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Digital Omnibus Takes Effect, EU Bans AI-Generated Deepnude Images
On July 27, 2026, the EU regulation known as the Digital Omnibus for AI took effect, adding the generation and manipulation of nude images of real people without consent to the list of prohibited AI practices. The package also pushes back compliance deadlines for high-risk AI systems by more than a year.
Contents
The regulation known as the Digital Omnibus for artificial intelligence took effect on July 27, 2026, three days after its publication in the Official Journal of the European Union. The most talked-about element of the package is a new ban on creating so-called deepnudes, AI-generated images that strip real people in photos without their consent.
What exactly is banned
The new provision covers AI systems designed to generate or manipulate images, video and audio in ways that create unwanted intimate content and material depicting the sexual abuse of children. The ban applies both to placing such systems on the EU market and to using them.
The drafters went further than the original proposals from November 2025. The ban is not limited to tools explicitly "intended" for undressing photos, but covers any system in which such an outcome is, as the regulation puts it, a reasonably foreseeable and reproducible result of use without substantial technical modification and without adequate safeguards.
Broader scope than announced
This means providers of general-purpose image and video generators must assess the risk of misuse already at the design stage, even if the product is not formally marketed as an app for creating nude images. Grok, Elon Musk's chatbot and image generator, repeatedly came up in the debate over the provision as an example of a problematic tool, following reports that it generated content sexualizing real people.
The push for the rules also came from a report published by the Center for Countering Digital Hate in early 2026, which documented the scale of the so-called "nudify" app problem online.
A year more for high-risk systems
The deepnude ban is just one element of a broader deregulatory package. The main goal of the Digital Omnibus was to ease the burden on companies deploying high-risk AI systems, meaning those used in employment, education, access to services or the justice system. The compliance deadline for these systems was pushed back from August 2, 2026, to December 2, 2027.
For AI systems embedded in products regulated by separate EU legislation, listed in Annex I of the AI Act, the deadline was pushed back even further, to August 2, 2028. The powers of the EU AI Office at the European Commission over oversight of general-purpose models were also expanded.
I believe the proposal to ban so-called nudify apps is something our citizens expect - Michael McNamara, Member of the European Parliament, lead negotiator for the Parliament's team on the package
Poland's perspective
Poland's Ministry of Digital Affairs had already spoken favorably of the proposed deepnude ban, calling it an important element in protecting the privacy, dignity and safety of users in the digital environment. For Polish companies offering image and video generation tools, this means they must implement safeguards against misuse no later than December 2, 2026, when the ban becomes fully enforceable.
At the same time, the postponed deadlines for high-risk systems give Polish companies and institutions, including public administration, extra time to bring compliance procedures into line, instead of the original deadline that was just days away.
We want rules that are innovation-friendly, both in how they are applied and in simplifying the law where our goals can be achieved at lower cost and with simpler procedures - Henna Virkkunen, European Commission Vice-President for Technological Sovereignty and Security
Critics of the deregulatory part of the package point out that further delays to AI Act deadlines, following earlier postponements of some content-labeling obligations, could weaken the pressure on companies to actually implement risk-assessment mechanisms before putting systems on the market.
Enforcement of the new deepnude ban will fall to national supervisory authorities and the EU AI Office, which will have to work out practical criteria for determining when an image generator "reasonably foreseeably" leads to violations. The first decisions and any penalties are unlikely to be known before December 2026, when the ban becomes fully applicable.
