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In March 2025, the UK entered a new online regulatory era with the coming into force of the Online Safety Act (the Act). Like many new regulatory regimes, Ofcom (the regulator) has significant authority to apply the Act. Early indications are that large for-profit social media providers are the principal focus at this time. Regardless, there are no “carve outs” for not-for-profit organisations, chartered institutes, institutions, royal colleges and similar. As such, membership bodies, associations, and organisations that provide online environments where users can author content should be aware of the potential implications of this new law.
The Act is designed to empower the UK government, through Ofcom, to better protect users – especially children and vulnerable individuals – in online spaces where it is possible for users to post content and/or message each other, share files etc. The law’s primary goal is to hold providers of such services accountable should they be found to facilitate harmful or illegal behaviour without adequate safeguards in place. Online bullying, harassment, suicide promotion, illegal content distribution, terrorism and grooming are specifically cited.
While Ofcom states that “proportionality is key,” the scope of the Act is not limited to the tech giants. Any organisation that provides an online space for user interaction could potentially fall under its purview if harm occurs in the platforms they offer. Even if your interactive comment spaces or online community are not the intended target of the legislation, you may still have new responsibilities and risks to manage.
It is crucial to understand that the responsibility for undertaking the risk assessment lies with the entity that controls who can use the service. In practical terms, this means the licensors of the software are the ones who must ensure compliance. If your organisation decides who can access and participate in your online community, you are likely responsible for assessing and managing the associated risks. While these requirements may seem daunting, many best practices for managing online communities already align with the Act’s expectations.
To help reduce risk and align with the new legal landscape, consider the following actions:
Many online community platforms are already rolling out enhancements to help organisations comply with the new requirements. For example, the Discourse Forums support community has published updates and guidance on how their platform is adapting to the Act. Staying informed about such developments can help you leverage new tools and features to maintain compliance.
With the Act now governing collaborative environments, it is appropriate for technology leaders at membership bodies to initiate internal reviews. Ofcom is providing further guidance, as is the UK Department for Science, Innovation & Technology. Review these and consider further action, such as:
As the Act becomes embedded in UK law, we will all learn more about its practical implications. But the core takeaway is this: Taking proactive steps now will help your organisation navigate this new regulatory environment with enhanced confidence.
We’re here to help you interpret the Online Safety Act and make the necessary changes. Speak to a digital expert now.