An Encouraging Start – Response to Ofcom’s Latest Research on the Online Safety Act

SWGfL welcomes Ofcom’s publication of its latest research on the early impact of the Online Safety Act (OSA). After more than two decades in which online platforms have operated with limited regulation or accountability, it is encouraging to see evidence that long-awaited protections are beginning to take shape. Ofcom’s findings show that the first wave of implementation is making a difference, and we recognise the significant work undertaken so far to build the foundations of a safer online environment.

However, while these developments are promising, we recognise that more is needed before the Act can deliver the consistent, meaningful protection that UK users deserve. Early progress is welcome, effective enforcement and continued implementation will be what determines the Act’s long-term success.

Encouraging Results, With Hopefully More to Come

We welcome the positive signs highlighted in Ofcom’s research. It is encouraging that:

• 58% of parents believe Ofcom’s code measures are already improving children’s safety.
• 67% believe these measures will make a difference in the future.
• 36% have already noticed a positive impact on their child’s online experience.

This shows that families are beginning to feel the benefits of a more robust regulatory landscape. We also acknowledge Ofcom’s early enforcement efforts, including investigations into 92 online services, fines issued to three providers, and actions that have limited access to high-risk sites from UK IP addresses. These are important early steps that set the tone for more comprehensive enforcement as further regulations come into force.

What More Needs to Be Done?

Ofcom’s research identifies meaningful improvements underway:

• Age assurance: Over half of the top 100 adult sites now have age checks in place, with children’s encounters with such checks rising from 30% to 47%.
• CSAM and grooming: More platforms are deploying hash-matching technologies and safer design measures.
• Hate, terrorism, and fraud: Ofcom has begun compliance work assessing platforms’ systems for removing harmful content and strengthening fraud reporting.

These are positive developments, and we appreciate that further regulatory codes and enforcement powers are still rolling out. Continued implementation will undoubtedly strengthen the regime. Even so, several crucial elements are not yet reflected in current outcomes. For the OSA to reach its full potential, the following are essential:

1. More proactive behaviour from platforms - Platforms must prevent foreseeable harms rather than waiting to act after they occur. Current progress, while improving, remains too slow.
2. Strong, decisive enforcement from Ofcom - As Ofcom’s responsibilities expand, consistent and assertive enforcement will be key to ensuring rapid compliance, especially for harms like NCII, where delays have devastating consequences.
3. Stronger NCII protections embedded into the regime – Ahead of the public progress report in 2027 on how platforms have been tackling NCII. We reiterate our core asks:
   • Preventing sharing of NCII
   • Mandatory, rapid takedown of NCII content
   • Blocking access to NCII content
   • Clear, enforceable duties requiring platforms to act
4. Full integration of safer-by-design principles - Safety features should be built into platforms’ design and functionality from the outset, not added reactively.

Still Some Way to Go

While the foundations are being laid and further implementation is expected, the Act has not yet achieved the level of protection, consistency, or accountability that users deserve. The research shows progress, but several high-harm areas remain inadequately addressed.

To avoid replicating issues seen in other jurisdictions, where ambitious policy goals were weakened by slow enforcement or gaps in legislation, the OSA must continue evolving. This requires:

• Enhanced enforcement: Investigations and remediation are positive, but there must be clear, timely consequences for non-compliance.
• The Government to strengthen the law: Particularly around NCII, where protections remain too limited.
• Regulatory agility: As the digital environment evolves rapidly, Ofcom must be equipped to keep pace.
• Clear routes to user redress: At present, individuals have no formal mechanism to challenge platform decisions when harm occurs.

Ofcom’s research confirms that early progress is visible, and many families are beginning to feel safer online. SWGfL welcomes this direction of travel and recognises that further implementation of the OSA will continue to strengthen protections over time. However, the momentum must not slow: robust enforcement, strong NCII safeguards, safer-by-design principles, and clear redress mechanisms are essential to ensure the Act delivers on its promise.

We will continue to advocate for a regulatory environment in which platforms consistently put the wellbeing of users above commercial interests.