AI Nude Deepfakes: How Online Shops Profit from Sexualized Image Abuse

Websites promising an 'X-ray vision' for photos have become openly available online. Using so-called nudifiers, they replace clothing with naked skin in uploaded images. Because such tools are now so easy to use, image-based abuse has become more accessible than ever. An investigation by netzpolitik.org compared ten such deepfake websites and found that they can be located within minutes using simple search terms. Creating sexualized deepfakes without the consent of the person depicted violates sexual self-determination and constitutes image-based violence, and distributing such images may be a criminal offense.

The technology behind these services is based on general-purpose image generators such as the open-source Stable Diffusion, several of which explicitly reference it. In simplified terms, software first detects the outline of a clothed person and then fills that area with a depiction of a naked body, while preserving the face and background. Frontal photos with tight-fitting clothing can produce highly realistic results. Although people have long manipulated photos with scissors and glue, AI deepfakes are far easier to create and far more convincing.

Only a few years ago, access to such tools was much harder. Software like Deepnude in 2019, and FaceSwap apps investigated in 2022, were confined to forums or required specific workarounds. Today, users simply register with an email address and upload any photo. The first images are free, after which subscriptions apply. Premium plans range from about 2 euros for beginners to as much as 380 euros for an annual subscription, promising higher resolution or faster processing. Operators claim hundreds of thousands of monthly users, though these figures cannot be independently verified. Analysis via the Internet Archive shows that these shops are a relatively recent development, with most appearing between 2023 and 2024.

All ten sites display at least superficial legal and ethical disclaimers. Pop-up notices state that users must be adults and may not upload images without consent, and some websites describe the generated content as art or disclaim responsibility. Several claim to block sexualized images of minors, and one asserts that it blocks 99.9 percent of illegal content through automated and manual review, while embedding watermarks with timestamps and IP addresses. Automated age estimation is imprecise, however, and especially unreliable for people around 18. None of the shops checked identity or consent through document verification or video confirmation, measures that major adult platforms such as Pornhub now require from performers.

Mainstream payment services play a role in this business. Six of the ten shops accept Visa and Mastercard, three accept PayPal, and three accept Google Pay. Eight offer login via Gmail, which also serves as a barrier against bots. Visa, Mastercard, PayPal, and Google told netzpolitik.org that such shops violate their policies and that they investigate reports, but none would say how often this has occurred. Several shops have already prepared for the loss of conventional payment options by accepting cryptocurrency.

Only three of the ten shops list a company address on their websites, and their registrations point to the United Kingdom and Argentina. Two others name the UK as their base, and two more claimed Cambodia and Taiwan when asked directly. The remaining three operators remain entirely unclear. One Taiwan-linked shop claims 200,000 paying users and 100,000 generated images per day, while a Cambodia-linked one reports 6,000 images daily and nearly 22 million images created since its founding. These numbers cannot be verified externally, and competitive pressure may encourage operators to exaggerate their popularity.

Deepfake nude images can spread quickly, including through schools and workplaces, and can humiliate and injure victims even when the image does not show their real body. In Pennsylvania, police arrested a student accused of creating AI nude images of classmates, and parents criticized the school's response. In Spain, a deepfake case the previous year became a national scandal after the mothers of affected girls organized and media reported widely. Using a few photos taken from social media, perpetrators could reproduce similar incidents with little effort. Victims often cannot know whether others believe the images are real, a concern raised by HateAid, an organization supporting victims of digital violence.

Digital violence of this kind is directed disproportionately at women, and this is reflected in the shops studied, where female bodies dominate the imagery and male nudity is only occasionally offered. Many of the bodies used as templates likely belong to erotic or pornographic performers, whose work is often precarious and who rarely consent to their content being used for AI training or deepfake templates. Ultimately, non-consensual sexualized deepfakes are less a technological or legal problem than a social one, rooted in people's decisions to violate the boundaries of others. As long as producing such images remains widely accepted, it will be very difficult to contain them.

To protect victims, the EU has agreed on a directive on combating violence against women, requiring member states, including Germany, to explicitly criminalize the distribution of non-consensual sexualized deepfakes. Member states have three years to implement it, so the new rules will likely take effect only from 2027. Until then, victims in Germany must rely on existing laws, such as civil claims for violation of personality rights, the German Art Copyright Act (KUG), and in some cases criminal provisions for insult or defamation, as noted by HateAid and the German Women Lawyers' Association.

The spread of AI nudifier websites exposes gaps in technical safeguards, payment oversight, and legal protection, but its root lies in social norms that tolerate the creation of non-consensual intimate imagery. Effective response will require stronger enforcement by payment providers and platforms, clearer legislation that is implemented promptly, and a broader cultural shift that treats the sexual exploitation of others' images as unacceptable.