Is Clearview AI Legal? What Regulators and Courts Ruled

Whether Clearview AI is legal depends on the jurisdiction. Regulators in Europe have fined Clearview AI, and in the United States (US) a class settlement approved in March 2025 was vacated by the U.S. Court of Appeals for the Seventh Circuit on July 13, 2026. As of November 1, 2026, no US class settlement is final.

Fines and court rulings differ in kind. A fine is a penalty set by a data protection authority, and the US ruling concerns a class settlement of private lawsuits.

Is Clearview AI Legal? What Regulators and Courts Decided

The Dutch and Italian fines are documented from retrieved sources. The French, Greek and UK actions are reported, with primary pages not retrieved, and the UK case has permission to appeal to the Court of Appeal. The table lists each action with its date and its source.

Sources differ on two dates. The Italian order is dated February 10, 2022, and it was announced March 9, 2022. Reports give the French decision as October 17, 19 or 20, 2022, so October 2022 is used here.

The US row records a court ruling on private lawsuits and involves no regulator fine. The UK row is a tribunal dispute over whether the ICO had jurisdiction at all. The First-tier Tribunal held that it lacked jurisdiction, and the Upper Tribunal ruled in October 2025 that it had jurisdiction.

What Clearview AI Does

Clearview AI operates a search engine for faces. It scrapes photographs from public websites, including social media, creates facial vectors, and returns matching photos with links to their sources when a user searches with a photo. The Seventh Circuit opinion describes this process.

The Dutch DPA says the database holds more than 30 billion photos of individuals. That figure is the Dutch regulator's own statement.

Clearview's customers originally included private companies. Since at least a settlement of a separate lawsuit with the American Civil Liberties Union (ACLU), they have included only federal and state government agencies and their contractors.

The class actions followed a January 2020 exposé in The New York Times. The Judicial Panel on Multidistrict Litigation transferred eleven cases to the Northern District of Illinois. Clearview is a Delaware corporation headquartered in New York.

The ethical debate over face scraping from public websites is covered in the facial recognition ethics guide.

The US Class Settlement: Approved, Then Vacated

The class settlement was negotiated after a first round of talks failed. Clearview, an undercapitalized start-up, could not make a large immediate payment.

Under the terms, the class would receive a payment equal to a 23 percent equity stake in Clearview, measured as of September 6, 2023. That payment would come on an initial public offering (IPO) or a liquidation event, such as a merger, consolidation or sale. The settlement master may instead sell the stake, or demand 17 percent of Clearview's generally accepted accounting principles (GAAP) revenue by September 30, 2027.

The settlement contained no injunctive relief.

The district court granted final approval on March 20, 2025. The Seventh Circuit found no inherent problem with the lack of injunctive relief or with the equity-stake form of payment. It vacated approval anyway, because the nationwide class had no separate representative for allocating relief among subclasses. The opinion calls it a general remand, which sends the case back to the district court.

The settlement was not paid out. As of November 1, 2026, no approved US class settlement is in force and nothing has been paid under it.

The Seventh Circuit opinion records that the district court credited the class's assertion, based on confidential Clearview financial documents, that Clearview was valued at about $225 million in January 2024. That makes the 23 percent stake about $51.75 million. The stake pays out only on an IPO or liquidation event, unless the settlement master sells it or demands 17 percent of revenue instead.

No source cited here reports the outcome of the remand.

Fines Versus Compliance in Europe

A fine is a penalty, while an order sets what Clearview must stop or delete. The sources record both separately. No source cited here reports that Clearview complied with any of the orders.

The Dutch DPA ordered Clearview to cease the unlawful behavior. It said Clearview faces an additional penalty if it does not comply, and no source cited here states the amount of that penalty. The Hunton summary is the only source cited for the Dutch decision, because the Dutch authority's own page returned an access error.

The Garante ordered deletion of data relating to people located in Italy. It also ordered a stop to further collection and processing through the facial recognition system, and the appointment of a representative in the European Union. Biometric Update reported in April 2025 that the EUR 20 million Italian fine was unpaid at that time.

