Spain Criminalizes AI-Generated Deepfake Nudes of Minors — the Legislative Response to the Almendralejo Schoolgirl Scandal

In September 2023, fifteen minors in Almendralejo, Spain, used the AI app 'Clothoff', accessed via Telegram, to generate sexually explicit images of twenty female classmates aged 11 to 14, based on clothed social-media photos; the images circulated across at least four of the town's five middle schools.

Close the legal gap exposed by the case by criminalising non-consensual AI-generated intimate imagery of minors nationwide and setting a clear minimum age of consent for use of one's own image.

In June 2024, the fifteen minors were sentenced to one year of probation with mandatory educational rehabilitation, on twenty counts each of child sexual abuse material offences and offences against moral integrity. On 25 March 2025, Spain's Council of Ministers approved a draft Organic Law on the Protection of Minors in Digital Environments, adding Article 173 bis to the Penal Code: it criminalises dissemination of non-consensual AI-generated pornographic content (one to two years' imprisonment) and sets a minimum age of 16 for a person to consent to use of their own image. The reform also requires device manufacturers to include effective parental-control systems and promotes complementary digital-skills and addiction-prevention education.

The juvenile sentencing (probation only) was described by critics as lenient relative to the scale of harm (20 victims). Corporate-responsibility analysts noted that existing EU regulatory instruments, including the AI Act, had imposed no adequate preventive obligations on AI nudification apps prior to the Almendralejo case.

The reform closes a regulatory gap analysts flagged in existing EU-level instruments, but its real-world enforcement and deterrent effect has not yet been evaluated.