The policy prohibits using any OpenAI service to generate sexual content involving minors, including imagery, text, or any other format that sexualizes individuals under 18.
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 prohibition applies to all users and operators without exception and represents an absolute restriction with no operator override capability, meaning no business or personal use case authorizes this content.
Interpretive note: The exact verbatim text could not be extracted from the PDF binary. The provision's existence and scope is inferred from the document metadata, linked URLs referencing OpenAI's CSAM policy, and publicly available versions of OpenAI's Usage Policy consistent with this document.
Any user or developer who generates or facilitates the generation of child sexual abuse material using OpenAI services is in direct violation of this policy and subject to immediate account termination, as well as potential criminal referral under applicable law.
How other platforms handle this
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1. REGULATORY LANDSCAPE: This provision directly intersects with COPPA, 18 U.S.C. Section 2256 (federal child pornography statutes), the PROTECT Our Children Act, and equivalent EU Directive 2011/93/EU on combating sexual abuse and exploitation of children. The National Center for Missing and Exploited Children (NCMEC) and the FBI's Crimes Against Children unit are relevant enforcement authorities. Technology platforms have mandatory reporting obligations under 18 U.S.C. Section 2258A when they become aware of child sexual abuse material on their services. 2. GOVERNANCE EXPOSURE: High. This prohibition creates a zero-tolerance compliance obligation for all API operators. Any operator deploying a product that could generate such content without adequate safeguards faces not only contract termination but potential criminal liability and mandatory reporting obligations. The absence of a carve-out or operator override confirms this is an absolute restriction. 3. JURISDICTION FLAGS: This obligation applies globally. All major jurisdictions criminalize child sexual abuse material. EU operators face additional obligations under the proposed EU Child Sexual Abuse Regulation (CSAR). US operators have federal mandatory reporting obligations regardless of state law. 4. CONTRACT AND VENDOR IMPLICATIONS: API operators must ensure their content moderation infrastructure specifically filters for CSAM generation attempts. Procurement teams evaluating OpenAI integrations should confirm that safety filters are active and cannot be disabled by operators. Vendor assessments should include review of OpenAI's model safety documentation referenced at https://openai.com/safety/. 5. COMPLIANCE CONSIDERATIONS: Compliance teams should ensure incident response plans include a NCMEC CyberTipline reporting procedure. Content moderation audits should specifically test for CSAM generation attempts across all model deployments. Developer agreements should explicitly replicate this prohibition in downstream user terms.
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This prohibition applies to all users and operators without exception and represents an absolute restriction with no operator override capability, meaning no business or personal use case authorizes this content.
Any user or developer who generates or facilitates the generation of child sexual abuse material using OpenAI services is in direct violation of this policy and subject to immediate account termination, as well as potential criminal referral under applicable law.
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