility?"
The overarching problem goes beyond deepnudes and is deeply rooted in society. In
addressing this core issue, it is critical to look beyond laws and punishment. As a society, weneed to address the deep-rooted tendency to want to see women naked without theirconsent. If we do not do this, the vicious cycle of sexual violence against women will most
likely be perpetuated. It is important to note that technology such as deepfakes is notnecessary to express misogyny. All it takes is a negative attitude toward women together witha desire to express this attitude publicly (Burkell & Gosse, 2019). All of the phenomena
mentioned above share a common denominator, namely intimidation and abuse, whichprimarily affect women (McGlynn et al., 2017).
This highlights the need for profound social change to address these issues and promotewomen's equality and dignity. It is not only a question of laws and regulations, but also of27

changing attitudes and tackling deep-rooted gender inequality in our society. Fully grasping
this problem is vital to identifying effective solutions and ensuring that women and girls
receive the protection and equality they deserve.

28

3. Deepnudes as a form of digital image-based sexual abuse
3.1 The impact of deepnudes on victims
Deepnudes can have a devastating impact on victims (Hao, 2021, Flynn et al., 2021). One
victim of deepnude expressed the following when she found out that her Facebook photos
had been edited and shared in an online group, "When I first saw the images, I broke down. I
felt violated" (Gillespie, 2020). The mental impact of deepnudes are serious and include posttraumatic stress disorder, anxiety disorders, depression, loss of self-confidence and evensuicidal thoughts (Hao, 2021). Because manipulated images are increasingly indistinguishable
from actual images, victims of deepnudes appear to experience similar mental consequences
and impacts as victims of digital image-based sexual abuse in 'regular' non-manipulated form,
such as the dissemination of actual nude images (Dodge & Johnstone, 2018; Delfino, 2019;
Gieseke, 2020). Victims experience similar symptoms, suggesting that deepnudes carry thesame serious mental impact as other sexual offences. The seriousness of digital image-based
sexual abuse must not be underestimated, and interventions used for victims of sexual abuseshould also be applied to victims of deepnudes (Bates, 2016; Powell et al., 2018; Henry, 2021;
Flynn, 2022). Not only does the impact of the violation of sexual identity contribute to theharm suffered by the victim, but also the fear that these images will be shared. Previous
research shows that the sharing of nude images has a huge impact on the physical,
psychological, professional, and relational lives of victims (Bates, 2016; Walrave et al., 2023).
What is more, the digital memory of the Internet means that it is difficult to remove theseimages (Okolie, 2023). Victims whose images have been spread online face the prospect ofsuffering with trauma for life (Institute for the equality of women and men, 2020). The factthat these images are permanently on the Internet therefore causes significant stress to thevictims (Gieseke, 2020). They experience a sense of powerlessness and loss of control overtheir own bodies and sexuality. The fear that people who know them will see their intimate
images leads to shame and may even result in isolation and depression (Rogers, 2022; Powell
et al., 2020).
The specific context of distributing nude images, including deepnudes, can have a significant
impact on how victims are viewed and treated (Maddocks, 2020; Powell et al., 2020). Researchshows that respondents perceive the harm of deepnudes to celebrities and men as less29

harmful than deepnudes of non-celebrities and women (Fido et al., 2022). Indeed,
respondents estimated that the impact on non-famous women will be greater than that on
celebrities and men. The same study suggested that respondents also judge people who
create images for their own sexual gratification more harshly than people who distribute theseimages. This assessment is combined with personal insight and an estimate of the impact on
a non-famous woman having nude images of her shared online, assuming that the impact issimilar for real as well as virtual images.
The regional or cultural context may also influence the impact of deepnude images on thevictim. This phenomenon is illustrated through two case studies, those of Rana Ayyub andWelmoed Sijtsma. Indian journalist Rana Ayyub openly expressed her views on child abuse
during a news broadcast. In April 2018, a deepfake sex video appeared in which Ayyub was
depicted engaged in a sexual act, which had never actually happened. The video spread likewildfire, appearing on more than half the mobile phones in India within 48 hours. Ayyub's
Facebook profile and Twitter account were flooded with death threats and rape threats.
Posters were even put up revealing her home address. (Ayyub, 2018).
Dutch presenter Welmoed Sijtsma was subjected to the same experience, but the specificcultural context meant that her experience was very different. Sijtsma was able to continue
her career and she even produced a documentary series entitled 'Welmoed and the sex fakes',in which she successfully identified the perpetrator. Sijtsma spoke openly about the impact
on her mental well-being. The different cultural context meant that she was supported in her
fight against deepnudes. These specific cases highlight the importance of conducting further
research on the impact of deepnudes on victims, including the specific social and culturalcontext, which is still currently in its infancy.
This context is determined not only by the culture in which it occurs, but by a broader, global(online) culture of objectification of women and gender inequality. The impact on victims ofdigital image-based sexual abuse, including deepnudes, is related to this cultural aspect.
Whereas according to the current scientific knowledge, deepnudes are viewed with alarm,some researchers argue that deepnudes may also help reduce the impact of digital imagebased sexual abuse. Because any image can be manipulated, images will have less value in ourassessment of reality (Voto & Viola, 2023). In this sense, they see deepnudes as aphenomenon that may have positive consequences in addition to negative ones. However,30this evolution depends on cultural change, the underlying trends of which cannot currently beobserved in research. Other researchers suggest that this trend actually further objectifies thefemale body and undermines the discourse on consent and sexual integrity (Mayoyo, 2023).

3.2 Perpetrators
Up until now, there has only been very limited research on the individuals behind deepnudes.
The most comprehensive survey was organised in mid-2019 among 6,109 respondents
between the ages of 16 and 64 across the United Kingdom (n = 2028), New Zealand (n= 2027)
and Australia (n = 2054) (Asher et al., 2022). The study was not restricted to deepnudes but
looked at the broader category of digitally manipulated images. It showed that 5.4% of
respondents had already created a manipulated image, 4.4% had already shared such animage and 4.2% had already threatened to distribute such an image. The study found that ahigh percentage of the perpetrators of one of these acts would also commit the other. In otherwords, individuals who created images would usually share them and vice versa. The study
showed that there was no significant difference between the different countries, and there
was therefore a similar trend. Other criteria did however prove significant. Men were foundto be the perpetrators of these deepfakes significantly more often. Additionally, it was foundthat LGTBQI+ individuals reported being more likely to be involved in creating deepfakes but
were also more likely to be the victims of them. The same was true for people with mental or
physical disabilities. They also scored higher in terms of being perpetrators and victims. Finally,
it was found that younger respondents were more likely to be victims and perpetrators thanolder respondents. This last finding was attributed to the fact that young people are more
active on social media and more aware of new digital applications.
This raises the question of why someone would create and distribute these images. Previous
research suggests that there are often multiple motives for creating, possessing, anddisseminating digital image-based sexual abuse (Flynn, 2022; Walrave et al., 2023; Van de
Heyning & Walrave, 2024a; Van de Heyning et al., 2023). Deepnudes are no exception in thisregard (Powell et al. 2020; Flynn, 2022). These images are mainly created for pleasure andsexual arousal. Users also mostly misjudge that using these filters would not be harmful orpunishable.

