The UK's Online Safety Act (OSA), which received Royal Assent in September 2023, establishes a comprehensive regulatory approach to online safety, with specific provisions addressing deepfakes and non-consensual intimate imagery. Ofcom serves as the primary enforcement authority with extensive powers to ensure compliance.

Regulatory Enforcement and Penalties

  • Ofcom monitors compliance and can impose fines up to £18 million or 10% of a company's qualified global revenue

  • Senior executives can face criminal charges for failing to comply with information requests or child protection obligations

  • Ofcom can block site access or freeze assets with court approval

Key Provisions and Protections

Criminal Offenses for Deepfakes

  • New legislation explicitly criminalizes the creation and distribution of sexually explicit deepfakes

  • This regulation is being incorporated as an amendment to the upcoming Criminal Justice Act

  • Unregistered intimate images, including pornographic deepfakes, have been criminalized in England and Wales since January 31, 2024

Platform Obligations

  • Online platforms must remove illegal content, including harmful deepfakes, when notified

  • Category 1 services (larger platforms) must exclude such content if prohibited by their terms of service

Algorithm Regulation

  • Service providers must assess their algorithms' impact on illegal content and harm to children

  • They must mitigate risks and consider design and functionality aspects

  • Category services must publish annual transparency reports about their algorithms and user experience, including children's experiences

Misinformation Considerations

Deepfakes are specifically addressed in the context of misinformation regulation:

  • State-sponsored disinformation using deepfakes is classified as a "foreign interference crime"

  • Platforms must remove disinformation causing significant harm, such as election interference

  • Ofcom's advisory committee on disinformation commenced operations in April 2025

> Implementing the Online Safety Act: progress update

UK Online Safety Act Compliance with Proofly

Ready-Made OSA Compliance Solution

Proofly provides platforms with the essential tools to meet UK Online Safety Act requirements efficiently:

  • Instant content analysis through our API to identify deepfakes and non-consensual media content

  • Algorithm risk assessment capabilities to fulfill OSA regulatory obligations

  • Streamlined review workflows supporting Ofcom's notification and takedown timelines

  • Documentation systems for mandatory transparency reporting

Our technology offers immediate implementation, helping platforms avoid severe penalties (up to £18 million or 10% of global revenue) while maintaining operational efficiency and user privacy protection.

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