Concerns about sharing children’s photographs online has been an issue for many years. Historically, these concerns have focused on privacy, identity theft and digital footprints. However, more recently those concerns have turned to the rapid development of artificial intelligence (AI) creating a new safeguarding risk with the ability to turn innocent images of children into AI-generated child sexual abuse material.
Recent warnings from the National Crime Agency (NCA) and the Internet Watch Foundation (IWF) highlight how offenders are harvesting ordinary photographs from social media, school websites, sports clubs and other public sources before manipulating them into sexualised and abusive content. In many cases, the original image is entirely innocent.
According to the IWF, analysts identified 6,310 AI-generated images meeting the legal definition of child sexual abuse during the first half of 2026, surpassing the total identified during the whole of 2025. The organisation has also reported a significant increase in AI-generated abuse videos and images involving younger children.
This development therefore presents a significant challenge for organisations working with children. Photographs published to celebrate achievements, promote activities or engage communities may now carry risks that would have been difficult to envisage only a few years ago. The issue is no longer simply who can see an image, but how that image can be copied, altered and exploited using increasingly sophisticated AI tools.
Parents are also increasingly using AI-powered applications to enhance, edit or modify photographs. Recent reports of the use of AI tools to remove watermarks from school photographs have highlighted a broader concern as once a child’s image is uploaded to an AI platform, there may be little visibility and control over how it is stored, processed, retained or reused.
Depending on the provider’s terms, images may be transferred internationally, retained for extended periods, used to train future AI models or exposed in the event of a data breach. Where school or group photographs are involved, parents may also inadvertently upload images of other children without the knowledge or consent of their families.
Against this backdrop, organisations should be actively educating parents about these emerging risks. While photography remains an important part of school life, it is important to ensure that governance and safeguarding practices keep pace with these rapid developments in technology.
In this respect, organisations should review:
Safeguarding leads should also consider AI-related image misuse as part of wider online safety and child protection strategies.
The implications extend beyond safeguarding. As awareness of AI-generated child sexual abuse material grows, organisations may face increasing scrutiny regarding how children’s images are obtained, stored and shared.
While the legal landscape is still evolving, insurers should be alert to potential claims involving allegations of safeguarding failures, misuse of children’s data, privacy breaches and psychiatric injury linked to the creation or circulation of manipulated images. Even where liability is not established, the reputational impact on an organisation could be considerable.
The technology is advancing faster than many safeguarding frameworks. What was once viewed primarily as a privacy issue is increasingly becoming a child protection issue.
The warnings from the NCA and IWF should serve as a timely reminder that safeguarding arrangements must evolve alongside emerging technologies. For organisations working with children, reviewing image-sharing practices, strengthening consent procedures and educating staff, parents and young people about AI-related risks are sensible and proportionate steps.
For insurers, AI-generated child sexual abuse material represents an emerging exposure that is likely to become increasingly relevant in the years ahead. Organisations that act now will be best placed to demonstrate robust safeguarding governance and a proactive approach to managing this rapidly developing risk.
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