31

In the study by Powell et al. (2020) into Australian users of deepnudes, it was found that lessthan half of the respondents were aware of the criminal law implications of digital imagebased sexual abuse (Powell et al. 2020). These findings highlight the need for awarenessraising initiatives, to make it clear that these actions are indeed punishable by law and should
not be seen as 'just another fun thing' (Szyf, 2023).
This lack of awareness should also come as no surprise given the large number of apps simply
presented by search engines. The fact that these apps can be found with a single mouse click
may give the impression that deepnuding is perfectly lawful. This impression may be
reinforced by the numerous online deepnudes of people, famous or otherwise. Any possible
feeling that creating deepnudes is immoral and unethical will then likely be dismissed as aresult (Öhman, 2022). Furthermore, deepnudes are still a relatively new phenomenon which
are generally not covered in education and training on media literacy and sex education.
Finally, deepnuding is also still not a criminal offence in many countries.
Indeed, the fact that the perpetrators use this technology for pleasure can be rather
problematic on a moral and ethical level (Williams, 2023). The previous argument was also
highlighted by a survey by eSafety (2019), the independent Australian regulator of online
safety. This study focuses on studying the motivations for sharing IBSA, such as deepnudes. It
became apparent that this phenomenon was very common and normal according to theperpetrators. Some perpetrators even argued that they had noticed people committing
similar actions and 'getting away with it'. The report reiterates the need to take more action
to counteract the normalising culture surrounding image abuse.
An important note here is that deepnudes differ from other applications of deepfake
technology to a certain extent, as these photos and videos are not necessarily intended to
disguise the fact they are fake, unlike, say, political deepfakes. These fake sexual images are
created and shared primarily for sexual gratification rather than emotional manipulation or
defamation (Williams, 2023). There are also other situations where the victim is blackmailed
with the images, such as in cases of sextortion. This term refers to situations in whichperpetrators threaten to publish sexual images if the victims do not cooperate in doing things
such as performing sexual acts, paying money or other demands (Wolak et al., 2018). Anothermotive may be that the perpetrators want to experiment with the technology. Here again,32

perpetrators argue that it is not a criminal act but a form of entertainment or fun (Andreasen
et al., 2022).

3.3 Legal framework
Whether creating deepnudes is a criminal act depends on the image created, whether or notthere is consent, and the technology used.
•

The image createdCreating a nude image or image of sexual activity with a minor is always a criminal act underthe Belgian criminal code. After all, this is child sexual abuse material/CSAM or child sexual
exploitation material/CSEM and is always illegal. At both the national and supranational levels,
it does not matter whether the image was of a real child, a manipulated image of a real child,or a virtual image of a non-existent child. The Lanzarote Convention provides in this sense thatchild sexual abuse material consists of:"Any material that visually depicts a child engaged in real or simulated sexually explicit
conduct or any depiction of a child’s sexual organs for primarily sexual purposes."1
Similarly, the EU CSAM Directive2 defines child sexual abuse material as any material thatvisually depicts any person appearing to be a child engaged in real or simulated sexually
explicit conduct or any depiction of the sexual organs of any person appearing to be a child,for primarily sexual purposes. Belgian criminal law implemented the more detailed definitionof child sexual abuse material in Article 417/43 of the Criminal Code. Creating a deepnude ofa minor, as well as making an image to depict a minor using this technology, is a criminal
offence. In addition, the Criminal Code criminalises a range of activities related to child sexual
abuse material, such as exhibiting, offering, selling, renting, broadcasting, delivering,
distributing, making available, handing over, manufacturing or importing (art. 417/44 Criminal
Code), possessing, and acquiring (art. 417/46), and accessing images of sexual abuse of minors
through information and communication technology (art. 417/47). In this regard, the Court ofCassation ruled that pursuant to Article 417/47 of the Criminal Code, even merely visiting a1

Council of Europe Convention on the Protection of Children against Sexual Exploitation and Sexual Abuse, doneat Lanzarote on 25 October 2007 (CETS 201), approved by the Act on approval of 7 February 2012, Belgian Official
Gazette 21 June 2013.
2
Directive 2011/93/EU of the European Parliament and of the Council of 13 December 2011 on combating thesexual abuse and sexual exploitation of children and child pornography, and replacing Council Framework
Decision 2004/68/JHA, OJ L-335.

33website containing child sexual abuse material and scrolling through it is enough to be foundguilty of possessing child sexual abuse material.3 Since these provisions build on the broad
definition of child sexual abuse material, these provisions also apply to deepnudes of minors.
•

Whether or not there is consent

Regarding adults, the critical question is whether consent was given for these images to becreated and shared. Indeed, creating deepnudes without consent is a criminal offence under
the prohibition on voyeurism (Art. 417/8 Criminal Code). Voyeurism is broadly defined,meaning that not only observing a naked person is punishable, but also making sound or video
recordings of this person while they are naked. During the parliamentary discussions, it was
explicitly stated that creating deepnudes (or deepfakes) also falls under Article 417/8 of the
Criminal Code, that is if these images were made without the consent of the person in theimage.
Not only creating, but also sharing, showing, or making nude images or images of a person
depicting explicit sexual activity accessible without consent, is punishable (Art. 417/9 Criminal
Code). If there is malicious intent or for profit, it even counts as an aggravated offence (Art.
417/10 Criminal Code). Like in the provision of voyeurism, the legislator here uses the broad
terminology of 'an image', without defining that it must be an actual depiction of the person.
The Court of Cassation has already ruled that the definition of this offence is fulfilled if theimage of a person who is identifiable has been disseminated (Van de Heyning, 2024b). The
question then presents itself as to whether creating or distributing a nude image is a criminal
act if it involves a completely fictitious person.
•

The technology used

In the run-up to the Act on sexual offences of 2022, the legislator discussed whether there
was a situation of voyeurism if these images were created using deepfake techniques. The
legislator believed that this is the case, as long as the images have been partially edited.4 Thisshould be understood as meaning that a real photograph(s) or video(s) of a person is editedwith artificial intelligence that results in the person being depicted naked without the person's

3

Cass. 20 April 2011, AR P.10.2006.F., Arr.Cass. 2011, vol. 4, 1034; RABG 2011, vol. 14, 959, note S. Berneman,
RDTI 2011, vol. 44, 27, note N. Blaise.
4
Report of the first reading of the draft law on amendments to the Criminal Code relating to sexual criminal law,Parl.St., Chamber 2020-2021, No. 55-2141/006, 64.

34

consent. This is the case with deepfake technologies such as Faceswap or Undress apps. Fulldeepnudes on the other hand, do not constitute criminal voyeurism.5 This is the case when anude image of a non-existent person is created with AI porn apps, even if the fictional personclosely resembles a real person.
This distinction seems less relevant to the non-consensual distribution (Art. 417/9 Criminal
Code) of deepnudes, given the case law of the Court of Cassation. Since the Court provides
that the non-consensual distribution of nude images is a criminal offence if a person isrecognisable, it can be assumed that this is the case when an AI-porn deepnude is created thatis very similar to a person, and all the more so if it is accompanied by doxing, meaning
attaching personal details such as a name or account of this person. After all, the person who
created and distributed the deepfake image wanted to make it appear that it was a real person
and was recognisable as such to others.
•

Regulation at the EU levelNot only Belgium, but also other countries in the EU have been pondering in recent years
whether their criminal law is sufficiently future-oriented to meet the new digital challenges.
A number of member states, including Belgium, have re-examined their legislation to be able
to punish online digital image-based sexual abuse, whether or not this includes deepnudes,
while others counted on the existing framework to meet these challenges (Mania, 2024).
Research has already shown that deepnudes do present new challenges to legislators,
particularly where this legislation assumes that it is a real image of a person (Mania, 2024; Vande Heyning et al., 2024a).
A draft directive on gender-based violence that also applies to manipulated images, including
deepnudes, is currently being presented at EU level.6 Article 7(b) of the current draft requires
member states to criminalise the production or manipulation and subsequent access, without
consent, to intimate images. In the recitals, it is stressed that this provision applies todeepnudes, including manipulated images that closely resemble a real person (Rigotti &McGlynn, 2022; Van de Heyning et al., 2024a). This directive would therefore go beyond the5

Report of the first reading of the draft law on amendments to the Criminal Code relating to sexual criminal law,Parl.St., Chamber 2020-2021, No. 55-2141/006, 65-66.
6European Commission, Proposal for a Directive of the European Parliament and the Council of the European
Union to combat violence against women and domestic violence, COM(2022) 105 final 2022/0066(COD), 8 March2022 (Proposal for a Directive).

