Digital regulation | UK Regulatory Outlook September 2026

Online safety and age assurance

EU KIDS ACT: European Commission announces new restrictions on children's access to social media and other digital services

The Commission has published a new legislative proposal in the form of a regulation, the KIDS ACT (EU Keeping Internet Digital Spaces Accountable and Trustworthy), which will ban social media and some other digital services, such as online games, for under-13s; introduce "mini" accounts with limited features that can be used by 13-15-year-olds but only with parental supervision; and provide that autonomous accounts can only be opened by 15-year olds if the platforms are "safe by design", as set out in the legislation. See this Insight for more information.

UK to legislate to make it 'impossible' for children to take or share nude images

The UK government has announced that it will introduce legislation requiring device providers to prevent children from taking, sharing or viewing nude images.

This follows its call, in June, on producers of smartphone devices to activate existing measures by September to prevent children from using their devices to take and share naked images, as reported in this Regulatory Outlook. The government had said that, should providers fail to act voluntarily, it would introduce legislation to compel compliance. Despite some progress by the technology companies, the government said that the voluntary measures did not meet the "scale of the government's ambition".

The legislation, which the government intends to introduce "as soon as possible", will be based on the following principles:

• It must be "impossible" for anyone under the age of 18 to take, view or send nude images. This means that nude images must be blocked across all device features, including the camera and third-party apps.
• Nudity detection filters must be switched on by default.
• The only way for a user to take, view or send nude images should be for an adult to verify their age through a robust age-assurance process.

The government is also exploring legislation that would require providers of apps used by children to prevent them from accessing or sharing nude content, with the aim of "ensuring the whole ecosystem changes to protect children".

UK Online Safety Act updates

Parliamentary inquiry launched into Online Safety Act effectiveness

The House of Lords Communications and Digital Select Committee has launched an inquiry into the implementation, enforcement and impact of the Online Safety Act 2023 (OSA). It will examine whether the OSA has begun to make regulated online services safer for UK users. It will consider Ofcom's interpretation, implementation and enforcement of the OSA's provisions, whether these have led online services to make meaningful changes to their systems, processes and design, and the impact of the OSA on children's and adults' online experiences.

The committee will also assess whether there are shortcomings in the OSA itself that limit the regime's effectiveness, and identify what further action may be required from the government, Ofcom, providers of regulated services or Parliament to drive improvements.

As part of the inquiry, the committee conducted a call for evidence, which closed on 7 September 2026.

Amendments to illegal content codes of practice on 'hash matching' in effect from 30 September

Ofcom has published the finalised version of its amendments to the illegal content codes of practice for user-to-user and search services, setting out its recommendation that certain service providers use automated technology (known as "hash matching") to detect and prevent the sharing of illegal intimate images, including explicit AI-generated deepfakes. The amendments come into effect on 30 September 2026.

It has also opened an enforcement programme to monitor whether platforms are either using automated detection technology as recommended or have other sufficient measures in place. It is a priority offence under the OSA to share or threaten to share intimate photographs or film without consent.

Ofcom has said that it aims, by the end of this year, to consult on strengthening its illegal content codes of practice in relation to the duty requiring platforms to remove non-consensual intimate image content within 48 hours, which was added to the OSA by the Crime and Policing Act, but is not yet in effect.

Ofcom seeks evidence on women and girls' online experiences

Ofcom published its final guidance on a safer life online for women and girls under the OSA in November 2025, setting out how regulated service providers can deal with content and activities that disproportionately have an impact on women and girls. See this Regulatory Outlook for more information.

Fulfilling its commitment to monitor how service providers choose to protect their users, Ofcom intends to publish a report in Q2 2027 examining what steps they are taking to improve online safety for women and girls. The regulator is now seeking evidence about women's and girls' online experiences since the guidance was published, including what, if any, changes they have experienced during this period.

The call for evidence closes on 4 November 2026.

Ofcom reminds providers of their existing duties in light of potential social media ban

Ofcom has published an open letter to in-scope service providers stating that the government's announcements about future safety measures, such as plans to introduce a social media ban for under-16s, do not affect providers' current obligations under the OSA. They must, therefore, continue to comply with their existing child safety and illegal content duties.

Ofcom has also published an article outlining its approach to online safety supervision and compliance. The regulator describes the range of tools available to it to drive compliance, from setting expectations upfront and gathering information, to engaging directly with individual services, launching formal investigations and imposing fines.

UK Media Act updates

Ofcom consults on code of practice for designated radio selection services

In March 2026, Ofcom recommended that three smart speakers should be designated by the secretary of state to fall within the scope of the radio selection services (RSS) regime in the Media Act. See this Regulatory Outlook for more information.

Ofcom is now consulting on its proposed code of practice for designated RSS. The code sets out recommended actions that providers of designated RSS should follow in order to comply with their duties under the Act. The consultation closes on 9 November 2026.