Ofcom’s Fix For An Online Safety Act That Isn’t Working: More Online Safety Act

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Ofcom’s media relations people know how to email me. I have ten press releases from them this year. They emailed me when they launched investigations of or took actions on X/Grok, Telegram, Pornhub, and Sanctioned Suicide. But when they recently published their required report on how the Online Safety Act is going… suddenly they’ve lost my email?

Now, it’s no secret that I’ve mostly been a critic of the Online Safety Act, but I’m open to being proven wrong. Unfortunately, Ofcom’s latest report seems to support many of my criticisms of the law, and perhaps that’s why they didn’t feel it was worth letting me know about it. Even the opening lines of the announcement make it clear they’re only releasing this report because they have to.

Ofcom is required by the Online Safety Act 2023 to review and report on content harmful to children online.

This is our first report under section 63 of the Act, which places a duty on Ofcom to produce and publish a statutory report on content that is harmful to children at least every three years following the passage of the Act.

Yeah, that’s the bureaucratic equivalent of “mom made me do this, but I don’t want to.”

The press release includes four bullet points, which play down how bad the report actually is. Everything about the report is basically “none of this is actually working” and Ofcom’s response and recommendations are basically “double down harder, declare more information harmful to kids, and allow us to take more enforcement actions.”

  • In our advice, we recommend that it is appropriate to add body stigma content and depression content, currently identified by Ofcom as kinds of non-designated content, to the category of priority content that is harmful to children. If the Secretary of State takes our recommendation forward, this will ensure that protections for children against these kinds of content are enshrined in the Act.
  • At this time, we do not recommend any other changes to the categories of primary priority or priority content that is harmful to children in the Act. We are not recommending changes where we found that the available evidence supports the current categorisation or where proposed legislation is likely to address concerns.
  • Most children in the UK say they have encountered at least one piece of harmful content online in a four-week period. According to our evidence, at a total level there was no significant change in the proportion of children encountering harmful content over the first nine months after the children’s safety duties came into force in July 2025. This finding is concerning and shows that further progress is needed to protect children online.
  • Exposure to harmful content can have serious impacts on children’s mental and physical wellbeing. Children continue to report that encountering harmful content negatively impacts their wellbeing. There is no new evidence indicating a change to the severity of harm experienced by children as a result of encountering harmful content.

But the actual numbers in the report (not included in the press release) are pretty bleak for those who believe that widespread identity and age verification, combined with potential liability for “harmful” content will do anything to protect children at all. The numbers suggest basically zero improvement in kids’ exposure to content deemed “harmful.”

The report looks at the access that kids have to various categories of supposedly “harmful” content before and after the OSA’s “child safety duties” went into effect. This is the UK’s version of the infamous “duty of care” concept that has become popular around the globe (including the US). As we’ve warned in the past, the “duty of care” sounds reasonable, but it really serves no useful purpose other than as a hammer to batter companies after kids inevitably find their way to content adults deem harmful.

We’ve also mentioned that this is effectively engaging in a global experiment on children without any actual evidence that it works. For all the talk of social media companies “experimenting on children,” the duty of care legislation does the same.

And the details from this report suggest the duty of care… has had a statistically meaningless impact on kids encountering harmful content online. In short if you looked at the data from before and after and asked if the government had put in place a massive new law to “protect the children online” you would not be able to place when (or if) it happened, because the data shows effectively no impact.

But it is limiting adult access to information.

The story is the same on basically every category of “harmful” content. Kids still see it.

Ofcom data shows that children’s reported exposure to suicide content and self-harm content on user-to-user services did not change significantly over the first nine months after the children’s safety duties in the Act came into force in July 2025….

Ofcom data shows that children’s reported exposure to eating disorder content on user-touser services did not change significantly over the first nine months after the children’s safety duties in the Act came into force in July 2025….

Ofcom data shows that children’s reported exposure to abuse and hate content on user-touser services did not change significantly over the first nine months after the children’s safety duties in the Act came into force in July 2025….

Ofcom data shows that children’s reported exposure to bullying content on user-to-user services did not change significantly over the first nine months after the children’s safety duties in the Act came into force in July 2025….

