Nudify Apps: Federal Laws, Penalties, and Removal Steps

Nudify apps are software programs that use artificial intelligence (AI) to create fake nude depictions of real people from regular, clothed photographs without their consent. In the United States, knowingly publishing these computer-generated intimate images of an identifiable person is a federal crime under the TAKE IT DOWN Act (S.146, Public Law 119-12). Under this federal framework, covered online platforms must remove flagged digital forgeries within 48 hours of receiving a valid complaint, and federal regulators have begun issuing formal warnings to companies operating automated undress services.

What Nudify Apps Are

Nudify apps take an existing image of a clothed individual and alter the body to appear unclothed or sexually explicit. The final output is an intimate depiction of an identifiable individual that did not exist in reality.

The term digital forgery defines these files under federal law. A digital forgery refers to an intimate depiction of an identifiable person created or altered using software, machine learning, artificial intelligence, or other technological means in a way that appears indistinguishable from an authentic visual record to a reasonable observer. You can track broader regulatory developments on our AI legislation hub.

These applications operate without obtaining the permission of the depicted individual. In the guides we publish here at Ban the Bots, we document how technological tools create severe nonconsensual harms when deployed against unsuspecting individuals.

Legal Status and the TAKE IT DOWN Act

Publishing nonconsensual explicit imagery made with AI undress tools is now covered directly by federal law. The TAKE IT DOWN Act (designated as S.146 and enacted as Public Law 119-12) was signed into law on May 19, 2025. The legislation established a federal criminal prohibition against knowingly publishing nonconsensual intimate digital forgeries.

The measure advanced through the United States Congress. The United States Senate passed the bill by unanimous consent on February 13, 2025. The United States House of Representatives followed on April 28, 2025, voting 409 to 2 to approve the statutory changes. You can examine our full analysis of the statutory text in our TAKE IT DOWN Act explainer.

The statute makes it a federal criminal offense to knowingly publish nonconsensual intimate images, a definition that specifically includes digital forgeries generated by automated software. Furthermore, the statute criminalizes threats to publish either authentic intimate recordings or synthetic digital forgeries. Related state-level initiatives and statutory definitions are cataloged on our deepfake laws page.

Federal Penalties and the First Conviction

Federal penalties under Public Law 119-12 impose substantial criminal sanctions on individuals who publish or threaten to publish synthetic intimate material. The statutory penalties differ based on the age of the victim and whether the conduct involves actual dissemination or coercive threats.

Federal prosecutors have already secured criminal convictions using these statutory provisions. James Strahler II of Columbus, Ohio became the first individual convicted under the TAKE IT DOWN Act according to reporting by NBC Washington, which cited statements from the United States Department of Justice (DOJ). In April 2026, Strahler pleaded guilty to multiple federal charges that included cyberstalking, producing obscene visual representations of child sexual abuse, and publishing nonconsensual digital forgeries.

On September 9, 2026, Spectrum News 1 Columbus reported that Strahler was sentenced to 15 years in prison on the combined charges. More context on synthetic visual manipulation is available in our overview of deepfakes.

Platform Removal Rules and FTC Warnings

Beyond penalizing individual perpetrators, the TAKE IT DOWN Act establishes enforceable operating requirements for commercial websites, hosting services, and social media platforms. Since May 19, 2026, covered platforms must remove flagged digital forgeries and all known identical copies as soon as possible, and no later than 48 hours after receiving a valid removal request.

The Federal Trade Commission (FTC) enforces the platform compliance obligations outlined in the law. Prior to the May 19, 2026 statutory enforcement date, the FTC issued formal compliance reminder letters to 15 technology companies detailing their upcoming obligations. On May 20, 2026, the FTC announced that it had dispatched formal warning letters to 12 separate commercial companies operating automated nudify tools that appeared to provide users with no mechanism to submit takedown notices. The FTC said those companies could face civil penalties of up to $53,088 per violation.

Through mid-October 2026, the FTC has not filed a formal administrative complaint, initiated a civil lawsuit, or announced a public settlement under the Act. To submit an administrative enforcement complaint against a non-compliant service, the FTC operates a dedicated portal at TakeItDown.ftc.gov. Victims can use that government resource when an online platform lacks a functional intake mechanism or refuses to remove synthetic imagery within the required 48-hour window. Practical ways to push back are collected on our fighting back page.

Mainstream Image Generators and Grok Imagine

Synthetic explicit depictions are not confined to obscure websites; mainstream consumer tools have also generated unauthorized explicit material. In January 2024, AI-generated sexually explicit images depicting musician Taylor Swift spread rapidly on social media platform X, accumulating more than 47 million views before moderators removed the files from the network.

In August 2025, xAI released its Grok Imagine media generation service in a public beta test. On August 5, 2025, The Verge reported that the system's optional spicy mode generated topless synthetic videos depicting Taylor Swift in response to an ordinary, non-explicit text prompt: "Taylor Swift celebrating Coachella with the boys."

Our article covering Grok deepfakes examines the timeline and platform response in greater detail.

Action Plan for Victims of Digital Forgeries

When an individual discovers that an undress tool or synthetic media application has produced an unauthorized depiction of their likeness, taking systematic steps helps establish a clear evidentiary record and speeds up removal across commercial networks.

Document the evidence immediately

Preserve records before files get deleted or accounts get banned. Capture complete screen captures of the synthetic images, the surrounding profile pages, user account handles, dates, and timestamps. Copy and store the exact web addresses (URLs) linking directly to the hosted visual files.

Submit a formal platform takedown notice

Under the TAKE IT DOWN Act, online hosting services must act within 48 hours only if the incoming takedown request satisfies specific statutory standards. To submit a valid request, prepare an electronic or written message containing these four items:

• A signature.
• Information to locate the image.
• A brief good-faith statement confirming that the depiction was created or published without consent.
• Contact information.

Escalate to federal agencies and law enforcement

If a commercial hosting provider fails to take down the material within 48 hours, file an administrative complaint through TakeItDown.ftc.gov. Victims should also report nonconsensual intimate imagery directly to local municipal police departments and the Federal Bureau of Investigation (FBI). Victims can seek support through the Cyber Civil Rights Initiative (cybercivilrights.org).

The DEFIANCE Act passed the United States Senate in January 2026. As of this site's last check, the legislative measure remained pending before the United States House of Representatives. If enacted into law, this proposal would give victims a federal civil right of action. The Electronic Frontier Foundation (EFF) published an analysis noting that the administrative takedown provision in Public Law 119-12 covers a much broader category of content than the criminal definitions set forth elsewhere in the statute.

The EFF also noted that the statutory mechanism lacks critical safeguards against frivolous or bad-faith takedown requests. The law sets no penalty for a false removal request. Readers investigating digital media authenticity can review our guide on how to spot a deepfake.

Reducing exposure to nonconsensual generation

Individuals can limit the audience settings on personal social media accounts to trusted acquaintances rather than public feeds. Parents can find related protective strategies on our AI safety for parents resource.

This explainer provides factual information on federal statutory requirements, platform obligations, and regulatory enforcement. This material does not constitute formal legal advice. Individuals facing immediate extortion, harassment, or distribution of nonconsensual imagery should contact qualified legal counsel, local law enforcement, or the Federal Bureau of Investigation at 1-800-CALL-FBI to initiate formal protective proceedings.