UK Online Safety Act: Ofcom publishes illegal content enforcement guidance

The UK communications regulator Ofcom released detailed guidance on 26 August 2024 setting out how it will enforce the illegal content provisions of the Online Safety Act, including duties to prevent children from encountering child sexual abuse material, and how platforms must assess and mitigate risks of illegal content including CSAM and abuse. The framework establishes information-gathering powers, fines up to ten percent of global turnover for non-compliance, and a graduated enforcement approach beginning with provisional notices of contravention before escalating to penalty and business-disruption measures.

Enforcement frameworks that rely on platform content-moderation at scale face the challenge that harmful contact often unfolds in private direct messages where centralised review is slow and reactive. Detection systems that identify coercive escalation, sexual solicitation and image-based abuse in real time in childrens messaging streams across Instagram, Snapchat, Discord and Roblox enable platforms to interrupt harm at the point of contact rather than after a child has been exploited, addressing the underlying duty to protect without requiring human review of every private conversation.