Ofcom data shows that children’s reported exposure to violent content on user-to-user services did not change significantly over the first nine months after the children’s safety duties in the Act came into force in July 2025….

Ofcom data shows that children’s reported exposure to harmful substances content on user-to-user services did not change significantly over the first nine months after the children’s safety duties in the Act came into force in July 2025….

Ofcom data shows that children’s reported exposure to dangerous stunts and challenges content on user-to-user services did not change significantly over the first nine months after the children’s safety duties in the Act came into force in July 2025….

Ofcom data shows that children’s reported exposure to depression content on user-to-user services did not change significantly between December 2025 and April 2026, with around a quarter of children reporting being exposed to depression content….

Ofcom data shows that children’s reported exposure to body stigma content on user-touser services did not change significantly between December 2025 and April 2026….

And so forth…

The one area they claim has seen some success is that “highly effective age assurance” on adult content sites has been successful in stopping kids from accessing those sites:

Highly effective age assurance is helping to prevent children from accessing pornography services. As of July 2026, the majority of the most popular pornography services in the UK had age checks in place.

That said, the data shows no meaningful drop in kids’ overall exposure to porn, since most of it appears to come via social media and forum sites, so just like all the other areas of content, we’re talking about “did not change significantly.”

Children are still encountering pornographic content on social media, messaging and gaming services. The proportion of children reporting exposure to this content did not change significantly over the first nine months after the children’s safety duties in the Act came into force in July 2025.

Bizarrely, the report doesn’t show any data, charts, or tables about the (lack of) changes in exposure to this content. The report doesn’t have any footnotes (as far as I can tell) with links to the data. Nor does the page announcing the report. They do, however, say that it’s from the Children’s Online Safety Tracker tool, and after searching through their website, I finally found some links to the raw data.

Having spent some time going through the data, I think about the only thing you can conclusively say is that… the Online Safety Act duty of care has had basically zero impact so far. In some cases the access to the content went up a tiny bit. In some cases it went down a tiny bit. There are three data sets: Wave 1, a baseline taken before the duty of care went into effect in July 2025. Then there’s Wave 2, at the end of 2025, looking at the impact about six months in. And now we have Wave 3 from earlier this spring, representing about nine months in.

And what we see is… basically nothing. There’s no noticeable change outside of statistical noise as of yet:

Dot-and-whisker chart showing change in the share of UK children aged 11–17 reporting exposure to harmful content, with 95% confidence intervals. For 11 content categories, the Wave 3 change since Ofcom’s baseline (blue) crosses zero in every case, as do the depression and body stigma changes from Wave 2 to Wave 3. Only bullying at Wave 2 (gray) clears zero, by a narrow margin, and the rise had faded by Wave 3.
  • By way of disclosure, I’ll note that I used Claude to help me make this chart based on the spreadsheets from Ofcom. I independently verified the numbers against Ofcom’s spreadsheets.

As you’ll see, the only category with a statistically significant change at any point was… bullying. Which went up (not down) significantly between Wave 1 (pre-duty) and Wave 2. But by Wave 3 it had fallen back down to within the insignificant zone, but still above the pre-duty number.

So the scorecard looks like this: The duty of care went into effect, companies put in place all sorts of intrusive age verification tools… and nothing happened. Kids still come across the same amount of questionable content.

Now, perhaps you can argue that nine months of data is not enough. But you would think that if this law was so important and a duty of care was so important, we should see some indication of a change in kids’ exposure to harmful content? Somewhere? Somehow?

But that doesn’t mean the law did nothing at all. Adults did have to deal with some of the fallout of the law, including smaller forums and sites deciding that they needed to shut down, rather than deal with compliance costs and risks of the law. Also, many more people have needed to put their private data at risk by needing to upload identification or other personal data to get access to sites.

All this to “protect the children” when the current data suggests… no real change to kids’ access to this content.

Perhaps someone should be asking why governments like the UK are running these experiments without any willingness to admit that maybe it does more harm than good?

ofcom, harmful content, online safety act, protect the children, uk