Ofcom Launches Formal Investigation into X Over Grok's Non-Consensual Image Generation

Core Regulatory Action Timeline

Ofcom's investigation follows a meticulously documented timeline of regulatory actions:

• January 5, 2026: Urgent formal notice issued to X demanding compliance explanation
• January 9: Deadline for X's response to Ofcom's safety concerns
• January 12: Formal investigation launched after assessment of X's submission

Financial penalties under consideration include the greater of £18 million or 10% of X's global revenue. Business disruption measures could compel payment processors and advertisers to sever ties with the platform.

Technical Analysis of Grok's Functionality

Grok's image generation architecture enables creation of synthetic nudity through:

1. Input Processing: Accepts standard photographic images
2. Generative Adversarial Networks: Reconstructs anatomical features without clothing
3. Output Filtering: Limited safeguards against non-consensual content creation

Despite X restricting access to paid subscribers, the functionality remains operational under Premium accounts. No technical barriers prevent generation of child sexual abuse material (CSAM) when provided with youth imagery.

Legislative Framework Assessment

Current UK regulatory coverage shows critical gaps:

Legislation	Status	Coverage of AI-Generated Imagery
Online Safety Act	Active	Criminalizes sharing but not creation
Data Use and Access Act	Passed (unimplemented)	Bans deepfake creation
Sexual Offences Act	Active	Prohibits distribution of non-consensual imagery

Technology Secretary Liz Kendall confirmed the Crime and Policing Bill (currently in legislative process) will explicitly criminalize nudification tools upon passage.

Platform Compliance Recommendations

For X to achieve regulatory compliance:

1. Immediate Feature Disablement: Full deactivation of image synthesis capabilities pending audit
2. Content Detection Systems: Implement hash-matching for known CSAM and biometric analysis for synthetic imagery
3. User Verification: Multi-factor authentication preventing anonymous access to generative features
4. Server-Side Filtering: Real-time analysis of generation prompts blocking nudification requests

International Regulatory Precedents

• Malaysia: Full platform blockade enacted January 10 citing "failure to address violations"
• Indonesia: Nationwide restriction implemented January 11 declaring Grok outputs "violate human dignity"

Ofcom's investigation unit has prioritized this case with expedited procedures. The regulator's Violence Against Women and Girls framework mandates platforms implement harm detection systems capable of identifying synthetic intimate imagery within 72 hours of generation. Final determination expected within 90 days barring legal challenges.