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Law / Finland

Rikoslaki Chapter 20, Distribution and Possession of an Image Depicting a Child Sexually, Including Realistic Depictions

Rikoslaki (39/1889) 20 luku 19-21 sec, as amended by 8.7.2022/723

In force since .

An AI prohibited practices rule binding public and private bodies.

Obligation class
Prohibition
Audit expectation
none
Setting the rule reaches
General

What it requires

  • Do not manufacture, offer or otherwise distribute an image depicting a child sexually, including a realistic image that deceptively resembles a photograph of a child depicted sexually even though no real child was involved; the test is whether the image deceptively resembles a photograph, so a wholly AI-generated or synthetically altered image can fall within it (Section 19).
  • Do not possess such an image, or pay for or otherwise arrange access to it (Section 21).
  • A narrow exception excuses production or distribution justified by the image's informational character or its evident artistic value (Section 19).

These lines are LexLint's reading of the law's text.

In the frameworks

NIST AI RMF
  • MAP 3.3Targeted application scope is specified and documented based on the system’s capability, established context, and AI system categorization.
NIST AI 600-1
MIT mitigations Draft
  • 1.5Safety Decision Frameworks
  • 3.3Access Management
FINOS AIGF
ETSI EN 304 223
  • 5.1.2-1Business need and security risks written down and assessed before deciding to build an AI system.
  • 5.1.4-5End-users told which uses of the system are prohibited.

Our reading of where this law's duties sit in each framework. It never says that running a control meets the law. How we read a framework against the law

Identifiers refer to ETSI EN 304 223 V2.1.1 (2025-12), © ETSI 2025, all rights reserved. ETSI owns the standard; no ETSI text (titles or sentences) is reproduced here. The standard is free to download from ETSI.

If you get it wrong

Criminal exposureYes

Criminal exposure note

Distribution (Section 19): fine or imprisonment for at most two years. Aggravated distribution (Section 20), where the depicted child is especially young, the image also shows serious violence or especially humiliating treatment of the child, the offense is committed in a particularly systematic manner, or as part of an organized criminal group, and the offense is also aggravated when assessed as a whole: imprisonment for at least four months and at most six years. Possession, or paying or otherwise arranging access to such an image (Section 21): fine or imprisonment for at most two years.

Who enforces it

Enforcement body

Ordinary Finnish criminal courts, on public prosecution.

Settledness

As of
Open questions
  • Does 'todenmukainen' (realistic) in the fourth paragraph of Section 19, which asks whether the image 'erehdyttävästi muistuttaa valokuvaamalla tai muulla vastaavalla menetelmällä valmistettua kuvaa' (deceptively resembles an image made by photography or a similar method), reach a wholly synthetic image produced by a generative model with no real child behind it, and does it reach a stylized or animated image?
  • Does the exception in the third paragraph of Section 19 for an image whose production or distribution is justified by 'tiedonvälitystä palvelevan luonteen' (its character of serving the communication of information) cover a developer who makes or keeps such images to train or test a detection system?

What it makes you log

Logging duty

Sections 19 to 21 of chapter 20 are a criminal prohibition on making, offering, distributing or possessing an image that depicts a child sexually, or arranging access to one, where the image is based on a real situation or is realistic, meaning it deceptively resembles a photograph. None of the three sections states a duty to create, keep or produce a log or record of any kind.

Kind
None
As of

What this law does

Drafted with AI

Drafted with AI from the cited sources under the direction of UnGovr staff. UnGovr holds editorial responsibility for this page. How this site is made

Research summary

Legal information, not legal advice. This is LexLint's own research summary of a public legal source, and it creates no attorney-client relationship. For decisions that matter, consult qualified counsel in the relevant jurisdiction. About LexLint

Section 19 bans manufacturing, offering, or otherwise distributing an image depicting a child sexually where the image is based on an actual situation involving a real child, or where the image is realistic, meaning it deceptively resembles a photograph of a situation in which a child is depicted sexually even though no real child was involved, by a fine or imprisonment for at most two years; because the realistic-depiction branch asks whether the image deceptively resembles a photograph, not how it was made, a wholly AI-generated or synthetically altered image can fall within it.

Section 20 raises the penalty to imprisonment for at least four months and at most six years for an aggravated case, including where the depicted child is especially young or the image also shows serious violence against the child. Section 21 separately punishes possessing such an image, or paying or otherwise arranging access to it, by a fine or imprisonment for at most two years.

A narrow exception in Section 19 excuses production or distribution that is justified by the image's informational character or its evident artistic value.

When LexLint raises it

When your app profile says your app generates images with AI, generates video with AI or publishes adult content.

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