EU AI Act for Adult Creators: Deepfakes, Labels, and the DSA

Why EU Rules Matter Even If You’re Not in the EU

Targeting EU users, platforms headquartered in EU, hosting in EU

Whether you’re an indie adult creator in Australia or run a custom vids store from the US, if your content is shown to users in the EU—or appears on EU-based platforms—you may be affected by the new EU AI Act and the Digital Services Act (DSA).

You don’t need to live in Europe to feel the impact:

• If your leaked content appears on a platform like xHamster or VK (headquartered or active in the EU)
• If your distribution site or tube mirror host is in an EU country
• If EU users are the ones accessing or uploading manipulated content using your face or name

That means understanding these rules isn’t optional—it can help protect your identity and content rights across borders.

EU AI Act — What’s Relevant to Adult Creators

Deepfake transparency duties (when/where labels apply)

The EU AI Act requires that media using AI to generate or manipulate lifelike visuals—especially of people—be labeled clearly and in context. That includes:

• AI-generated voiceovers impersonating your voice
• Deepfake porn using your likeness or face without consent
• Altered clips from your real content placed into unreal scenes

If your likeness is used in these ways, platforms in the EU are expected to require transparency labels—and remove or flag material that violates these rules. You can request labeling or takedown using tailored language (see template below).

Face recognition and biometric restrictions (impacts on scraping sites)

The Act also restricts the use of biometric data, like face recognition, especially when used without consent. That puts pressure on search engines and facial-recognition-based leak sites that scrape adult content.

Under the AI Act’s biometric provisions, platforms may be forced to limit or reduce these scraping tools—giving adult creators a new tool to request removals or blocks based on privacy violations, not just copyright.

What to include in takedown notices referencing AI content

When including AI concerns in your takedown notice, be specific. Here’s what helps:

• State that the image/video is an unauthorized AI-generated or “deepfake” manipulation
• Mention lack of consent and EU AI Act Article 52 requirements for transparency
• Highlight risk of reputational harm, non-consensual depiction, or identity misuse

The DSA: Faster Takedowns via “Trusted Flaggers” and Notice-and-Action

Platform obligations; what “manifestly illegal” means in practice

The Digital Services Act (DSA) introduced major obligations for platforms hosting user content. That includes:

• Faster removals of manifestly illegal content
• Reply obligations—platforms must explain if they reject your notice
• Special privileges for “trusted flaggers” to fast-track notices

“Manifestly illegal” covers material that is clearly non-consensual, harassing, impersonating, or violates copyright. A strong notice, especially from a verified entity like a trusted takedown provider, carries more weight.

How to file a high-quality notice that gets prioritized

To be processed under the EU’s notice-and-action rules, your submission must:

• Identify the specific URL and content in question
• Explain clearly which law or rule is violated (copyright, impersonation, AI Act etc.)
• Include your legal name and contact information (or a verified agent)

Platforms must provide a confirmation of receipt and decision explanation, improving transparency. If ignored, you may qualify for out-of-court resolution options (more below).

Platform Playbook (EU-Facing)

Filing portals to use; data you must include

Most major EU-facing platforms now provide dedicated submission portals for takedowns to comply with the DSA. You’ll typically need to provide:

• Exact URL of the content
• Brief explanation of illegality (1–2 sentences)
• Your legal name or authorized agent’s contact

Some sites may ask you to choose a category like “NCP” (non-consensual pornography), impersonation, or illegal AI content. Be precise. Save evidence (screenshots, URLs) before the content is removed.

Run a free leak scan to identify EU-hosted duplicates or how your face may be used in altered content.

Appeals, internal review, and out-of-court dispute options

Under the DSA, you have:

• The right to appeal internally if a takedown request is denied
• Access to an independent out-of-court dispute body (coming online in 2024–2025)

Consider appealing if the platform claims the content is “parody” or doesn’t violate terms. Be documented and professional; template language can help (see below).

Templates and Checklists

DSA-compliant notice template

This is a formal notice under Article 16 of the EU Digital Services Act.

URL of illegal content: [Insert Full URL]

Description: This video/image uses my likeness without consent. It is either a non-consensual deepfake or real content redistributed illegally. It violates your terms and possibly the EU AI Act’s transparency obligations.

Reason for illegality: Violation of rights under GDPR, copyright infringement, and impersonation. May qualify as "manifestly illegal content."

Full name: [Your Legal Name or Agent]

Contact: [Email address]

Location: [Optional if outside EU—if included, note country]

Deepfake labeling request language

To compliance/team:

This content appears to use AI to simulate my appearance. Under Article 52 of the EU AI Act, audiovisual deepfakes must include transparency disclosures and user warnings. I request the video be labeled accordingly, or removed if non-compliant.

Regards,
[Name/Agency/Platform Handle]

Risks, Penalties and What Creators Should Avoid

The EU is taking enforcement seriously. Large platforms (aka Very Large Online Platforms or VLOPs) can face fines of up to 6% of global revenue for systemic violations—but creators must act responsibly, too.

What to avoid:

• False claims of content being deepfaked—stick to facts and known uses
• Automated takedown spam—use strong, individual cases
• Multiple notices from fake names—platforms check for this under the DSA

When in doubt, get help from a takedown provider experienced in cross-border enforcement.

Summary checklist:

• ✔ Confirm if content is hosted on/visible to EU users
• ✔ Identify if AI/manipulated elements are involved
• ✔ Use the DSA-compliant notice template above
• ✔ Save all submission screenshots and URLs
• ✔ Follow up with appeals or escalate to out-of-court pathways if needed

This article is for informational purposes only and is not legal advice. Enforcement and notice rules differ by jurisdiction and by platform.

Request an EU-compliant takedown packet if you’re dealing with leaks or manipulated content based in the European market.

Get discreet help with takedowns and protect your brand across borders. We’re here to help you stay protected and visible — on your terms.