Grok, Nudification and Addressing Online Harms to Women and Girls

The start of 2026 has seen a deluge of reports and worldwide condemnation about the ways in which Grok, the AI assistant developed by X (or the ‘deepfake porn site formally known as Twitter’ as it was dubbed by the FT) has enabled users to digitally undress women and girls. This blatant misuse of technology, and the flippant response from X owner Elon Musk, has provided a stark illustration of the dangers of AI-generated harms, the challenge of regulating big tech and the evolving nature of violence against women and girls (VAWG).

The scandal has asked questions of government and the much vaunted Online Safety Act (OSA) that finally became law in 2023, following an extremely protracted parliamentary passage. Under the OSA Ofcom is entrusted with regulating platforms in order to protect users from illegal content and content harmful to children. Ofcom issued statutory codes on both during 2025 and in November published guidance on a safer life online for women and girls. This guidance contains much that is positive, but is advisory only, and the current government (as well as the previous Conservative administration) have thus far resisted campaigns to put this guidance on the same footing as the statutory codes on protection of children and illegal content. There are no guarantees that platforms such as X will follow the guidance or face any sanctions for failing to do so.

Massive public and political outrage that has attended the Grok debacle has spurred Ofcom into opening an ‘urgent investigation’ into X. This remains underway, despite X claiming last week that it had disabled the ability to undress real people, after attracting condemnation by initially restricting the functionality only to paying X subscribers.

In the face of noises from across the Atlantic and claims from Musk that this was an assault on free speech, the government has recommitted to the OSA and support for Ofcom ‘to use all of its powers’ to address the blatant behaviour of X. In her statement to Parliament on 12 January DSIT secretary of state Rt Hon Liz Kendall MP announced that the government would rush to introduce new offences to criminalise non-consensual creation of intimate images – provisions which were included in the Data Use and Access Act 2025 but until now did not have a date for commencement – and that it will ‘ban nudification apps’.

But What Will This Mean in Practice?

Prior to the Christmas Parliamentary recess the government finally published their long awaited VAWG strategy ‘Freedom from violence and abuse: a cross government strategy’, which had been promised in light of the 2024 Labour manifesto commitment to ‘halve VAWG over 10 years’. In contrast with previous strategies, the threat of online VAWG is foregrounded (this is mentioned over 50 times). The strategy contains for the first time a specific action plan to address online VAWG including outlawing nudification apps and ‘working to ensure AI models cannot assist VAWG offending’.

But there is a lack of detail on how enforcement is expected to be transformed into response. There is no mention of the policing role around online VAWG beyond a commitment to increasing the use of undercover online officers – a welcome step but hardly one that on its own is likely to transform the response. A landscape review published by the Centre for Protecting Women Online in 2025 found that there were systemic issues with the policing response to online and technology facilitated VAWG:

1. Technology has transformed the VAWG threat.

   In common with other crime types, technology has revolutionised the nature and scale of VAWG offending. But this has not yet fed through into police data on recorded crime, which doesn’t accurately represent the threat compared with other credible independent sources. The result is a growing gap between how and where harm is happening and the police understanding and response.

2. The police response to technology-facilitated VAWG has not evolved to keep pace with the threat.

   All police forces have digital investigation capabilities, but police forces have not yet mainstreamed these as a core element of their national response to all forms of VAWG. This means that opportunities to better identify perpetrators and safeguard victims and survivors are currently being missed.

3. There is existing good practice in policing, but it is scattered and needs to be better co-ordinated and mainstreamed.

   There are committed practitioners across policing who are attempting to address these threats and some promising projects showing impact, but they are not yet integrated into a consistent national programme to address this challenge. The effect of national change programmes such as Operation Soteria has had measurable impact on the response to rape and sexual offences and should be extended to cover technology-facilitated VAWG.

4. There is a need for a concerted focus to close the gap between the threat and the current response.

   Policing needs to focus on rapidly closing this gap in order to build public trust and confidence and meet the ambition of halving VAWG set out in the government’s VAWG strategy. The lessons from other national responses to online threats such as serious organised crime and child sexual abuse and exploitation are instructive in this regard, and involve a whole of government approach that is as focused on prevention and protection alongside pursuit of perpetrators.

Policing alone can never address issues as systemic as the abuse of technology to harm women and girls. The challenge is too broad and widespread for enforcement alone to be effective. However it is also critical that where government is committed to criminalising new forms of harm, such as the use of technology to nudify women and girls in order to cause threats, harm and humiliation, that there are credible plans for how this will happen in order for victims and survivors to have confidence to report, and perpetrators to understand that actions have consequences.

If the bold aspirations set out in the VAWG strategy are to be achieved then ensuring there are effective, credible and committed policing responses in place nationally is a key requirement.

© RUSI, 2026.

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