▢ POLICY & LAW 1 MONTH HORIZON RESOLVES 1 DEC 2026 · in 30d

EU AI Act prohibitions on systems generating non-consensual intimate imagery and CSAM take effect on December 2, 2026.

Under the EU AI Act staggered implementation, explicit bans on AI systems designed to generate non-consensual intimate images or child sexual abuse material are scheduled for December 2026.

Across 6 frontier models answering independently, the panel has all but ruled it out: the median is 6%.

They do not agree: DeepSeek puts it at 88% and Gemini at 2%, 86 points apart. A spread that wide usually means the question turns on something none of them can see yet.

Nothing is settled until 1 Dec 2026, when the outcome is checked against sources and every number above gets a permanent score.

MODEL BY MODEL

What each one said

  • DeepSeekDeepSeek

    The AI Act's Article 5 prohibitions already exist in law; this is about whether the Dec 2, 2026 date slips.

    • Article 5(1)(ba) and (bb) were added by the May 2025 Digital Omnibus-era amendments, so the ban text is already in the Official Journal, not pending.
    • The Commission has no pending proposal to delay the Article 5 applicability date; the Digital Omnibus (Nov 2025) targets high-risk rules in 2026-2027, not these…
    • Precedent: the Feb 2, 2025 prohibitions took effect on schedule despite lobbying, so slippage risk here is low but nonzero given omnibus momentum.
    deepseek/deepseek-v4.1-flash · asked 1 Nov 2026
    88%
  • ClaudeAnthropic

    The AI Act's Article 5 bans took effect Feb 2025, not Dec 2026; this date doesn't match actual legal schedule.

    • Article 5 prohibited practices (including CSAM/manipulation bans) entered into force 2 February 2025, six months after entry into force.
    • December 2026 corresponds to obligations for high-risk AI systems under Annex III, not prohibited practices under Article 5.
    • Unless the statement is referring to some newly delayed or amended provision, this specific framing appears factually mismatched with the Act's actual timeline.
    anthropic/claude-sonnet-5 · asked 1 Nov 2026
    9%
  • QwenAlibaba

    The EU AI Act has no December 2, 2026 milestone; Article 5 prohibitions already applied Feb 2, 2025, and no NCII/CSAM-specific ban exists at that date.

    • The Act's staggered dates are Feb 2 2025, Aug 2 2025, Aug 2 2026, and Aug 2 2027—no December 2026 trigger exists in the regulation text.
    • NCII and CSAM generation are already criminalized under Directive 2011/93/EU and national laws; the AI Act's Article 5 prohibitions don't single them out as a separate…
    • A delegated or implementing act could theoretically create a new date, but the Commission has shown no movement toward a Dec 2026 NCII/CSAM-specific AI prohibition.
    qwen/qwen3.8-max-0902 · asked 1 Nov 2026
    6%
  • GPTOpenAI

    The stated effective date is almost certainly wrong: the AI Act’s December 2026 milestone is on the 2nd, after the deadline.

    • Article 113 puts the broad high-risk AI rules into application on 2 August 2026, while prohibited-practice rules applied on 2 February 2025.
    • The relevant wording is not a standalone December 2026 prohibition; EU lawmakers would need to amend Regulation (EU) 2024/1689 to create it.
    • A last-minute corrigendum or emergency amendment moving a new ban to 1 December 2026 would sharply raise the odds, but that is atypical.
    openai/gpt-5.6-terra · asked 1 Nov 2026
    5%
  • GrokxAI

    Article 5 bans already apply from 2 Feb 2025; no Dec 2026 trigger exists.

    • The AI Act’s prohibited-practices chapter (Art. 5), covering CSAM and non-consensual intimate-image generators, became applicable six months after entry into force.
    • Staggered dates are 2 Feb 2025, 2 Aug 2025, 2 Aug 2026 and 2 Aug 2027; December 2 appears nowhere in the text or later amendments.
    • A last-minute legislative change to shift only these two bans to 2 Dec 2026 is vanishingly unlikely one month out.
    x-ai/grok-4.6 · asked 1 Nov 2026
    3%
  • GeminiGoogle

    Prohibitions under the EU AI Act took effect in February 2025, leaving no scheduled December 2, 2026 prohibition milestone.

    • Article 111 dictates prohibited AI practices applied 6 months post-entry into force, on February 2, 2025, not late 2026.
    • The 24-month general application date is August 2, 2026, making a December 2, 2026 effective date legally non-existent.
    • Resolving on December 1, 2026 mathematically precedes the December 2 date specified in the proposition anyway.
    google/gemini-3.8-flash · asked 1 Nov 2026
    2%

6 of 6 models answered · 86 points between the highest and lowest. None was shown the market price.

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Question sourced from a news sweep on 1 Nov 2026. Forecast by google/gemini-3.8-flash, anthropic/claude-sonnet-5, openai/gpt-5.6-terra, x-ai/grok-4.6, deepseek/deepseek-v4.1-flash, qwen/qwen3.8-max-0902 via OpenRouter.