CHICAGO — Earlier this year, administrators at Lake Zurich High School confronted a growing challenge facing schools nationwide: students using artificial intelligence to create sexually explicit images of their classmates. After reporting the matter to police, the district launched a series of student and family education efforts focused on online safety and responsible technology use.

The incident illustrates the kinds of situations Illinois lawmakers may have had in mind when they passed a bill last year requiring schools to address AI-generated content in their bullying prevention policies. Beginning July 1, the state’s definition of cyberbullying was expanded to include AI-generated digital replicas, forcing districts across Illinois to update policies and procedures.

Also by July 1, the Illinois State Board of Education was required to develop statewide guidance on artificial intelligence in schools. The guidance is expected to address AI-generated false representations of individuals to help districts update their policies ahead of the 2026-27 school year.

ISBE press secretary Lindsay Record said that while the agency is still developing guidance, “it remains the case that local policies, procedures and responses to specific incidents are determined at the district and school level.”

In Lake Zurich for the coming school year, officials expect to build on the guidance provided following the earlier incident.

“The district anticipates continued integration of explicit teaching opportunities for all students regarding safe, responsible technology usage — in alignment with core district values,” Jean Malek, executive director of communications for Lake Zurich Community Unity School District 95, told the Medill Illinois News Bureau in an email.

“Additionally, the district anticipates continued information and resource-sharing with families on how to best support safe technology usage.”

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Even though schools already have policies to address bullying, the new law provides important clarification by naming unauthorized AI-generated digital replicas as a newer form of harm, said Scott Rowe, superintendent of Township High School District 214.

“The message is clear,” Rowe said. “AI does not remove responsibility.”

The law, he said, will give districts clearer language for policies, student expectations and family conversations.

The school-focused legislation doesn’t change Illinois’ criminal statutes governing AI-generated sexual imagery. Under state law, AI-generated sexual images that appear to depict minors may be prosecuted under child pornography and related obscenity statutes. Depending on the circumstances, creating, possessing or distributing such images can result in felony charges.

The issue is not isolated: A 2024 survey by the Center for Democracy & Technology found that 40% of K-12 public school students were aware of a deepfake involving someone at their school, including 15% who knew of a sexually explicit deepfake depicting a member of their school community.

The survey also found that many schools had not proactively addressed the issue, with more than 60% of teachers reporting their school had not shared policies or procedures related to AI-generated sexual imagery.

Laura Tierney, founder of The Social Institute, a company that provides schools with digital literacy resources, said Illinois is taking a step in the right direction by acknowledging that educators have a role to play alongside law enforcement in addressing harmful AI-generated content.

“Legislation alone won’t solve the spread of this. With legislation has to come education on the topic, and Illinois schools now have a legal obligation to address AI-generated cyberbullying,” Tierney said. “And so now I think the question is whether they have the curriculum and the tools to back this policy up.”

Tierney said most students are well aware that deepfakes are hurtful but might not fully understand how to support their friends if they see images circulating online.

“I think this is an opportunity to coach towards the positives rather than solely scare students with the negatives,” Tierney said. “It’s old school to focus on how harmful it is, like, ‘here’s all the legal implications.’ The reality is that it’s still going to happen. So how can we help students make positive choices?”

Rowe said the biggest challenges for schools when responding to incidents involving AI-generated content are speed, realism and reach: Images can spread quickly and students may not know whether or not they are fake.

“AI-generated content may be artificial, but the harm it causes can be very real,” Rowe said.

Rowe added that students do not have to create the original content to contribute to the harm. Sharing or forwarding it can extend the damage and may result in school consequences and, in some cases, legal consequences, he said.

“Anything related to AI — it’s a bit of a game of Whac-A-Mole, just because the technology is evolving very quickly,” said Debra Jacobson, general counsel of the Illinois Association of School Boards. “Kids are often way ahead on technology and what they’re doing with it so that can contribute to the challenge. I don’t think that’s anything necessarily new, but I think the trend has just been accelerating.”

Naomi Taxay is an undergraduate student in journalism with Northwestern University’s Medill School of Journalism, Media, Integrated Marketing Communications, and a fellow in its Medill Illinois News Bureau working in partnership with Capitol News Illinois.

Capitol News Illinois is a nonprofit, nonpartisan news service that distributes state government coverage to hundreds of news outlets statewide. It is funded primarily by the Illinois Press Foundation and the Robert R. McCormick Foundation.