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Spain’s Data Watchdog Issues Europe’s First Fine for AI-Generated Nude Deepfake

The authority applied GDPR by classifying the altered image as personal data processed without a lawful basis.

Overview

  • The AEPD imposed a €2,000 penalty on the perpetrator, reduced to €1,200 for prompt payment, in a publicly released but redacted resolution.
  • The regulator opened proceedings on September 20, 2023 after press reports and admitted a victim’s complaint filed on October 2, 2023.
  • Investigators sought information from the Public Prosecutor’s Office and the Tax Agency to identify and locate the person behind the manipulation.
  • The decision has been linked by media to the 2023 Almendralejo case involving minors who previously received one year of supervised liberty and educational measures.
  • The move is presented as Europe’s first administrative monetary sanction for a nude deepfake, complementing a 2024 Berlin court order that halted distribution of a Scholz deepfake.