35

current Belgian regulations in regards to AI porn apps. Regulation at the EU level can have amajor impact on the fight against non-consensual deepnudes, as it creates an equal playing
field within the EU on which victims, support organisations, the police and the judiciary canrely with respect to online players, such as social media, to remove images (Mania, 2024).

36

4. Deepnudes among young people in Belgium
4.1.

Familiarity with deepnudes among young people in Belgium

In addition to a literature review, the research team also conducted a survey of adolescentsand young adults between the ages of 15 and 25 on whether they were familiar withdeepnudes. They were asked whether they knew what deepnudes were, if they had alreadyseen a deepnude, and if so, how they had already seen it.
•

Have you ever heard of deepnude?

The literature review shows that deepnude apps and bots are becoming increasingly common
online. Moreover, Google Trends also shows a clear rising global trend for the search terms'pornographic deepnude' over the last five years.

Chart 6: Google Trend for deepnude searches

The question therefore arises, first of all, whether young people have ever heard ofdeepnudes. Two in five adolescents and young adults between the ages of 15 and 25 (41.9%
of respondents) (N=1182) heard about 'deepnudes'. Men indicated (BI = 95%) that they weresignificantly more likely to be familiar with deepnudes (45.7%) than women (38.5%). Thisfinding supports the theory of gender inequality, already laid out earlier in this report, andconfirms the literature, as described by Maddocks (2020), which stresses that deepnudes area gender-related phenomenon.

Chart 7: Distribution of responses to ‘heard of a deepnude’ by gender37

Results show that there is no significant difference in this area between young LGBTQIA+
people and young heterosexual people (48.8% vs. 41.1%). Age, on the other hand, is adetermining factor. Young adults are more familiar with deepnudes (43.9%) than adolescents(33.9%). There is also a significant distinction between different parts of the country. Around
37% of Flemish adolescents and young adults, 44.3% of their Walloon peers and 52.9% of their
Brussels peers have heard of deepnudes. This difference is significant and suggests that, basedon this survey, young people in Brussels are more aware of deepnudes than those in Flanders
or Wallonia.
•

Have you ever seen a deepnude?

In the second stage, the researchers asked respondents whether they had ever seen adeepnude image. The caveat here is that the responses were self-reported, so there is noverification that the image they saw was actually a deepnude. This caveat also applies inreverse. Since these images are now extremely realistic, respondents who answered 'no' to
the question of whether they had ever seen a deepnude may have seen one without realising.
More than one in five (23.1%) of the respondents (N=650) indicated that they had seen an AImanipulated nude image before. The number of respondents who had not yet seen one was
57.2%, while 19.8% said they did not know. When analysing this variable broken down bygender, it was again found that men had seen a deepnude significantly more often (30%) than
women (17%).

Yes

No

Chart 8: Distribution of responses to 'have seen a deepnude' by gender

It is noteworthy that a significant difference does appear for this variable based on sexual
orientation. Young LGBTQIA+ people reported seeing a deepnude more often (24.5%, N=93)
than young heterosexual people (23.2%, N=546). However, the difference is small, meaning
this clearly needs further investigation. A significant difference can also be found based on38

age. More young adults (>18 years old) (24.5%) reported having already seen a deepnude thanadolescents (17.2%). This difference is most pronounced in the 21- to 22-year-old age group,
where the percentages are highest. The survey found that young people in Brussels (25.6%)
indicated they had seen more deepnudes than young people in Flanders (20.7%), with asignificant difference. 23.6% of Walloon respondents indicated that they had already seen adeepnude.
•

How did you see these images?

In addition to being asked whether they had already seen a deepnude, respondents were also
asked how they came into contact with a deepnude. Here, 68% of respondents indicated thatthey had seen a deepnude on social media platforms. Furthermore, 62.2% of respondents
reported having seen deepnudes via friends, with friends showing or forwarding the images
to them. This confirms the literature review, which suggests that people enthusiastically sharedeepnudes. Finally, young people report having seen these images on pornographic websites
or in a (television) series. One respondent indicated that a friend of hers became a victim of
deepnude manipulation, which is how she became aware of the phenomenon.
•

Through which platform did you see a deepnude?

Respondents who indicated that they had seen a deepnude via social media were also asked
which social media they had seen it on. The majority of the respondents (32.9%) answeredthat they had seen a deepnude via Snapchat. Furthermore, respondents reported having seen
deepnude images on X/Twitter (25.7%) and Instagram (25.5%). Lastly, TikTok (20.2%) andTelegram (18.9%) were also relevant social media platforms for spreading deepnudes.

Chart 9: Distribution of platforms through which respondents had seen a deepnude

39

4.2.
•

Deepnudes among young people in Belgium: receiving, possessing andmakingHave you ever received deepnudes?

The respondents who indicated that they had seen a deepnude image before, were also asked
if they had ever been forwarded these images. Given that most respondents who had alreadyseen a deepnude indicated that they had seen it through social media or friends, it can be
expected that a significant proportion of these young people were forwarded thesedeepnudes. The survey found that 13.8% of respondents (N=389) said they had received adeepnude. This rate is significantly higher among men (19.6%) than among women (8.8%).

Chart 10: Distribution of responses to 'have received a deepnude' by genderSignificantly more young adults (14.9%) have already received a deepnude than adolescents(9.3%). There appeared to be no significant difference between the group of heterosexual
respondents (14%) and the LGBTQIA+ group (13.9%). In line with previous variables, Brussels
again shows a significantly higher number of respondents indicating that they had received adeepnude (20.6%) than Flemish (12.9%) or Walloon (12.1%) respondents.
•

Do you have deepnudes in your possession?

Respondents were also asked if they had deepnudes in their possession. This may be because
they created them themselves (see below), but also because they received them throughsocial media. Here, 7.6% of respondents (N=215) reported possessing deepnudes. This issignificantly lower than respondents who said they had already received a deepnude,suggesting that respondents who received a deepnude did not necessarily keep it. It would
therefore be useful to investigate further why they keep these images or not.
40

There is a significant difference between men and women. Of the 215 respondents who havea deepnude in their possession, no less than 164 were men and 49 women. There also appears
to be a significant difference between young adults (8.9%) and adolescents (2.9%). Althoughno significant difference was found between young heterosexual people and young LGTBQI+
people regarding their awareness of deepnudes, young heterosexual people were found tohave deepnudes in their possession significantly more often (7.8%, N=143) than LGBTQIA+
respondents (6.6%, N=16).

Chart 11: Distribution of responses to 'possess a deepnude' by gender

When combined with gender, heterosexual men therefore appear to be significantly more
likely to have deepnudes in their possession. Again, there are regional differences. Brussels
respondents are significantly more likely to have deepnudes in their possession (14.1%) thanFlemish (6.2%) or Walloon (6.9%) respondents.
•

Do you know of an app that can create deepnudes?

