United Kingdom – Online Safety Act 2023
Understanding and operationalising the UK’s Online Safety Act, enabling platforms to reduce illegal activity risk, strengthen user protection, and meet evolving regulatory expectations with confidence.
A New Duty of Care Framework for Online Safety in the UK
The UK Online Safety Act establishes a duty of care framework for in scope user to user services and search services, supported by Ofcom codes of practice and phased implementation. The Government’s explainer is explicit that services must implement systems and processes to reduce the risk their services are used for illegal activity and to remove illegal content when it appears.
The regime includes illegal content duties, underpinned by risk assessments and proactive measures for priority offences. Official guidance also frames fraud as within scope of the illegal content and activity the Act targets, alongside other categories of harm. Enforcement is supported by Ofcom’s powers, including significant financial penalties and strong supervisory mechanisms.
Implementation is being delivered in phases, led by Ofcom, with duties and codes taking effect progressively through 2024 to 2026, reflecting the scale of changes required across the online ecosystem.
Key Regulatory Shifts Under the Online Safety Act
The Act introduces enforceable obligations requiring platforms to proactively manage illegal content risks and demonstrate accountability at scale.
Illegal Content Duties
Mandatory systems and processes to identify, mitigate, and remove illegal content, including fraud and scam activity.
Risk Assessment Frameworks
Ongoing risk assessments to evaluate exposure to illegal harms and inform proportionate mitigation strategies.
Proactive Prevention Measures
Implementation of safeguards to prevent priority offences before they occur, not just reactive enforcement.
Ofcom Oversight & Enforcement
Regulatory supervision supported by strong enforcement powers, including significant financial penalties.
Transparency & Accountability
Clear documentation, reporting, and auditability of moderation, enforcement, and risk management decisions.
Phased Implementation
Progressive rollout of duties and codes between 2024–2026, reflecting the scale of operational change required.
What This Means for Organisations
The Online Safety Act requires organisations to move beyond reactive moderation toward structured, risk-driven safety operations.
Organisations must demonstrate:-
Continuous monitoring of services for illegal activity, including fraud and scams
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Risk assessments that inform proportionate safety and enforcement measures
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Rapid detection and removal workflows for illegal content
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Clear audit trails supporting regulatory scrutiny and internal governance
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Ongoing improvement of systems to address evolving threat patterns
This requires operational maturity across detection, enforcement, intelligence, and compliance reporting.
Core Operational Obligations Under the Online Safety Act
Monitoring & Detection
Continuous identification of illegal activity, including impersonation, scams, and fraudulent infrastructure.
Risk Assessment & Mitigation
Structured evaluation of platform risks with aligned controls to reduce exposure.
Enforcement & Takedowns
Timely removal of illegal content and disruption of harmful activity across channels.
Audit & Evidence Management
Comprehensive documentation of actions, decisions, and outcomes for compliance validation.
Intelligence & Pattern Detection
Identification of repeat offenders, coordinated campaigns, and evasion tactics.
Regulatory Reporting Readiness
Preparedness to meet Ofcom expectations for transparency, reporting, and compliance assurance.
How unphish Aligns with the Online Safety Act
unphish supports the Act’s duty of care model by enabling demonstrable, repeatable reduction of scam and fraud exposure and rapid disruption when illegal activity is identified.
Continuous Monitoring
Persistent detection of impersonation, scam campaigns, and fraudulent infrastructure targeting UK users and services.
Rapid Disruption & Enforcement
Accelerated takedown workflows that reduce exposure windows across web, social, and brand impersonation channels.
Compliance-Ready Evidence
Evidence packs and audit trails that support Ofcom style scrutiny and internal compliance assurance.
Risk Intelligence & Insights
Actionable intelligence supporting risk assessments, including repeat campaign detection and evasion patterns.
