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

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

In June 2024, the fifteen minors were sentenced to one year of probation with mandatory educational rehabilitation, on twenty counts of child sexual abuse material offences and twenty counts of offences against moral integrity — an outcome critics described as lenient relative to the scale of harm.

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. The new article criminalizes the dissemination of AI-generated pornographic content without consent, carrying penalties of one to two years' imprisonment, and sets a minimum age of 16 for a person to consent to the use of their own image.

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.

Read the full analysis: https://www.lamoncloa.gob.es/lang/en/gobierno/councilministers/paginas/2025/20250325-council-press-conference.aspx