In a next phase, respondents were asked if they knew of any deepnude apps to create theseimages. Although the majority of participants (87.2%) indicated that they did not know of any
deepnude apps, more than 1 in 10 (12.8%) responded that they did know specific deepnude
apps (N=362). There is therefore a substantial group of adolescents and young adults who not
only know about the existence of deepnudes, but also know about the specific apps to create
these images. In analysing the results, it appears that male respondents were significantly
more likely to say they knew about these apps (17.7%) than female respondents (8.4%). Young
adults are also significantly more likely to indicate being aware of these apps than adolescents.
Finally, Brussels respondents (22.5%) appear to be significantly more familiar with these apps
than their Flemish (10.4%) and Walloon peers (12.2%).
41•Have you ever used this app to create a deepnude?

In the final phase of the survey, the researchers asked whether respondents had actually madea deepnude. Of the 362 respondents familiar with the apps to create deepnudes, it was foundthat 60.5% (N=219) of these respondents had actually tried to create a deepnude, or had
already done so. This represents 7.8% of the total population. This suggests that being familiar
with these apps is indeed a steppingstone to actually producing deepnudes. Indeed, themajority who know that these apps exist will try them out. This suggests that the easy
availability, accessibility of these apps in addition to them being easy to find online, facilitate
the creation of deepnudes. To support the thesis that these apps being easy to findcontributes to the creation of such images, future research will need to examine how young
people learned about these apps, i.e., whether they consciously searched for them or whether
they learned about them through other means (e.g., through friends, social media or otherchannels).
There is a significant difference between male respondents, who were much more likely toindicate that they had already used these deepnude apps, namely 69.4% (N=232), versus
female respondents, namely 45.4% (N=123). This distinction confirms previous research by
Powell et al. (2020) that suggests that the perpetrators are predominantly male, and thevictims are predominantly female. Again, there is no significant difference between
heterosexual (62.2%) and LGBTQIA+ (54.7%) respondents. There is a significant difference
based on age, however, with young adults more likely to report having used these apps (9%)
than adolescents (2.5%). Brussels respondents were significantly more likely to say they had
already used these apps than their Flemish and Walloon peers.
•

Why did you create a deepnude?

Respondents who had already used these apps were then asked why. There appeared to be avariety of reasons given by respondents:

42

Chart 12: Motivations for having a deepnude app

These findings show that there are both motivations connected with the victim of thedeepnude, such as revenge or humiliation, and motivations where the victim is not aconsideration in using the deepnude, such as curiosity, fun or popularity. These motivations
are also found in research on other forms of digital image-based sexual abuse, such as
disseminating nude images. Here too, the motivations to harm a victim appear to be in parallelwith other motivations that are not intended to harm the victim, but where the victim is taken
into consideration (Powell et al., 2020; Walrave 2023).

4.3.

Conclusions: deepnude is making itself known among young people inBelgium

The survey shows that deepnudes are clearly no longer an obscure phenomenon among young
people in Belgium. More than 4 in 10 young people know what a deepnude is and more than
1 in 5 have already seen one. Moreover, more than 1 in 10 young people have previously
received a deepnude (13.8%) and nearly 8 in 100 young people (7.8%) have a deepnude in
their possession. Young people receive these images primarily through social media andfriends. More than 1 in 10 young people are aware of deepnude apps (12.8%), and of thisgroup, 6 in 10 say they have actually used them (60.5%).
The Belgian figures are therefore significantly higher than those in the UK, New Zealand andAustralia study (Flynn et al., 2022 - hereafter UK-NZ-AU study). In the UK-NZ-AU study, only
5.4% reported having previously created a digitally manipulated image. There are two possible
explanations for this difference. First, this study focused purely on young people between theages of 15-25, while the UK-NZ-AU study was not limited to this age group. The latter study
43

found that young people are more often perpetrators and victims of digitally manipulated
image-based sexual abuse, which may explain why in the current study, more respondents
indicated that they had previously created images. Second, the UK-NZ-AU survey was taken in
mid-2019, with the commercialisation of deepnude apps and emergence of deepnudes inbots, while the Belgian survey was taken in early 2023. These apps have since proliferated andare also much more visible. The media has also upped its coverage of deepnudes, which may
also explain why these apps are more familiar. Further research should clarify whether thisrising trend among adolescents and young adults is continuing.
The study confirms that deepnudes are a gendered form of digital image-based sexual abuse.
In all questions, male respondents scored significantly higher than female respondents. Thisconfirms the previous findings in the UK-NZ-AU study.

Chart 13: Summary of gender differences

Age also appears to be a relevant factor for all aspects of deepnudes: awareness, possession
and receiving as well as using deepnude apps. This could be explained by the fact that older
respondents simply have more experience with both social media and that they are alreadymore sexually experienced. It is also noteworthy that regional criteria were also found to besignificantly relevant to all aspects of deepnudes, with Brussels respondents clearly more
likely to come into contact with deepnudes than their Flemish and Walloon peers. There is no
significant difference between the latter two. Finally, sexual orientation does not appear to
be a differentiating factor, with the exception of possessing deepnudes.

44

Chart 14: Summary of age differences

Chart 15: Summary of regional differences45

5. The deepnude apps market
5.1 The deepnude apps market
Accesible and easy to find deepnude apps mean that more and more users are finding their
way to creating deepnudes, and the number of deepnudes continues to grow. Deepnudes canbe used for benign purposes, such as digitally removing clothing for fashion shoots or in films
with the permission of the person depicted in the image. Various deepnude apps therefore
like to emphasise their applications for artistic purposes or as an expression of free speech.
For example, on their blog, the app Nudify.online states: 'The Nudify deep nude AI aims toallow users to engage in a new form of artistic expression while maintaining an atmosphereof respect and integrity'. This kind of framing therefore seems to suggest that the app primarily
serves legitimate purposes and in this sense deserves protection within the principle of freespeech (Waldstreicher, 2020).
The fact that the majority of these deepnude apps are not used for such legitimate purposesis evidenced by the huge numbers of users of these apps (Olson, 2021). For example, the app
Undress.app was visited 30.88 million times in October 2023 and the app ClothOff.io 14.8
million times. It is obvious that these are not professional users. Moreover, the presumably
non-consensual use of deepnude apps can be inferred from the fact that so many well-known
actresses have been the subject of deepnudes who obviously did not give the individual user
their consent to do so. Moreover, research shows that a large number of non-famous womenare also deepnuded without their consent (Home Security Heroes, 2023). Finally, the analyses
by the research team on the tool from web analytics company Semrush show that these apps
are used almost exclusively on smartphones and not on laptops or desktops. This also suggeststhat these are not professional apps. In addition, there is an even greater interest in viewing
deepnudes on platforms that offer deepnude images of famous and non-famous people. The
deepnude tube site MrDeepfake was visited 111.82 million times worldwide in October 2023.
The survey of young people in Belgium between the ages of 15 and 25 shows that 6 out of 10
young people who know of deepnude apps will use them. Availability therefore leads to use.
Despite the fact that the dangers of these deepnude apps and their harmful effect are wellknown, they can be found on the surface web with a simple search. (Tenbarge, 2023) Harrison
was struck by the presence and availability:46

