Taotlus

Pärnu mnt 139 / 15060 Tallinn / [email protected] / www.politsei.ee

Registry code 70008747

FOR INTERNAL USE

Notation made on:

Final date:

Basis:

Holder of information: Police and Border

Guard Board

UndressMe AI

[email protected]

Your ref no

Our ref 17.04.2026 no 2.1-3/13719-1

Procedural notice and request for

assistance to counter the threat

Police and Border Guard Board of the Republic of Estonia (hereinafter referred to as PBGB) is

contacting the organization UndressMe AI as the operator of the artificial intelligence content

generation tool (hereinafter referred to as the Program) regarding information indicating

possible misuse of the Program for the creation of material depicting minors in sexually explicit

or suggestive contexts.

The purpose of this notice is to inform the service provider of the suspected misuse of its service

and to request the provider’s observations and information regarding the measures taken to

prevent such misuse.

1.1 Legal framework

According to § 178 of the Estonian Penal Code, it is prohibited to produce, acquire, store,

display or distribute material depicting a person under eighteen years of age in a pornographic

or erotic situation (Karistusseadustik, § 178).

The interpretation of erotic content involving minors has been clarified in Estonian case law.

The Criminal Chamber of the Supreme Court has held that erotic content may also be present

where otherwise ordinary situations are depicted but the focus of the material is recognisably

directed towards the naked bodies of children and the representation has no other meaningful

context (Riigikohus, 2017). The Tallinn Circuit Court has further stated that erotic content may

occur even in depictions of ordinary life situations where the visual focus is deliberately

directed at children’s bodies in a sexualised manner (Tallinna Ringkonnakohus, 2022).

At the European Union level, Directive 2011/93/EU on combating the sexual abuse and sexual

exploitation of children defines child sexual abuse material as including any material depicting

a person under eighteen years of age in a real or simulated sexually explicit situation (European

Parliament & Council of the European Union, 2011). Recent legislative developments at the

European Union level further clarify that such material may also include realistic images or

pseudophotographs generated through artificial intelligence or similar technologies (European

Parliament, 2025).

Under § 6 subsection 1 of the Estonian Law Enforcement Act, a law enforcement agency is an

authority authorised by law to perform state supervision. Pursuant to § 6 subsection 2 of the

same Act, where the ascertainment and countering of a threat or elimination of a disturbance

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does not fall within the competence of another authority, it is within the competence of the

police. In accordance with § 30 subsection 1 of the Law Enforcement Act, the police may

question a person if there is reason to believe that the person possesses information necessary

for preventing or countering a threat or eliminating a disturbance within the competence of the

authority (Korrakaitseseadus, § 6; § 30).

In accordance with § 40 subsection 1 of the Administrative Procedure Act, before issuing an

administrative act, an administrative authority shall grant the participant in proceedings the

opportunity to present their opinion and objections. Where such an opportunity has been granted

but the participant does not respond within the specified time limit, the authority may proceed

with issuing an administrative act on the basis of the information available (Haldusmenetluse

seadus, § 40).

In addition, pursuant to Article 51(1)(a) of Regulation (EU) 2022/2065 (Digital Services Act),

the competent authority has the power to require providers of intermediary services and other

relevant persons to provide information necessary for the performance of supervisory tasks

without undue delay. Where such requested information is not provided, Article 51(2) of the

Digital Services Act empowers the competent authority to adopt enforcement measures,

including the issuance of binding orders to ensure compliance with applicable legal obligations

(European Parliament & Council of the European Union, 2022).

Accordingly, where the requested explanations or information are not provided within the

specified time limit, the competent authority is entitled to proceed with the issuance of a binding

administrative order in order to ensure compliance with applicable legal requirements and to

prevent the continued availability or dissemination of potentially unlawful content.

1.2 Information received by the Police and Border Guard Board

According to information received by PBGB, there are references indicating that the Program

operated by UndressMe AI may have been used to generate images depicting persons appearing

to be minors in sexually suggestive or pornographic situations. At this time we have information

about 3 of such cases.

The descriptions of the material indicate that the generated content depicting faces of real

persons appearing to be under the age of fourteen in pornographic situations.

Although PBGB has not at this stage captured specific URLs, image hashes or user account

identifiers associated with the content, the available information indicates that the material may

have been generated using the Program and shared through online environments.

Such content may fall within the scope of material depicting minors in pornographic or erotic

situations within the meaning of § 178 of the Penal Code.

PBGB also notes that according to the Terms of Service, the Program uses automated

mechanisms intended to detect attempts to upload images of minors and maintains logs of such

attempts for a period of up to six years. PBGB therefore requests confirmation whether such

detection mechanisms have identified any attempts to generate or upload content involving

minors and whether corresponding logs exist that could assist in assessing the potential misuse

of the Program related to Estonia.

1.3 Terms of service of the service provider

PBGB notes that the publicly available Terms of Service of the Program contain provisions

prohibiting the creation of such material.

