Ofcom, the UK’s internet safety regulator, has released another set of draft guidance as part of its ongoing implementation of the Online Safety Act (OSA). This latest set of recommendations aims to support companies to meet legal obligations to protect women and girls from online threats such as harassment, bullying, and intimate image abuse. The focus is on ensuring that online platforms implement robust measures to safeguard users from these pervasive dangers.

Prioritizing Women’s Safety Online

Protecting women and girls is a top priority for the UK government in the implementation of the OSA. The act explicitly highlights certain forms of misogynist abuse, such as sharing intimate images without consent or using AI to create deepfake porn targeting individuals, as enforcement priorities. Jessica Smith, who led the development of the female safety-focused guidance at Ofcom, emphasized the importance of these regulations in addressing deep-seated online harm against women and girls. Eliminating these pernicious behaviors could modernize UK internet laws to match some US internet safety laws.

Criticism and Delays in Implementation

The Online Safety Act, approved by the UK Parliament in September 2023, has faced criticism for not sufficiently reforming tech giants, despite substantial penalties for non-compliance. Child safety campaigners have also expressed frustration over the lengthy implementation process and doubts about its effectiveness. Even the technology minister, Peter Kyle, commented in a January interview with the BBC that the law is “very uneven” and “unsatisfactory.” Nevertheless, the government continues to adhere to the approach, acknowledging the lengthy lead times required for parliamentary approval of Ofcom’s compliance guidance.

Even the technology minister Peter Kyle said in an interview with the BBC in January that it is “very uneven” and “unsatisfactory.” Despite criticism, the government continues to adhere to the approach. Part of the discontent around the OSA can be traced back to the long lead time ministers allowed for implementing the regime, which requires parliament to approve Ofcom compliance guidance.

Enforcement Timeline and Key Recommendations

Enforcement of the core requirements, such as tackling illegal content and child protection, is expected to start soon. However, other aspects of OSA compliance will take longer to implement, with the latest set of recommendations not becoming fully enforceable until 2027 or later. In a recent interview, Smith stated, “The first duties of the Online Safety Act are coming into force next month. So we will be enforcing against some of the core duties of the Online Safety Act ahead of this guidance [itself becoming enforceable].”

The Scope of Guidance

The new draft guidelines supplement earlier Ofcom guidance on illegal content, which includes protecting minors from adult content. In December, the regulatory body published finalized recommendations for reducing risks associated with illegal content, emphasizing child protection. Additionally, Ofcom has recommended age checks and content filtering for online services, such as implementing age checking for adult websites.

Strategies for Protecting Women Online

Ofcom recommends a “safety by design” approach, which encourages tech companies to consider safety in the design process right from the start. The latest draft guidance addresses four major areas where women and girls face disproportionate online harm: online misogyny, pile-ons and online harassment, online domestic abuse, and intimate image abuse. This holistic approach aims to ensure safety measures are baked into product design, rather than being added as an afterthought.

Examples of Good Practice

Smith suggested several examples of “good” industry practices, such as:

• Removing geolocation by default to minimize privacy and stalking risks.
• Conducting “abusability” testing to identify how a service could be misused.
• Enhancing account security.
• Designing user prompts to discourage the posting of abusive content.
• Providing accessible reporting tools for users to report issues.

Challenges and Industry Responses

Smith acknowledges the challenges posed by recent changes in the industry, such as Elon Musk’s restructuring of Twitter and rebranding it as X, where he has significantly reduced the trust and safety team, prioritizing a maximalist approach to free speech. The company replaced the head of legal policy and global public policy with an X policy executive and reduced the company’s legal team significantly. This lean team oversees Elon Musk’s vision for a maximalist speech policy. After the restructuring, Musk has responded to employees lobbying for corporate goals centered on safety, user experience, and financial considerations by neglecting these efforts. Meta has also taken steps that mimic Musk’s approach, ending third-party fact-checking contracts in favor of a community-driven labeling system. Smith emphasized that compliance expectations are clear, stating, “Platforms that are operating in the UK will have to comply with the UK law. So that means complying with the illegal harms duties and the protection of children duties under the Online Safety Act.”

Transparency and Accountability

Transparency will play a crucial role in Ofcom’s response to these high-level industry shifts. To curtail these harms, Ofcom will employ its transparency and information-gathering powers to demonstrate impacts and raise user awareness. “We will produce a report about who is using the guidance, who is following what steps, what kind of outcomes they’re achieving for their users who are women and girls, and really shine a light on what protections are in place on different platforms so that users can make informed choices about where they spend their time online,” explained Smith.
She continued, “When seeking to avoid the risk of being publicly shamed for poor performance on women’s safety, platforms can turn to Ofcom’s guidance for practical steps on how to improve the situation for their users, and address the risk of reputational harm too. When industry moves are taken that increase harms, this is where we will be able to shed light and share relevant information with users, the media, and policymakers.”

Technological Solutions to Combat Deepfake Porn

Intimate image abuse, particularly deepfake pornography, is a growing concern. Although initially the required use of the new hash matching protocols may have been off-putting to platform operators (as they require permission from the photos subjects to make the matches), the technology is effective, and Ofcom now recommends it to tackle this issue. Smith explained, “There was more deepfake intimate image abuse reported in 2023 than in all previous years combined.” This has spurred Ofcom to recommend that platforms adopt hash matching technology to detect and remove such abusive content more effectively, acknowledging that deepfake content creation tools have been a booming industry, especially in the last three years, increasing the need for such measures. Indeed, the tech tools that generate deepfakes are touted as an “entry-level” AI-based technology, easily used by consumers.

Future Steps and Compliance

The draft guidance is currently under consultation, with Ofcom inviting feedback until May 23, 2025. The final guidance will be produced by the end of this year. However, Ofcom’s first report on industry practices will be released 18 months later. While substantial progress will be formalized by 2027, platforms are encouraged to proactively adopt these measures, cutting their risk exposure prior to enforcement. This deliberate implementation schedule is to ensure transparency, thorough reporting, and clarity in OSAs mission.