"It's uncanny that it's harder to find a pirated movie on search platforms thandeepnudes." (Harrison, 2023).
Them being easy to find is all the more striking because these apps essentially violate the term
& conditions of various search engines (Harrison, 2023). For example, Google stipulates that
it is prohibited to:"Abuse or harm others or yourself (or threaten or encourage such abuse or harm) - forexample, by misleading, defrauding, illegally impersonating, defaming, bullying,harassing, or stalking others" (Google Terms of Service, version 5 January 2022
accessed 30 November 2023, Belgian version).
However, further analysis (see 5.2) suggests that many of these apps explicitly advertise thefact they allow anyone to be undressed and shown naked, suggesting the encouragement ofabuse or harm to third parties.
Nonetheless, a search for 'deepnude' will primarily generate pages of results featuring
deepnude apps and pages of these types of images, rather than pages on the harmfulness orlegal framework.
Many of these websites offer free access for simple tasks. The lion's share of income fromdeepnude apps comes from more high-quality, 'premium' versions of deepnude apps.
Deepnude creators, for example, charge $65 to make a video of 'a personal girl', meaning
someone with less than 2 million Instagram followers. This video lasts 5 minutes, and the pricerapidly increases for longer clips. In addition to selling individual videos, deepnude creators
also offer subscriptions to access online libraries with thousands of videos, with somesubscriptions costing as little as $5 a month and others being free. Some 'creators' even recruit
staff to help them create content (Tenbarge, 2023). In addition to subscriptions and paymentsfor premium versions, the companies behind the apps also generate revenue from advertisingon their sites and selling data. They are no different from other free apps in this regard.
However, most deepnude apps do state that they value anonymity and only store the personal
data of their users to a limited extent and do not monetise this data. For example, the app
deepnude.cc states that they store a minimum amount of personal data and do not sell it on
account of the legal and administrative burden involved, but also because of the sensitive
content they offer:
47

"We must strive to acquire trust from users due to privacy sensitive nature of our
product."
Nevertheless, they store user patterns as well as aggregated data, i.e., statistical data
generated from raw data but that can no longer be traced back to this data, which they thenmonetise (see for example the terms & conditions of deepnude.to that explicitly refers toaggregated data).
Deepnude apps are clearly no longer a niche business but are growing exponentially in termsof number and sales. The number of circulating deepfakes has risen by 550% since 2019 (Home
Security Heroes, 2023). Purchases of deepnudes are now a worldwide phenomenon.
Nevertheless, there are still regional differences, both in terms of use and development.
Whereas the first deepnude apps appeared in the United States, many apps are designed in
Asia in addition to these original American deepnude apps. An analysis of the terms &conditions or terms of service (ToS) shows that the registered offices of these apps are locatedgenerally in the Far East or in the United States. There are also regional differences in
popularity by users. Analyses of the most popular deepnude apps through Web analytics
companies SimilarWeb and Semrush show that the main customers are mostly located in the
United States and Asia. For example, the top five countries based on users of the popular app
MrDeepfake were the Philippines (21.36%), United States (17.26%), Indonesia (7.96%), India(6.97%) and Singapore (3.86%). However, Google Trends shows that despite this popularity incertain countries, there is worldwide interest. This is shown in the map below, based on search
results analysed by Google Trends from the same app during the same period:48

5.2 Analysis of deepnude apps: words vs. reality.
To gain a better understanding of how deepnude apps work, the 25 largest and most populardeepnude apps were analysed based on their formal policies on malicious content, as well as
their implementation of these policies in reality.
•

Whether there are any terms of service and privacy policies

First, the ToS of the various apps were analysed. There is a significant difference in availability
and professionalism in this regard. Since these apps offer an online service, they are obliged
to provide a ToS. Moreover, given that these apps process data submitted by users, meaning
photos and therefore personal data, they also need to provide privacy policies informing theirusers what happens to this data. The analysis shows that the majority of apps do have a ToS
as well as a privacy policy. Only deepnude.org did not have a consultable ToS at the time ofthe study. It can be inferred that these apps want to be in compliance with the provisions onproviding digital services. Moreover, with the exception of deepnude.org, these apps also
appear to provide a detailed privacy policy. Their ToS regularly stress the importance ofprivacy and confidentiality, given the sensitive content. Accordingly, more than half of theseapps state that they do not sell users' personal data, and only keep limited data to protect
users' anonymity to the max. This means that in the event of searches by national authorities
for illegal use of these apps, these companies will not have the data.
•

The contents of the terms of service: copyright, CSAM and consent

There are significant differences in the level of detail between the various ToS of deepnude
apps. Whereas some go into detail about what content may not be created with the app, andwhich applications violate the ToS, others are very rudimentary and limit themselves toprohibiting harm to third parties and not violating the copyright of third parties. The study
notes that there are certain phrases in some ToS that reappears almost word-for-word acrossseveral deepnude apps, despite being formally different apps (12 out of 25 selected apps).
These ToS include a whole list of unauthorised content, including copyright or image right
infringement, child sexual abuse material, non-consensual nude images, hate speech ormaterial that is threatening, intimidating, defamatory or offensive material, or that incites
violence or crime, content that is against national or international regulations, or material that
violates the rights of third parties.

49

These ToS have an informal prioritisation for copyright violations, which often include anotherseparate policy or provisions on copyright and the violation thereof, and child sexual abusematerial. It is often stated, in capital letters or repeatedly, that child sexual abuse material isprohibited. Additional actions are taken if users (attempt to) create CSAM, such as immediate
exclusion, warnings to users that if they (attempt to) create such material the app will pass
the user's data to the national authorities, or warnings that artificial intelligence is used on
the app to prevent child sexual abuse material (Nudify Online app).
The apps were also analysed for whether they stressed the importance of having the consent
of the depicted person when using deepnude apps. The vast majority (17 out of 25) of theapps state that the deepnude app can only be used with consent. This is usually mentioned in
the ToS and therefore not necessarily when making a deepnude. Indeed, most of thedeepnude websites offer free software where the deepnude image can be created without
reading the ToS. This means that a nude image can be created without the user being
informed that consent from the person depicted is required. Only two apps provide a pop-up
before a deepnude image can be created (pornjourney.ai and Undress.app.). Only one app(Nudify.site) provides a high-quality description of consent, namely 'explicit and verifiableconsent'.
•

Underage users

Underage users appear to be a major concern for apps in their ToS. In addition to the major
focus on banning CSAM content, the vast majority of apps stipulate that they should not be
used by minors (18 out of 25). Several apps feature a pop-up in this regard (7 out of 25) or acheck box on the home page where the user has to indicate that they are 18 or older. As such,a deepnude can only be made after a user confirms their age. No other verification is provided
by these apps, meaning that use by underage minors depends entirely on information they
provide themselves. Several apps mention the RTA (restricted to adults) - label, which means
they will be caught by parental control restrictions that can be set up for use by minors.
Nevertheless, the majority of apps do not have an RTA label.
•

Liability and waiver of liability of the apps

The ToS often include various provisions on waiver of liability, both towards users and third
parties. These waivers of liability are mostly written in general terms, and again, it was50

observed that the exact same wording is frequently found on different apps. One example is
the waiver of liability on deepnude.gg:"Notwithstanding anything else stated in these terms, and irrespective of whether
deepnude.gg takes or does not take measures to remove inappropriate or harmful content
from its site, deepnude.gg has no duty to monitor any content on its site. Deepnude.gg
does not assume responsibility for the accuracy, appropriateness, or harmlessness of any
content appearing on deepnude.gg."
Moreover, it is made clear to the user that if the user is found to be in violation of the verybroad and comprehensive prohibited used of the app, they cannot hold the company liable.
The following example from Makenude.ai is typical in this regard:"You agree to indemnify and hold harmless makenude.ai and all its personnel from all loss,
liability, claims, damages, and expenses, including reasonable attorney fees, resulting fromyour violation of these terms, your infringement of any third party's rights, and any
damage caused to any third party as a result of your uploading of files, comments, or any
other content to our servers."
It is therefore clear that the apps want to waive all liability and that the often highly detailed
description of prohibited uses reflects this waiver of liability.
•

