The UK Online Safety Act, enforced from early 2025, mandates digital platforms to implement robust content moderation systems to protect users from illegal and harmful content. This isn't optional guidance – it's a legal requirement with significant consequences for non-compliance.
Digital platforms have historically self-regulated their content moderation practices, with mixed results. While major social platforms have faced public scrutiny and improved their practices, illegal content and harassment have found new homes in unexpected places. Gaming chat rooms, marketplace messaging systems, and community features in seemingly low-risk apps have become vectors for harmful content. Even platforms that don't consider themselves "social networks" have discovered their user interaction features being misused for harassment, fraud, or sharing illegal content.
The Online Safety Act changes this fundamentally, recognizing that content moderation isn't just a social media problem, it's crucial wherever users can interact. The Act introduces strict requirements for how platforms must protect their users from illegal and harmful content, regardless of whether content sharing is their primary function. Understanding and implementing these requirements is now a business-critical priority, especially for platforms that may have previously considered content moderation a secondary concern.
Does this affect your platform?
Your platform falls under this Act if you provide any service that:
Allows users to post, share, or exchange content that other users can access.
Includes file-sharing or media-uploading capabilities.
Contains user-generated content, such as messages, comments, or posts.
Has users in the UK (regardless of where your company is based)
Enable any form of user-to-user interaction like direct messaging between users, public/private chat rooms, discussion forums or content search features and user profile searches
Even if these features are just a small part of your platform, you're still required to comply. Many platforms are discovering they fall under the Act's scope due to features they hadn't considered high-risk, such as customer-to-seller messaging in marketplaces or comment sections on service booking platforms.
Size-based requirements and obligations
The Act recognizes that platforms of different sizes have varying resources and risk profiles. This translates into specific differences in implementation requirements:
1. Large services (Category 1: >7M UK users)
Required systems:
Enterprise-grade automated content monitoring
24/7 moderation capability
Advanced user reporting systems
Comprehensive audit trails
Real-time content screening
Specific obligations:
Response time: Within 24 hours for standard reports, 1 hour for high-priority content
Automated pre-screening of all user-generated content
Regular reporting to Ofcom (quarterly)
Dedicated safety personnel
Integration with law enforcement reporting systems
2. Smaller services (Under 7M UK users)
Required systems:
Basic content monitoring capabilities
Standard user reporting mechanisms
Content takedown processes
Record-keeping systems
Specific Obligations:
Response time: Within 48 hours for standard reports, 24 hours for high-priority content
Post-upload content monitoring
Annual reporting requirements
Designated safety contact
Basic law enforcement cooperation procedures
Implementation timeline for compliance
Initial enforcement: March 2025
Functional content moderation systems
User reporting mechanisms
Basic safety features
Initial risk assessments completed
Documentation of current safety measures
Full compliance schedule
Q1 2025 (January - March)
Complete initial risk assessments
Submit assessments (Category 1 services)
Implement basic reporting mechanisms
Set up content monitoring systems
Q2 2025 (April - June)
Complete system implementations
Staff training programs established
Documentation systems operational
Integration with required databases
Q3 2025 (July - September)
Additional safety duties begin
Enhanced monitoring systems active
Full audit capabilities operational
Advanced feature implementation
Q4 2025 (October - December)
Full compliance required
All systems fully operational
Complete reporting capabilities
Comprehensive safety measures in place
Non-compliance consequences:
Financial penalties up to £18M or 10% of global turnover
Service restriction orders
Business disruption notices
Criminal prosecution for senior managers
Mandated system audits
Requirements summary
1. Risk assessment obligations
Risk assessment forms the foundation of your compliance strategy. It's not a one-time exercise but an ongoing process that shapes your platform's safety measures.
Assessment areas:
Types of illegal content likely to appear on your service
Features that could enable illegal content sharing
User behaviors that might lead to illegal activities
Impact on different user groups
Effectiveness of current safety measures
Risk assessment process requirements:
Initial comprehensive assessment
Regular reviews (minimum annually)
Additional assessments when: Making significant platform changes, adding new features, identifying new types of risks and receiving regulatory guidance updates
Documentation requirements:
Written records of assessment methodology
Evidence supporting risk determinations
Action plans for identified risks
Timeline for implementing safety measures
Your risk assessment isn't just paperwork, it's a crucial tool for identifying where your platform needs enhanced protection measures.
2. Content moderation requirements
Content moderation under the Act goes beyond simple content removal. It requires a comprehensive system and specialized tools for detecting, assessing, and acting on potentially illegal content.
Content detection:
Identifying potentially illegal content
Flagging high-risk content for priority review
Processing user reports effectively
Monitoring patterns of harmful behavior
Response capabilities:
Swift content review processes (typically within 24 hours)
Immediate takedown mechanisms for confirmed illegal content
User notification systems
Appeal processes for content decisions
Special category requirements:
CSAM (Child Sexual Abuse Material) detection systems
Integration with recognized hash-matching databases
Automated screening for known illegal content
Priority handling of high-risk content categories
The key is building a moderation system that's both thorough and responsive, capable of addressing content concerns before they escalate.
