Irish DPC opens an inquiry into X over sexualised images generated with Grok, children included
Irish DPC took investigation action against X Internet Unlimited Company (XIUC) over Grok image generation inside the X platform, announced 17 February 2026. No financial penalty was imposed. Status: confirmed.
The record
Key facts
- Record ID
- AIT-2026-0004
- Status
- Confirmed
- Action type
- Investigation
- Regime
- GDPR
- Authority
- Data Protection Commission
- Jurisdiction
- Ireland
- Target
- X Internet Unlimited Company (XIUC), headquartered in Ireland
- Sector
- Generative AI
- AI system
- Grok image generation inside the X platform
- Date announced
- Date of decision
- Amount
- No financial penalty
- Appeal
- None recorded. Not applicable while the inquiry is open.
- Last verified
In full
What happened, and why it matters
The Irish Data Protection Commission, lead supervisory authority for X across the EU and EEA, opened a statutory inquiry under section 110 of the Data Protection Act 2018 into the creation and publication on X of non consensual intimate and sexualised images of people in the EU and EEA, children among them, made with the generative functionality of the Grok model inside the platform. The inquiry asks whether X complied with the GDPR's processing principles, its lawfulness requirement, data protection by design and by default, and the duty to carry out a data protection impact assessment. It is the third open proceeding against the same company on this tracker and the second about Grok: the Commission had extended its Digital Services Act proceedings to Grok three weeks earlier, and the DPC's own inquiry into training Grok on European users' posts has been open since April 2025. Together they show the pattern the AI Act's own transparency article will meet in practice: a generative feature inside a platform is reached first under the GDPR and the DSA, by authorities that already have jurisdiction, before any AI Act authority is involved. No finding has been made and no fine imposed.
At a glance
The four things to take away
- Inquiry notified to X on 16 February 2026 and announced on 17 February 2026.
- Legal basis: section 110 of Ireland's Data Protection Act 2018; the DPC is lead supervisory authority for XIUC under the one stop shop.
- Subject: non consensual intimate and sexualised images of EU and EEA data subjects, including children, generated with Grok on X.
- GDPR provisions under examination: Articles 5, 6, 25 and 35.
- No finding of infringement and no fine as of 14 September 2026.
The law
Provisions this action rests on
- GDPR Article 5cited
- GDPR Article 6cited
- GDPR Article 25cited
- GDPR Article 35cited
- AI Act Article 50adjacent
Read the official text of Article 50 in the EU AI Act Explorer, consolidated with the Digital Omnibus applied.
How it moved
Timeline
Commission extends its DSA proceedings against X to cover Grok
DPC notifies X of the inquiry
DPC announces the inquiry
Verification
Sources
Primary sources are the authority's own decision or press release, the Official Journal, or a court judgment. A record with no source is not published.
- Data Protection Commission, Data Protection Commission opens investigation into X (XIUC)Primary · 17 February 2026
Next
Related enforcement actions
- ConfirmedAI adjacentAIT-2026-0001
Commission extends its DSA proceedings against X to cover Grok
26 January 2026 · Investigation · DSA · No financial penalty
Formal proceedings extended on 26 January 2026, Commission press release IP/26/203.
- ConfirmedAI adjacentAIT-2025-0002
Irish DPC opens a full inquiry into X over training Grok on European users' posts
11 April 2025 · Investigation · GDPR · No financial penalty
Statutory inquiry announced 11 April 2025 under section 110 of the Data Protection Act 2018.
- ConfirmedAI adjacentAIT-2024-0005
Irish DPC takes X to the High Court over Grok training data and secures an undertaking
4 September 2024 · Interim measure · GDPR · No financial penalty
High Court proceedings issued 8 August 2024 under the urgency power in section 134.
- ConfirmedAI adjacentAIT-2025-0001
Garante blocks DeepSeek in Italy over transfers to China and missing information
30 January 2025 · Ban · GDPR · No financial penalty
Urgent definitive limitation on processing, adopted 30 January 2025.
- AnnulledAI adjacentAIT-2024-0007
Garante fines OpenAI 15 million euro, and the Court of Rome annuls the decision in full
2 November 2024 · Fine · GDPR · 15 million euro
Fine of 15 million euro plus a media campaign order, decision 2 November 2024, announced 20 December 2024.
- ConfirmedAI adjacentAIT-2024-0004
Irish DPC opens a cross border inquiry into Google over the PaLM 2 model
12 September 2024 · Investigation · GDPR · No financial penalty
Statutory inquiry announced 12 September 2024 under section 110 of the Irish Data Protection Act 2018.
Cite this record
Free to reuse under CC BY 4.0, with attribution. The record ID AIT-2026-0004 is permanent and is never reused.
- In a sentence
- According to the GAGE EU AI Act Enforcement Tracker (as of 14 September 2026), irish dpc opens an inquiry into x over sexualised images generated with grok, children included.
- APA
- GAGE (Global Academy of Generative-AI Education). (2026). Irish DPC opens an inquiry into X over sexualised images generated with Grok, children included. EU AI Act Enforcement Tracker. Retrieved 14 September 2026, from https://www.gage.academy/tools/eu-ai-act-enforcement-tracker/actions/AIT-2026-0004-dpc-x-grok-sexualised-images-inquiry
- MLA
- "Irish DPC opens an inquiry into X over sexualised images generated with Grok, children included." EU AI Act Enforcement Tracker, GAGE (Global Academy of Generative-AI Education), 14 September 2026, https://www.gage.academy/tools/eu-ai-act-enforcement-tracker/actions/AIT-2026-0004-dpc-x-grok-sexualised-images-inquiry.
- Chicago
- GAGE (Global Academy of Generative-AI Education). "Irish DPC opens an inquiry into X over sexualised images generated with Grok, children included." EU AI Act Enforcement Tracker. Last modified 14 September 2026. https://www.gage.academy/tools/eu-ai-act-enforcement-tracker/actions/AIT-2026-0004-dpc-x-grok-sexualised-images-inquiry.
- Permalink
- https://www.gage.academy/tools/eu-ai-act-enforcement-tracker/actions/AIT-2026-0004-dpc-x-grok-sexualised-images-inquiry
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