Words vs. reality: systems analysis

Based on the ToS, there may be the perception that these apps largely seek to avoid harmfuluse. Deepnude.to states to that effect in its ToS that the app 'does not promote sexually
explicit images in any form' and 'we apply various protection policies to create a safe
environment and discourage illegal behaviour.' Similarly, Nudify.site states that the purposeof the app is 'to provide a unique artistic and transformative experience for users' and isintended for 'private and artistic use and should be used responsibly and ethically.' Likewise,
the repeated use of consent and the ban on creating CSAM may create the perception thatthe apps are advocating ethical use.
However, anyone analysing the apps digital infrastructure and functioning would come to avery different conclusion. First, these apps are built in such a way that there is no oversight.
For example, virtually none of the apps provide for verification of whether the images createdare violent or non-consensual. This would be easy to implement by verifying the entered51

prompts or the source material in Face Swap apps. Only one app explicitly states that it uses
technology to prevent the making of images of childrend.
Secondly, there is no check that the person depicted has given their consent to make theimage. The importance of consent is often limited to just a mention in the ToS, without any
consent request, pop-up, or explicit submission of consent being necessary before a person
can make an image on these apps. This is evident in the upload procedure on, among others,
Deepnude.app.

Moreover, all these apps underline the fact that creating the deepnude is anonymous anduser data is not kept, so the user knows that if they create illegal images, for example, without
consent, they will not be identified by a victim or the national authorities.
Finally, these apps explicitly advertise and attract users on the premise that they can use theapp to make a nude image of anyone. Some apps explicitly refer to making images of famous
people. For example, the initial image of one of the most popular apps, Nudify.online, is a
picture of actress Emma Watson being undressed by the app. The actress did not give consent
for her image to be used by this site, nor for being undressed. By showing a non-consensual
undressing as an example, the message to users is clear. Here, the fact that the ToS state thatconsent is required is completely undermined by the initial image on the home page.
Moreover, the choice of Emma Watson is not a coincidence (Gosse & Burkell, 2020). She is
known for her outspoken positions on gender equality and against sexual violence against

52

women. By choosing her as a victim, the app makes an implicit policy choice for a misogynistic
reputation.

An analysis of marketing titles, as well as text on the apps' home pages, shows that thesemarketing and policies are mainstreamed across different apps. Deepnudes.net makes thisparticularly explicit by alluding to users' dreams of undressing someone without any reference
to consent or ethical concerns. For anyone still in doubt, this ad provides one more push:"We know why you're here - there's a special someone you've been dying to Undress
with more than just your eyes but can't, right? Oh! Well... we've all been there, trustus, which is why we now have the ideal solution for your fapping pleasure! We give you(sound the horns) ... DeepNudes!"Below is a sample of several of the most popular apps and their slogans.
DeepNude.gg

See anyone naked

Nudify Online

Nudify any girl online for free

Undress.app

See anyone naked

Deep-nude.com

See any girl clothless with the click of a button.

Deepnudenow.com

Undress Anyone Online and Completely for Free

Deepnudify.com

Deepfake Application to View Anyone Naked

53

Ainude.ai

Turn a hot girl's photo to deepnude image for FREE

Nudify.site

Undress anyone in seconds

Clothoff.io

UNDRESS ANYBODYWITH CLOTHOFF!

Makenude.ai

See any girl clothless with the click of a button.

Pornjourney.ai

With our tool, it is very easy to Undress any images!
Upload your image and Undress girls in your dreamon http://PornJourney.ai•

Nudify.it

Undress anybody with our service for free.

Undress.vip

Undress any girls clothes

Conclusions

The analysis of deepnude apps shows that they seek to waive their liability as much as possibleby broadly defining unauthorised use of the app, as well as an almost total exemption fromany liability for use of these apps. In reality, however, no precautions are taken to prevent
unauthorised use. The only observed security measures taken are related to creating childsexual abuse material (including by detecting these images or excluding certain prompts tocreate such material) and the access of minors to these apps (including via pop-ups and the
RTA label).
An analysis of the websites shows that the marketing and text on their home page, as well as
their digital architecture, is in sharp contrast to the ToS regarding prohibited use. This isevidenced by the fact that creating non-consensual nude images is explicitly alluded to on the
homepage or through marketing of the apps (1), there is no prior warning to users that nonconsensual material or violent material must not be created (2), there is no oversight byartificial intelligence (banned prompts) or by other technical means on creating this type ofmaterial (3), and it is explicitly stated that these images can be created in complete anonymity(4). It can be inferred that many of these apps not only allow such use, but even allude to it
and encourage it. As such, these companies cannot assert that these apps are only marketed
and used for legitimate creative or commercial purposes.
545.3 The legal framework and legal gaps for deepnude apps•

Criminal liability for deepnuding of adults

Having analysed the legal framework for deepnuding, it emerged that both creating anddistributing deepnudes of a minor and deepnudes made through Face Swap or an Undress
app of an adult without consent is a criminal offence under Belgian law (see above under 3.3).
Moreover, there appears to be a worldwide trend, with more and more countries criminalising
deepnuding without consent, or considering it (Delfino, 2019). The EU's draft directive against
gender-based violence, that includes a provision criminalising the production or manipulationof intimate images, is one example.7 An analysis of the legal framework suggests that theseapps evade many legal frameworks in the strict sense.
With the recent arrival of the Digital Services Act (hereafter: DSA), the European Union
implemented a new framework that regulates the liability of online service providers, andrequires them to tackle certain content and provide security measures. 8 However, thisRegulation only applies to services that provide mere technical assistance, namely mere
conduit -, caching - and hosting - services (Walrave, 2022). Deepnude apps are not a mere
upload service, but provide specific substantive, albeit automatic, processing of images.
All tube sites offering deepnude images however are covered by this regulation. Insofar asthese are sites that publish deepnudes of real people, they will be liable for making nonconsensual nude images accessible in accordance with Articles 417/9 - 10 of the Criminal
Code. Insofar as these are platforms on which deepnude images are published, in accordancewith the Digital Services Act, they will have to remove these images as soon as they haveknowledge that they are present on their platform. If these platforms refuse to remove theimages, they will also be liable in accordance with Articles 417/9 - 10 of the Criminal Code.
This is different for AI-porn deepnude apps, since this form of deepnude is not a criminal
offence according to the legislator based on Articles 417/9 - 10.
While the companies behind the apps cannot, or if so with difficulty, be held liable forvoyeurism in accordance with Article 417/8 of the Criminal Code, the apps themselves can be7

European Commission, Proposal for a Directive of the European Parliament and the Council of the European
Union to combat violence against women and domestic violence, COM(2022) 105 final 2022/0066(COD), 8 March2022 (Proposal for a Directive).
8
Regulation on a Single Market for Digital Services and amending Directive 2000/31/EC (Digital Services Act), ECR
2022, L-277/1.

