Senior Associate James Broomhall has provided comment in Reuters on the growing concerns surrounding the legality of explicit images produced by Elon Musk’s Grok AI, and where criminal liability lies for the production of such images.

Explaining where criminal liability could potentially lie, James said: “While criminal liability would ordinarily rest with the user, the Online Safety Act 2023 imposes regulatory duties on service providers to mitigate and prevent harmful content, including deepfake pornography; failure to do so can result in significant fines, and although the Act does not create individual takedown offences, a platform or its parent could still face criminal exposure if it were shown to have intentionally created or requested non-consensual AI-generated sexualised images.”

James’ commentary was published in Reuters and The Independent, 3 February 2026.