OpenAI absolutely prohibits using any of its tools or models to generate sexual content involving minors, with no exceptions regardless of context, operator permissions, or stated purpose.
This analysis describes what OpenAI's agreement states, permits, or reserves. It does not constitute a legal determination about enforceability. Regulatory applicability and practical outcomes may vary by jurisdiction, enforcement context, and individual circumstances. Read our methodology
This is a hard, unconditional restriction that applies to every user and operator without exception; violation would constitute both a policy breach and potentially criminal conduct under laws in most jurisdictions.
Any user or developer who generates or attempts to generate child sexual abuse material using OpenAI products will be in violation of this policy and subject to account termination, and the conduct may be reportable to law enforcement under applicable mandatory reporting obligations.
How other platforms handle this
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"Generate CSAM or detailed sexual content involving minors— Excerpt from OpenAI's OpenAI Usage Policies
(1) REGULATORY LANDSCAPE: This provision directly engages with the PROTECT Act (18 U.S.C. § 2256 and related sections) in the United States, the EU's Directive on combating sexual abuse and exploitation of children, and equivalent criminal statutes in virtually all jurisdictions. The National Center for Missing and Exploited Children (NCMEC) operates the CyberTipline, and electronic service providers may have mandatory reporting obligations under 18 U.S.C. § 2258A. The FTC and state attorneys general also have consumer protection authority over platforms that fail to implement adequate safeguards. (2) GOVERNANCE EXPOSURE: High. This is among the most legally and reputationally significant prohibitions in the document. Failure to enforce this restriction — whether through technical controls, content moderation, or operator oversight — could expose OpenAI and downstream operators to criminal referral, civil liability, and regulatory enforcement action. (3) JURISDICTION FLAGS: This obligation applies globally. All major jurisdictions criminalize CSAM generation and distribution. EU operators face obligations under the proposed EU CSAM Regulation in addition to existing national criminal law. UK operators must comply with the Online Safety Act's provisions on illegal content. (4) CONTRACT AND VENDOR IMPLICATIONS: API operators must ensure their own terms of service and technical controls prohibit this use. Procurement teams should verify that any downstream integration of OpenAI models includes explicit contractual prohibitions on CSAM-related use and appropriate content filtering. This prohibition should be reflected in vendor risk assessments. (5) COMPLIANCE CONSIDERATIONS: Operators should implement content filtering and detection mechanisms, establish incident response procedures for potential CSAM detection, document their compliance posture, and assess whether their platforms trigger mandatory NCMEC reporting obligations under federal law. Legal teams should confirm that employment and contractor policies address reporting obligations.
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This is a hard, unconditional restriction that applies to every user and operator without exception; violation would constitute both a policy breach and potentially criminal conduct under laws in most jurisdictions.
Any user or developer who generates or attempts to generate child sexual abuse material using OpenAI products will be in violation of this policy and subject to account termination, and the conduct may be reportable to law enforcement under applicable mandatory reporting obligations.
No. ConductAtlas is an independent monitoring service. We are not affiliated with, endorsed by, or sponsored by OpenAI.