Legal challenges in tackling AI-generated CSAM across the UK, USA, Canada, Australia and New Zealand: Who is accountable according to the law?

This study is among the first to examine the regulatory context of five closely inter-connected countries (UK, USA, Canada, Australia and New Zealand) in terms of accountability around child sexual abuse material (CSAM) created via generative artificial intelligence (gen-AI). The findings of our legislative review have helped us identify the key strengths as well as weaknesses of the legislative contexts studied. These countries were selected due to their democratic political systems, technological advances and progressive legislative systems. We examined 29 pieces of legislation and 25 cases for the UK context; 27 pieces of legislation in Australia and New Zealand, together with 4 emerging cases; as well as 279 statutes, 52 pieces of pending legislation and 65 cases in the US and Canada.