UK Online Safety Act: Ofcom publishes illegal content enforcement guidance

The UK communications regulator Ofcom has published final enforcement guidance under the Online Safety Act requiring platforms to prevent children from encountering illegal content including child sexual abuse material, with duties taking effect from early 2025. The guidance sets out how Ofcom will assess compliance, the evidence it will consider, and the penalties available for failure to implement age-appropriate protections, with fines reaching up to ten per cent of qualifying worldwide revenue.

Detection at the point of contact addresses the regulatory obligation more directly than access restrictions alone. Where blanket measures rely on upstream identity verification that imposes privacy costs on all users and may displace harmful contact to less visible channels, real-time monitoring of message exchanges for grooming, sextortion and child sexual abuse material—including AI-generated content—intercepts the threat as it emerges, surfaces the child at immediate risk, and creates an auditable record for platform compliance and enforcement escalation.