55

seen as an instrument of the offence. Moreover, having a deepnude app combined with athreat to make a deepnude of someone or having photographs of that person in one's
possession, may well constitute the start of committing the offence of voyeurism. Indeed,
downloading the app was already the first tangible step towards creating the deepnude.
•

Criminal liability for deepnuding minors

In principle, the analysis of the production of deepnude child sexual abuse material iscomparable to that of non-consensual deepnude images of adults, albeit on different
provisions. This means that criminal liability falls on whoever creates the nude image and noton the deepnude app. Specifically for child sexual abuse material, it raised the question
whether in certain cases these deepnude apps are nonetheless criminally liable if it is possible
to create an image of a minor. Indeed, one can argue that given the fact that the company
behind the app has control over restrictions in the prompts for using artificial intelligence,
they can also restrict this material. Moreover, some of these apps explicitly state that they
prevent this kind of use.
The question is therefore if there is no such restriction, should the app not be a co-perpetrator
or at least complicit in producing child sexual abuse material. Given that these services are
not covered by the DSA, the company cannot hide behind limited liability. The question will
be whether there was knowledge that child sexual abuse material was being produced. In suchcases, these companies will usually refer to their ToS, which state that it is prohibited to createsuch material. On the other hand, a judge could disregard this if it turned out that the company
behind the app did know the app was being used for this purpose, did not take action when it
could easily have done so, and in reality permitted such activity.
Based on an analysis of AI porn apps in particular, the study found that some apps advertisethe fact that they do not impose any restrictions on the creation of images. This may be anelement to assert that they are complicit in the production of child sexual abuse material.

56Regarding the disseminating of these images by tube sites and online platforms, the same
analysis applies in principle as for the disseminating of deepnude naked images of adults. Thismeans that there is criminal liability for making child sexual abuse material accessible if thissite published the images itself or, in the case of an online platform, had knowledge of theseimages and did not remove them. The analysis is not comparable if it involves thedissemination of AI porn images, since images of fictional minors are also prohibited childsexual abuse material. As such, if they do not remove material after becoming aware of it,
online platforms will in fact be liable for making child sexual abuse material accessible.
•

Liability through the operation of deepnude apps

The focus on liability primarily relates to creating nude images. However, to produce and run
these apps, artificial intelligence must be supplied with a huge quantity of existing images
from which it can make analyses. These images may come from databases, for example
pornographic databases, where these images were created, kept and sold with consent, butthey may just as easily be supplied without the consent of the individuals depicted in theseimages.
When it comes to the processing of facial characteristics, this will be a violation of the GDPR
since there is processing without consent. However, often this consent will have been
generated by other apps selling these images, where those whose data was sold did not realise
what it was being used for. Moreover, it is mostly other body parts with which the databases
are supplied, in particular in Face Swap and Undress apps. These other body parts do notconstitute personal data, so the GDPR does not apply. There may be a violation of intellectual
property rights if the photos are commercial. However, there is currently no comprehensive

57

framework to ban this broader non-consensual processing of images of third parties for theseuses.
In the event that a victim notices that their nude images or body parts have been used to train
such an app, possible IT fraud under Article 504quater of the Criminal Code may offer solace.
This provision punishes an unlawful economic benefit for oneself or for another person toacquire with fraudulent intent by introducing, altering, deleting or changing by any othertechnological means (the normal use) of data stored, processed or transmitted by means ofan information technology system, into an information technology system. In the case ofdeepnude apps, it can be argued here that the company behind the app pursued illicit revenue
by developing their app by taking over data, namely images, that were available online.
This analysis makes it clear that there is a need for more comprehensive regulations thatprevent the collection and processing of such data.
•

The future: the AI Act of the European Union

The European Union has been negotiating regulations to regulate artificial intelligence, known
as the AI Act9, for some time. At the time this report was finalised, there was still no final
agreement on the text. The proposal divides AI apps into several categories based on theassessment of the risk these apps pose to fundamental rights and society. Interestingly,
deepfakes were only assessed as medium risk.
This means there are limited obligations in terms of transparency. Rather than placing
restrictions on deepfake apps, the proposal stipulates mandatory disclosure when image,audio or video material has been generated or manipulated with AI if it noticeably resembles
authentic content (Article 52(3) AI Act). This requirement would therefore apply only to Face
Swap- and Undress- apps. It is striking that despite the many articles on the impact ofdeepnudes and the dangers, there was very little attention to the issue in the design of the AI
Act and these apps are only assessed as medium risk (Fernandez, 2022).
The AI Act will therefore fill a gap as it points in a more general sense to the responsible
development of AI, imposes the need to protect fundamental rights and specific transparency

9

Proposal for a regulation laying down harmonised rules on artificial intelligence, COM (2021) 206 final,
2021/0106(COD).

58

obligations, but will only have a limited impact on the availability of deepnude apps on thesurface web.

5.4 The future of deepnudes
The development of deepnude apps is already providing hyper-realistic possibilies today thatwere impossible a few years ago. AI porn sites already offer the ability to create fully virtual
naked persons, have them perform the desired sexual acts online, as well as interact with theuser via sexting. Images of real people can also be undressed and added into pornographic
videos as though it was actually them. The analysis clearly showed that the current legislation
is inadequate both in terms of regulating these apps and prohibiting specific uses on them. It
is obvious that the AI Act will be insufficient in this regard.
Given the huge impact on the sexual integrity of victims as well as the broader societal
consequences in terms of objectification and inequality of women, there is a need for further
regulation that requires the companies behind the apps to incorporate certain safeguards,
such as, for example, excluding users who attempt to create child sexual abuse material, acommitment to clearer guidelines for users before the app can be used, as well as guidelines
in terms of identification of users to rule out non-consensual use, and cooperation withnational authorities and support organisations in cases of malicious use. If these apps do notabide by the rules, search engines and web stores should no longer list them. Moreover, there
also need to be transparent guidelines on the use of images to train machine learning, withcompanies required to demonstrate that they have only used images based on explicit
consent.
Nevertheless, there is little point in banning these apps completely. First, there is just as muchediting software based on AI that is not intended for deepnude but can be used for thispurpose by users who know how to use this technology. Second, previous efforts to takedeepnude apps offline found that they quickly resurface elsewhere. Third, there appears to
be a market and space for AI porn with completely fictional characters which, if based on thelawful collection of images for deep learning and certain boundaries, could play a role in the
future of the porn industry. However, it is hard to see how commercial Undress apps can play
any legitimate role. As such, besides a legal response, there is also need for a response fromthe industry itself, in particular from app stores, social media and search engines. Domain
registries play an important role in this regard, as they provide the basis for these apps. It is59high time that, in addition to regulation of search engines, online marketplaces and social
media, domain registries are also scrutinised for their policies of offering domain names forharmful activities.
It will be crucial to find a solution to deepnuding in the coming years. As AI tools become moresophisticated and accessible, there will be continued innovation in digitally generated sexual
images (Williams, 2023). This development is no longer limited to apps and web sites but isslowly filtering down into the Metaverse. As a result, the risk of being a victim in the Metaverse
is growing, in particular due to deepfake-related interpersonal cybercrime. This includes
various forms of criminal activity in the digital space, such as sexual violence and cyberstalking(Moshin, 2021).
A study by Stavola & Choi (2023) shows that it is becoming easier for Metaverse users to create
their own deepfakes, especially in the form of avatars (e.g., Deepfake 3.0). Experts stress that
it is extremely difficult to prevent the creation of deepfake avatars in the metaverse, especiallysince there are currently no effective ways to detect deepfakes there.
"The Metaverse is one giant deep fake. There is no expectation of real world fidelity."(Bui, 2022)
It appears the creators of the Metaverse are aware of the threat of deepfakes and thepotential risks to the platform. However, at present they do not have sufficient resources todeal with it effectively. A report from June 2020 revealed that current software for detecting
deepfakes in the metaverse only has a 65% accuracy rate (Castillo, 2022).
Moreover, another pressing challenge is currently emerging as the porn industry experimentswith virtual reality (VR). The deepnude tube site is already advertising the following: "See yourfavorite celebrity in VR, making having sex with them so realistic!". VR provides an additional
realistic factor in online sexual experiences. It is therefore conceivable that in the not-toodistant future, non-consensual sexual acts in a virtual reality world could be possible where
the images were generated by artificial intelligence of a person who does not consent. Not
only is the image of this person consequently abused by depicting them as nude or sexually
explicit, the image will also be involved in virtual sexual activity. AI-porn generator
Dreamgirlfriend (DreamGF) posted a philosophical reflection on the ethical concerns of AI
porn and deepnude as well as the future challenges, including the impact of virtual reality:
60

