Smaller User-to-User Services and Protecting Children from Harm Online

Smaller User-to-User Services and Protecting Children from Harm Online

The Online Safety Act 2023 imposes obligations on regulated user-to-user online services to take steps to reduce the risks of harm to users posed by illegal content. These requirements include:

• Providers of large user-to-user services should offer all registered users the ability to block and mute other user accounts on the service, if they have:
  • Identified as medium or high risk for one or more of: coercive or controlling behaviour; harassment, stalking, threats and abuse; hate; grooming; and/or encouraging or assisting suicide;
  • User profiles; and
  • At least one of the following functionalities: user connections; posting content; user communication.
• Providers of large user-to-user services should offer all registered users the ability to disable comments on their content, if they have:
  • Identified as medium or high risk for one or more of: harassment, stalking, threats and abuse; hate; grooming; and/or encouraging or assisting suicide; and
  • A function which allows commenting on content.

Ofcom’s goal with these measures was to reduce the risk of harm to users. Initially, Ofcom focused on large user-to-user services but intended to consider extending them to smaller services in the future. That future has now arrived.

Extending Measures to Smaller User-to-User Service Providers

Ofcom now proposes to extend these measures to cover smaller services that are likely to be accessed by children, stating that such service providers should make the appropriate tools available to child users on the parts of their services that are accessible by children.

Ofcom’s proposals would extend the measures as follows:

• User blocking and muting would apply to user-to-user services that are likely to be accessed by children with user profiles which have:
  • At least one of the following functionalities: user connections; posting content; user communication; and
  • Below 7m monthly UK users and a high risk for one or more of: coercive or controlling behaviour; harassment, stalking, threats and abuse; hate; grooming; and/or encouraging or assisting suicide; or
  • Between 700,000 and 7m monthly UK users and a medium risk for one or more of the above types of illegal harm.
• The ability to disable comments would apply to user-to-user services that are likely to be accessed by children with the function to allow commenting on content which have:
  • Below 7m monthly UK users and a high risk for one or more of: harassment, stalking, threats and abuse; hate; grooming; and/or encouraging or assisting suicide; or
  • Between 700,000 and 7m monthly UK users and a medium risk for one or more of the above types of illegal harms.

Responding to the Consultation

Ofcom’s consultation on these proposals is open until 22nd July 2025. Full details of the proposals and the consultation questions are available on Ofcom’s website (external link).