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In particular, the Terms of Service state that:

• uploading, attempting to create or generating content involving minors is strictly prohibited

• any content involving child abuse or exploitation, including images or artistic depictions of

minors in sexual or suggestive contexts, is prohibited

• users must not upload or generate reference images involving minors.

These provisions demonstrate that the service provider itself recognizes the risk of misuse of

the Program for generating content involving minors.

1.4 Possible misuse of the service

According to the information available to PBGB, the suspected misuse may involve:

• generating synthetic content depicting minors in pornographic situations

• generating content based on prompts describing minors in pornographic contexts

• sharing such generated material through external platforms.

Where such activity occurs, it may constitute the production or dissemination of material

depicting minors in erotic or pornographic situations within the meaning of § 178 of the Penal

Code.

In addition, where real or identifiable individuals are used as a reference for generating

synthetic sexual images, the conduct may also raise issues related to the unlawful use of another

person’s identity or personal data under § 157¹ and § 157² of the Penal Code.

1.5 Request for information

PBGB requests UndressMe AI to provide information and observations regarding the

following:

 whether the service provider has detected attempts to generate images depicting minors

in sexual or suggestive contexts using the Program

 what technical measures are implemented in the Program to prevent the creation of such

content

 whether any content moderation or automated detection mechanisms are used to identify

prompts or generated images involving minors

 whether the service provider retains logs, metadata or other information regarding

generated content which could assist in identifying such misuse

 whether the service provider has previously reported similar incidents to competent

authorities.

 whether the generation of content through the Program requires the use of Gems or other

paid tokens and whether records of such transactions are retained.

PBGB also requests information regarding whether the Program stores generated content or

corresponding hash values that could be used for identification of such material.

1.6 Request for cooperation

PBGB emphasizes that the purpose of this notice is to inform the service provider of potential

misuse of the Program and to encourage cooperation in preventing the generation or

dissemination of material harmful to children.

PBGB invites UndressMe AI to provide information on the measures taken or planned to

strengthen safeguards preventing the generation of such material.

PBGB also requests information regarding the appropriate contact channel for potential law

enforcement cooperation in the event that further investigation becomes necessary.

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1.7 Deadline for response

PBGB requests UndressMe AI to submit its observations and the requested information within

30 days from the receipt of this notice.

Responses may be submitted electronically to the Police and Border Guard Board via the

designated contact channel [email protected]

2. Recommendations for internal review

In light of the information described above, PBGB recommends UndressMe AI to initiate an

internal review in order to assess whether the Program may have been used to generate content

involving minors in sexual or suggestive contexts.

PBGB recommends that the internal review includes,

 where technically possible: verification of whether prompts or reference inputs

describing minors have been submitted to the Program

 review of generated outputs that may depict minors in sexualized situations

 assessment of whether such content may have been generated or stored within the

Program infrastructure

 identification of user accounts involved in the generation or distribution of such material

 preservation of relevant logs, metadata and other technical information that may assist

in determining the origin and distribution of the material.

PBGB further requests that any information identified during such review that may indicate the

creation or dissemination of child sexual abuse material be preserved in accordance with the

applicable legal requirements and, where relevant, communicated to the competent law

enforcement authorities.

The purpose of this request is to prevent the potential misuse of the Program and to support the

protection of children in online environments.

3 References

European Parliament. (2025). Proposal for a directive of the European Parliament and of the

Council on combating child sexual abuse and child sexual exploitation. https://eur-

lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:52025AP0116

European Parliament, & Council of the European Union. (2011). Directive 2011/93/EU of the

European Parliament and of the Council of 13 December 2011 on combating the sexual abuse

and sexual exploitation of children and child pornography. https://eur-

lex.europa.eu/eli/dir/2011/93/oj

European Parliament, & Council of the European Union. (2022). Regulation (EU) 2022/2065

of the European Parliament and of the Council of 19 October 2022 on a single market for

digital services and amending Directive 2000/31/EC (Digital Services Act). https://eur-

lex.europa.eu/eli/reg/2022/2065/oj

Riigikohus. (2017). Criminal Chamber judgment No. 1-16-5792

https://www.riigikohus.ee/et/lahendid?asjaNr=1-16-5792/101

Tallinna Ringkonnakohus. (2022). Judgment No. 1-21-7004.

https://www.riigiteataja.ee/kohtulahendid/detailid.html?id=312681027

Republic of Estonia. (2025). Penal Code.

https://www.riigiteataja.ee/en/eli/507052025001/consolide

Republic of Estonia (2023). Administrative Procedure Act.

https://www.riigiteataja.ee/en/eli/505122023003/consolide

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Yours sincerely

(Digitally signed)

Eduard Kamenski

Senior Commissioner

North Prefecture, Information Bureau, Web

Community Group

Web Police Officer

Eduard Kamenski, +3726125840, [email protected]