Garante commissioner Guido Scorza said at a 2025 summit of the International Association of Privacy Professionals (IAPP) that the regulator was working with the US Federal Trade Commission (FTC) to notify Clearview formally of the enforcement action. He also criticised the lack of an international convention for enforcement. No source cited here reports payment after April 2025.

The French data protection authority (CNIL) is reported to have imposed the maximum fine under the General Data Protection Regulation (GDPR), EUR 20 million, in October 2022. The decision followed a formal notice dated November 26, 2021. It reportedly ordered Clearview not to collect and process data on people in France without a legal basis. Reports also say a further penalty payment of EUR 5.2 million was imposed on April 13, 2023 for not complying.

No CNIL page is cited here. The account rests on a European Data Protection Board (EDPB) national-news item, and the EDPB says such items are not official EDPB communications.

The Hellenic Data Protection Authority is reported to have fined Clearview EUR 20 million in Decision 35/2022, dated July 13, 2022. The decision reportedly found breaches of lawfulness and transparency principles and of data-subject rights. It also reportedly ordered deletion of data on Greek data subjects and a ban on further processing. The account rests on an EDPB national-news item, and no Hellenic DPA page is cited here.

The UK Information Commissioner's Office (ICO) fined Clearview GBP 7.5 million in 2022. A First-tier Tribunal held that the ICO lacked jurisdiction. In October 2025, the Upper Tribunal ruled that the ICO had jurisdiction and sent the substantive appeal back to the First-tier Tribunal. The ICO's news item, dated December 19, 2025, reports that Clearview was granted permission to appeal to the Court of Appeal. The ICO page was not retrieved, so these points are reported. No Court of Appeal outcome was found.

No retrieved source states whether the Dutch, French or Greek fines have been paid. Payment status of the Italian fine after April 2025 was not found.

Can You Opt Out of Clearview AI?

The sources establish an opt-out program for Illinois residents. Under the ACLU settlement, Clearview was required to establish that program. The settlement also permanently enjoined Clearview from allowing database access to private parties except in compliance with the Illinois Biometric Information Privacy Act (BIPA).

Clearview has expanded its opt-out program from Illinois to other states, or stopped doing business there, to comply with new biometric privacy laws. The opinion names California and Virginia. As of the opinion, Clearview had not extended the program to New York.

The Greek decision, as reported, found breaches of data-subject rights. No source cited here establishes a general opt-out route for people in other states or countries, or the steps to use one.

If you live in Illinois, the program the ACLU settlement requires is the route the sources record. If you live in California or Virginia, the opinion names those states as places where the program was extended. If you live in New York, the opinion says the program had not been extended there as of the opinion. If you live elsewhere, no source cited here sets out a route.

For the wider category of face search tools, see the facial recognition search guide.

Who Uses Clearview AI

Clearview's customers have been limited to federal and state government agencies and their contractors since at least the ACLU settlement, according to the Seventh Circuit opinion. No source cited here names an individual agency.

For how immigration enforcement uses face matching in general, read the guide to US Immigration and Customs Enforcement (ICE) facial recognition. No source cited here says Clearview supplies ICE.

What You Can Do About Face Scraping

The Seventh Circuit opinion is the primary US record cited here, so it is the place to start. Read the Seventh Circuit opinion, then the facial recognition laws guide for the rules on facial recognition.

For a broader overview, see the facial recognition privacy guide. For ways to push back on face scraping, see the fighting back section.

Clearview AI's legal status depends on the jurisdiction. It rests on the Seventh Circuit opinion, the Garante's own page, the Hunton summary of the Dutch decision, the EDPB national-news items, the Biometric Update report and the reported ICO item. The answer would change if the Seventh Circuit remand produces a new settlement or a different outcome, if the UK Court of Appeal decides the ICO case, or if regulators enforce the unpaid fines. These findings reflect the cited records as of November 1, 2026. They report regulator and court actions and are not legal advice.

Read the Seventh Circuit opinion first, then decide whether the Illinois opt-out program that Clearview AI runs under the ACLU settlement applies to you.