"There are also concerns AI porn will continue to become more advanced, with models
generating erotic content in virtual spaces that trick users into feeling they are having
a real sexual encounter. Sex with highly realistic computer simulations could become
addictive or lead to unhealthy relationships forming with AI."10
Developing effective measures to recognise deepfakes as well as guidelines on the creation,
use and sharing of these images is crucial to overcoming the growing threats of deepfake
technology to sexual integrity and privacy. Gieseke therefore strikes a chord when she asserts:"It is therefore imperative to regulate deepfake pornography when it is actively
weaponized against victims without inhibiting its ability to innovate and legally
flourish." (Gieseke, 2020).

10DreamGF, Blog post 'Are you looking to generate porn? We have the tools for you!" (7 April 2023):
https://dreamgf.ai/blog/ai-generative-porn.

61

6. Conclusion and recommendations
6.1 General conclusions
Deepnude, or digital undressing, is not a new phenomenon. In recent years, there has been a
sharp rise in the number of deepnude apps, deepnude images and the use of these apps.
While analysis shows that most of these users are still primarily in the United States and Asia,
there is a growing market in Europe as well.
A survey of young people in Belgium between the ages of 15 and 25 shows that deepnudes
have now also made their appearance in Belgium. Four in 10 young people know what
deepnudes are (41.9%). More than 1 in five (23.1%) have seen a deepnude at some point intheir lives, mostly on social media platforms or through friends. More than 1 in 10 (13.8%) say
they have previously received a deepnude, and nearly 8 in 100 (7.6%) acknowledge having a
deepnude in their possession. This means that in addition to creating deepnudes, there is alsoa market for exchanging them. The study observed that in addition to deepnude apps, there
are also various deepnude tube sites and platforms hosting deepnude images and videos.
These deepnude tube sites and platforms attract millions of visitors per month.
The survey also found that more than 1 in 10 young people (12.8%) are aware of deepnude
apps, with 6 in 10 of these young people (60.5%) having already tried an app. These figures
show that the individuals who are aware of a deepnude app will use it in more than half thecases. Consequently, the wide availability of these applications through a simple search on the
major search engines directs young people to a whole range of deepnude apps, many of which
can be used for free and anonymously. There is a wide variety of motivations for using theseapps, ranging from revenge, the intention to humiliate, to have fun, boredom and to impress
friends.
The study highlighted the gender, age and geographic distribution as significant factors. Boysscored significantly higher than girls on all questions. The study also found that the majorityof apps also focus on undressing women, and the literature review shows that nude imagesof women make up the majority of online deepnude images. The study therefore also confirmsthat today non-consensual deepnude is a gendered form of digital image-based sexual abuse.
Moreover, it appears that young adults score significantly on all questions regarding
experiences with deepnudes, which can be explained by more digital experience as well as
62

more sexual experience. In addition, the study also found that young people in Brussels scoredsignificantly higher than their Walloon or Flemish peers on all questions. However, sexual
orientation did not appear to be a determinant for awareness and use of deepnuding.
The study concluded that the Belgian legal framework is already highly developed for
criminalising the creation and sharing of non-consensual deepnudes, or deepnudes of(fictional) minors. Regulations along these lines are also starting to emerge at EU level. On theother hand, there is a lack of both a legal and self-regulatory framework for deepnude apps
themselves. A systematic analysis of the 25 most popular apps showed that although on paper
they prohibit harmful and unlawful applications of deepnudes, as well as the use ofdeepnudes, in practice they do not take any action in this regard, and sometimes appear toencourage it. Search engines also take little to no action against these apps despite the factthat they are mostly used for malicious ends. In addition to the lack of regulation of these apps
themselves, there also appears to be a lack of regulation of the databases on which thetechnology behind the app itself is trained. The study concludes that the draft AI Act at theEuropean Union level in itself will not be sufficient to meet the current and future challenges.
The study therefore calls for additional efforts in terms of regulation, research, awarenessraising and education to address the harmful effects of deepnudes.

636.2 Recommendations
The study makes the following recommendations:➔ Recommendation 1: Work on raising awareness among the broader society (including
young people in particular), policy makers, social media platforms and the education
system about the prevalence of deepnudes and the impact of non-consensual
deepnuding. Advise on the ethical, moral boundaries in digital sexual experiences aswell as the legal boundaries.
➔ Recommendation 2: Work more broadly to change attitudes on sexual privacy andintegrity as well as the importance of consent among young people. This includes
awareness, media literacy and a change in the way society approaches gender andsexuality.
➔ Recommendation 3: Improve legislation. Review the Belgian criminal provisions
regarding the use of AI porn applications that (knowingly) resemble real persons. Work
towards amending the forthcoming EU regulations on AI (the AI Act) and gender-based
violence to ensure the broadest possible protection for victims of deepnudes.
➔ Recommendation 4: Invest in scientific research around deepnudes, including on the
motives for producing deepnudes and the impact on victims. Larger subgroups arenecessary in this regard, to replicate the results.
➔ Recommendation 5: Fund projects relating to various forms of image-based sexual
abuse (IBSA). Embrace the evolution that bring about new forms.
➔ Recommendation 6: Tackle the ubiquity of deepnude apps, regulate these apps andpush for self-regulation of both these apps and search engines and social media.
➔ Recommendation 7: Foster cooperation with domain name registries that supply
deepnude apps and websites with domain names.
➔ Recommendation 8: Work together with social media platforms to develop policies
and measures to limit the dissemination of deepnudes and prohibit advertising forthese apps on their platforms. Encourage them to make users aware of the risks andconsequences of sharing deepnudes.

64➔ Recommendation 9: Regularly monitor and analyse trends around deepnudes tokeep up to date with the development of technology, forms of deepnudes and otheraspects of this issue.
➔ Recommendation 10: Ensure that financial support for independent institutions towhich victims of deepnudes can turn, such as Child Focus and The Institute for theequality of women and men, is in line with the growing complexity and ubiquity oftechnology to ensure effective support.

65

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Colophon
Study finalised in November 2023.
Responsible publisher
Michel Pasteel, director of the Institute for the equality of women and men

Instituut voor de gelijkheid van vrouwen en mannen
Place Victor Horta 10, 1060 Brussels+32 (0)2 233 44 00
equality.womenmen@iefh.belgique.be
https://igvm-iefh.belgium.beAuthors
Prof. dr. Catherine Van de Heyning
Prof. dr. Michel Walrave
Prof. dr. Mona Giacometti
Nina Dakota Szyf
Aurélie Gilen

Depotnummer
D/2024/10.043/3.
The positions, titles and degrees used in this publication refer to people of any gender orgender identity.
Cette publication est également disponible en français.
Deze publicatie is ook beschikbaar in het Nederlands.

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