Itai Tech - a UK-based company - is being investigated over "nudify" software.
IMHO, "nudify" software is deplorable because it is aimed at, and result in, the generation of non-consensual nude imagery of the victim.
Whether or not the user is 18 or over shouldn't come into it, IMHO, but the investigation is about Part 5 compliance.
Whether the output is "pornographic content" - perhaps the distinction between nudity and pornography - under the OSA is an untested area.