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Yesterday we published an update on online safety developments, but
there’s more to say as the announcements just keep coming.

Protecting women and girls

Ofcom has said that it will be fast-tracking its decision on
proposed new requirements for tech firms to use technology to block
illegal intimate images at source. Last year, it consulted on a range of additional online
protections designed to push tech platforms to go further in
tackling illegal content online. As part of these measures, it
proposed a new requirement for sites and apps to use a proactive
technology – known as “hash matching” – to
detect intimate images that are shared without consent, such as
explicit deepfakes.

Ofcom says that due to the urgent need for better online
protections for women and girls, who are disproportionately
affected by non-consensual intimate image abuse, it has decided to
accelerate its timeline. In May, it will announce its final
decision on its proposals that tech firms should expand their use
of proactive technology to prevent illegal intimate images from
reaching users. Subject to the parliamentary process, Ofcom would
expect any new Illegal Harms Code measures to come into effect by
the summer.

Its decisions on the remaining additional protections, which
include proposed new protocols for tech firms to respond to spikes
in illegal content during a crisis, will follow this autumn, as
planned.

Update on investigations – big fines for lack of age
checks!

Ofcom has fined porn company 8579 LLC £1.35
million for not having age checks in place, plus £50,000 for
failing to respond to an information request. 8579 LLC must
immediately implement highly effective age assurance or face a
daily penalty of £1,000.

It has also fined Kick Online Entertainment SA
£800,000 for failing to put in place age checks to protect
children from pornographic content plus £30,000 for failing
to comply with an information request.

Provisional notices of contravention issued

Ofcom has also issued 4chan Community Support LLC with a
provisional notice of contravention. It says there are reasonable
grounds for believing that it has contravened its duties under
section 9, 10 and 12 of the Online Safety Act, especially its duty
to conduct a suitable and sufficient illegal content risk
assessment, its duties in relation to its Terms of Service; and its
duty to protect children from encountering pornographic content
through the use of highly effective age assurance. Ofcom will
provide updates on the investigation in due course.

Ofcom has also issued the provider of the Im.ge service with a
provisional notice of contravention again because it believes that
it has not carried out a suitable and sufficient illegal content
risk assessment. Ofcom’s investigation continues to examine
whether there are reasonable grounds to believe that the provider
of Im.ge has failed, or is failing, to comply with its duty to
protect users from illegal content. It will update in due
course.

It is closing its investigation into the provider of Nippybox.
The service has become unavailable to UK users and, to Ofcom’s
knowledge, more widely. Having assessed the impact on UK users, it
has decided to close the investigation. Ofcom may decide to re-open
its investigation if appropriate.

What can we learn from the investigations so far?

The Online Safety Network has now published a tracker document for Ofcom’s
investigations, It has also written a blog post about the emerging themes and says
that it does not think that Ofcom has sufficient resources. It also
notes that Ofcom has largely been investigating smaller platforms
but isn’t shying away from investigating platforms based
outside the UK. It also says “there have been some crisis
points already which raise questions not just about whether Ofcom
will choose to act, but also about the circumstances in which it
can act”. The Act is not for crises but for making the system
as a whole operate well.

The investigations also make clear that it is crucial that
organisations carry out risk assessments, respond to information
requests promptly and fully, and make sure that they have robust
age gating in place where appropriate.

Ofcom publishes final guidance for the online safety
super-complaints regime

The super-complaints regime came into force on 31 December 2025
and enables eligible organisations to bring systemic issues to
Ofcom’s attention about features of regulated online services,
or conduct of those services, that may lead to material risk of
significant online harm or adverse impact on the right to freedom
of expression. The legislation sets out criteria which decide which
organisations are eligible to make a complaint and how Ofcom will
decide if a complaint is admissible under the Online Safety Act. In
summary, an organisation must demonstrate that it represents people
in the UK. This can be people who use regulated online services,
the public or a specific group of people. An eligible organisation
must also be able to be relied on to act independently of regulated
online services, routinely contribute significantly, as an expert,
to public discussions about any aspect of online safety matters and
must be relied on to have regard to Ofcom’s guidance about
making super-complaints. Ofcom has now published its final guidance for organisations wishing to
submit a super-complaint.

The content of this article is intended to provide a general
guide to the subject matter. Specialist advice should be sought
about your specific circumstances.