Digital regulation | UK Regulatory Outlook June 2025

UK updates 

Online safety updates 

Ofcom opens new investigations 

Ofcom has launched a number of new investigations into online discussion and file-sharing services under the Online Safety Act 2023 (OSA). The regulator is scrutinising whether the services have failed to: 

• Implement appropriate safety measures to protect UK users from illegal content and activity.
• Complete and keep a record of a suitable and sufficient illegal harms risk assessment.
• Respond to Ofcom's statutory information request. 

Ofcom has also been proactive in looking into the compliance of services that publish or display pornographic content with implementing "highly effective age assurance" to protect children from pornography. 

All in-scope user-to-user and search services that identified risks relating to illegal content in their compulsory illegal content risk assessments had to have measures in place to protect users from such risks from 17 March 2025.  

In addition, services likely to be accessed by children must, by 24 July 2025, complete and record a children's risk assessment to assess the risk of children encountering content harmful to them on their service and the impact on them (this is in addition to completing an illegal content risk assessment). Those service providers will need to have implemented the measures set out in the protection of children codes of practice (or be using equivalent measures) to protect children and mitigate the risks identified in their children's risk assessment from 25 July 2025. See this Regulatory Outlook for more information. With Ofcom already being proactive in enforcing the illegal content duties, showing not only the importance of complying with the OSA's requirements, but also of cooperating with the regulator and responding to information requests, services should be ready for Ofcom to adopt a similar rigorous approach in relation to the child protection requirements, not just in relation to pornographic content, but other content harmful to children as well.  

Government responds to consultation on super-complaints  

The government has published a response to its consultation on "super-complaints" under the OSA. The super-complaints regime aims to ensure that eligible entitles can raise complaints with Ofcom about "systemic issues" to make the regulator aware of existing or emerging online harms (see this Regulatory Outlook for background).  

Following the consultation, the government has made some changes to the regime to broaden it and help speed up the process, including: 

• Expanding the eligibility criteria to include newer organisations that are experts in online safety matters, not just "experienced" organisations.
• Removing the statutory pre-notification period, which required complainants to inform Ofcom of their complaint 30 days before submission.
• Removing the requirement for entities to have consulted with a range of bodies, industry experts or academics.  

The government has also laid a statutory instrument in Parliament to define the eligibility criteria for entities to submit super-complaints and the procedural steps to establish the duties of complainants and Ofcom when a super-complaint is submitted.  

Once approved by Parliament, the super-complaints regime will come into force on 31 December 2025. Ofcom will also be consulting on draft guidance for the new regime. 

Media Act updates 

Ofcom updates on report to secretary of state on the operation of the UK market for ODPS and non-UK ODPS  

In September 2024, the secretary of state for culture, media and sport wrote to Ofcom, asking it to prepare a report on the operation of the UK market for on-demand programme services (ODPS), following the provisions in the Media Act 2024 on the video-on-demand Tier 1 services framework coming into force (but not into effect). See more in this Regulatory Outlook and this Insight.  

On 30 May 2025, Ofcom delivered the report to the secretary of state. 

The secretary of state is obliged under the Media Act to take this report into account before making regulations on the Tier 1 service regime and designating services as having Tier 1 status. Ofcom is not making this report publicly available due to restrictions in the Communications Act 2003 on sharing the information provided to Ofcom by ODPS providers.  

Ofcom consults on listed events regime  

Ofcom has published a consultation on changes made to the listed events regime under the Media Act and on a draft revised code on listed events.  

The updated regime will no longer restrict listed events to traditional broadcast channels, but will include any services that can be used to show live coverage of such events to UK audiences, including global media platforms and streaming services.  

The consultation relates to: 

1. Ofcom's duty under the Act to make regulations defining "live coverage", "adequate live coverage" and "adequate alternative coverage", which will affect when the regime applies and the conditions that service providers must satisfy to be authorised to show live coverage of listed events.
2. The draft revised code on listed events, which will reflect the changes made by the Act. The code will explain the approach Ofcom will take where regulator consent is needed to show live coverage of listed events. 

The deadline for responses is 8 August 2025. 

Other updates 

Ofcom's strategic approach to AI  

Ofcom has outlined how it is supporting the industries it regulates in using AI, and how it is using the technology itself. Ofcom provides examples of how online platforms, broadcasters and telecoms companies are leveraging AI, from automated content moderation to improve online safety to improving accessibility to media content through automated dubbing and audio descriptions, and using AI to keep telecoms networks secure. It also considers the ways in which AI could be useful to spectrum allocation and postal companies in the future. 

Ofcom also sets out a range of initiatives it is working on to support AI innovation across all the sectors it regulates and how it is trialling the use of AI to enhance its own productivity. Ofcom also outlines its planned AI work for 2025-2026, which includes horizon-scanning to identify emerging and longer-term AI developments affecting its sectors, working with big online platforms to understand how they are deploying AI tools, exploring whether additional measures are needed to address AI-based harms online, and issuing guidance to broadcasters on using AI. 

Online marketplaces may be subject to additional obligations relating to electrical and electronic equipment  

See Consumer section