3. Risk categories and compliance levels
The Online Safety Act takes a risk-based approach to compliance. Your platform's risk level determines your specific obligations and implementation requirements.
Basic risk platforms
Examples:
Educational course platforms with simple discussion boards
Professional networking sites with messaging features
Marketplace apps with basic buyer-seller messaging
Small community forums with limited file sharing
Key requirements:
Standard content monitoring
48-hour response time
Basic user reporting tools
Monthly safety reviews
Medium risk platforms
Examples:
Dating apps with chat features
Gaming platforms with in-game chat
Community platforms with file sharing
Video streaming platforms with comments
Youth-focused forums or communities
Key requirements:
Advanced content screening
24-hour response time
Enhanced reporting systems
Weekly safety reviews
High risk platforms
Examples:
Social media platforms with multiple interaction features
Live streaming apps with chat functionality
Online gaming platforms with voice/video chat
Large community forums with private messaging
Content sharing platforms with direct messaging
Key requirements:
Real-time content monitoring
1-hour response for critical issues
Comprehensive detection systems
Daily safety reviews
Your platform's risk category determines both your compliance requirements and the most effective implementation approach.
While large teams like Reddit or Telegram might invest in building comprehensive in-house systems, many organizations find that partnering with content moderation platforms like CometChat can help them implement appropriate safety measures quickly and efficiently.
For example, a dating app (medium risk) might need specialized detection for inappropriate content, while a marketplace app (basic risk) might focus more on transaction-related safety.
Practical implementation guide
Complying with the Online Safety Act requires both technical systems and organizational structures. Here's how to approach implementation systematically:
Phase 1: Organizational readiness
Establish safety leadership
Designate a Safety Officer responsible for compliance
Create clear reporting lines for safety issues
Define roles and responsibilities for content moderation
Ensure senior management oversight of safety measures
Map current operations
Document all user interaction points (messaging, comments, file sharing)
Review existing safety measures and moderation practices
Identify high-risk areas requiring immediate attention
Assess current response procedures for harmful content
Gap analysis
Compare current capabilities against Act requirements
Evaluate resource needs (staff, technology, training)
Document missing safety features
Identify compliance timeline challenges
Phase 2: Essential safety systems
The Act mandates specific capabilities that combine human oversight with technical solutions:
Content monitoring infrastructure
Real-time content screening systems
Automated detection of illegal content
Integration with industry safety databases (e.g., CSAM databases)
User reporting mechanisms
Many platforms are implementing these requirements through established solutions like CometChat's moderation API, which provides pre-built compliance-ready tools while reducing implementation complexity.
Moderation workflows
Clear procedures for content review
Documented response protocols for different risk levels
Emergency procedures for high-priority content
Appeal handling processes
Staff training programs
Documentation & reporting systems
Comprehensive audit trails
Incident logging mechanisms
Regular safety reports for management
Evidence preservation procedures
Performance monitoring metrics
Phase 3: Operational implementation
Success requires balancing automated tools with human oversight while maintaining clear governance:
Governance framework:
Regular safety committee meetings
Clear escalation procedures
Policy review processes
Stakeholder communication channels
Technical implementation:
Automated content screening
Pattern detection systems
Hash matching for illegal content
Real-time monitoring tools
Human moderation:
Trained moderation team
Clear decision-making guidelines
Cultural context consideration
Regular performance reviews
For many platforms, especially those building moderation capabilities for the first time, partnering with established providers like CometChat can provide a foundation of proven tools and practices, allowing internal teams to focus on governance and oversight rather than technical implementation.
The UK Online Safety Act represents a significant shift in how digital platforms must approach content moderation. While the requirements are substantial, they're not insurmountable with the right approach and tools.
For Large Platforms: Focus on scaling existing systems and ensuring comprehensive coverage:
Upgrade automated detection capabilities
Enhance human moderation teams
Implement advanced reporting systems
For Growing Platforms: Build scalable systems that can grow with your user base:
Start with essential moderation tools
Plan for future capability expansion
Focus on efficient resource use
For Smaller Platforms: Implement core requirements while maintaining efficiency:
Use automated tools where possible
Focus on high-risk areas first
Consider managed service solutions
The key to successful compliance is starting early and building systematically. Whether you're exploring comprehensive solutions for a large platform or focused tools for a smaller service, CometChat can help guide your compliance journey. Our team has extensive experience in content moderation implementation and can serve as a thought partner in planning your approach, from initial assessment through to full compliance.
Remember, the deadline for compliance isn't just about avoiding penalties, it's about ensuring your platform remains a safe and trusted space for your users. Reach out to discuss your specific moderation requirements or to explore how our solutions can support your compliance efforts.
Want to learn more? Contact our team to discuss your platform's unique needs and how we can help you achieve compliance efficiently and effectively.
Shrimithran
Director of Inbound Marketing , CometChat