Classify the complaint by service, complainant, duty, and decision; route it to the right procedure; then give an appropriate response and retain the decision evidence.
The Act requires complaints procedures for specified matters. It does not create a universal internal appeal for every platform decision, so any appeal step must be tied to the applicable duty, code measure, or published terms.
A regulated user-to-user or search service must operate an easy-to-access, easy-to-use and transparent complaints procedure for the matters listed in section 21 or 32 of the Online Safety Act. The procedure must provide for in response. Start by identifying who is complaining and which statutory matter is raised. A user complaint, a complaint from an , an internal review, an Ofcom complaint, and a by an eligible organisation are different routes and should not be merged into one queue.
Step 1 - log and classify. Capture the service, account or search result, content or conduct, date, complainant status, safety issue, decision being challenged, and any immediate threat. Preserve the relevant content, notices, policy version, moderation signals, and system logs before they expire.
Step 2 - route by statutory matter. For a user-to-user service, section 21 covers complaints by users and affected persons about specified illegal-content and child-safety duties, content reporting, and certain provider actions; Category 1 services have additional complaint subjects. Section 32 sets the corresponding complaints duty for search services. Check the statutory provision because the eligible complainant and subject differ by route.
Step 3 - contain urgent harm, then decide. Emergency, safeguarding, or law-enforcement escalation can run in parallel with the merits review. The reviewer should apply the Act, the service's terms, the current risk assessment, and the code measure or documented alternative actually adopted. Take , explain the outcome in usable language, and complete or assign any correction.
Step 4 - review a challenged decision when the service's applicable procedure provides for it. The baseline sections 21 and 32 duties require a complaints procedure and , but they do not create a universal statutory second-tier appeal for every decision. Use a reviewer who was not responsible for the original decision where independence matters, and record the final outcome and correction. Ofcom does not act as a general appeal body for individual cases; eligible entities may bring a statutory about features or conduct that present a material risk of significant harm or significantly adversely affect freedom of expression.
Sources (5)
Binding source for the complaints-procedure duties and complaint subjects that apply to regulated user-to-user services.
Binding source for the complaints-procedure duties and complaint subjects that apply to regulated search services.
Official explanation that the child-safety codes cover the section 21 and 32 complaints duties as well as the related content-reporting duties.
The OSA requires Ofcom to set out in codes of practice the measures service providers can take to fulfil their child safety duties (section 12 and section 29 of the OSA) as well as their duties on content reporting and complaints procedures (sections 20, 21, 31 and 32 of the OSA).
Workflow support for Complaint and Appeal Handling Workflow.
The Online Safety Act 2023 (the Act) is a new set of laws that protects children and adults online.
Workflow support for Complaint and Appeal Handling Workflow.
The Online Safety Act 2023 (the Act) protects children and adults online.
The case record should show whether the complainant and subject fall within the applicable statutory procedure. Capture contact preferences, accessibility needs, safeguarding flags, exact allegation, content identifier, original decision, applicable duty and policy, evidence reviewed, outcome, remedy, notice sent, review route, retention rule, and owner.
Sources (5)
Binding source for the complainants, complaint subjects, accessibility, transparency, terms, and response requirements that the user-to-user workflow record must distinguish.
Binding source for the equivalent search-service complaint routes and their different eligible complainants and subjects.
Template field support for Complaint and Appeal Handling Workflow.
The Online Safety Act 2023 (the Act) is a new set of laws that protects children and adults online.
Template field support for Complaint and Appeal Handling Workflow.
The Online Safety Act 2023 (the Act) protects children and adults online.
Template field support for Complaint and Appeal Handling Workflow.
Providers must use risk and evidence-based approaches to ensure there is no room for illegal content and activity on their platforms.
Review the procedure after a material service or terms change, an Ofcom code update, repeated overturned decisions, missed safeguarding cases, accessibility failures, or evidence that users cannot find or use the route. Sample both upheld and rejected cases and check the result against the evidence available at the time.
Sources (5)
Current regulator explanation of the difference between individual complaints and the systemic super-complaints route, including Ofcom's role and the 1 January 2026 commencement date.
Review support for Complaint and Appeal Handling Workflow.
Section 47(1) of the OSA require Ofcom to keep under review each code of practice.
Review support for Complaint and Appeal Handling Workflow.
The Online Safety Act 2023 (the Act) is a new set of laws that protects children and adults online.
Review support for Complaint and Appeal Handling Workflow.
The Online Safety Act 2023 (the Act) protects children and adults online.
Review support for Complaint and Appeal Handling Workflow.
Providers must use risk and evidence-based approaches to ensure there is no room for illegal content and activity on their platforms.
Use Sorena to record the complaint route, decision owner, response, supporting evidence, and any corrective action.
Turn Complaint and Appeal Handling Workflow into scoped questions, evidence fields, and review tasks.
Use Research Copilot to answer follow-up questions with cited source material.
Review complaint intake, appeal routes, evidence owners, and Online Safety Act workflow actions with Sorena.
"The Online Safety Act 2023 (the Act) protects children and adults online."
"The Online Safety Act 2023 (the Act) is a new set of laws that protects children and adults online."
"Online Safety Act"
"The OSA requires Ofcom to set out in codes of practice the measures service providers can take to fulfil their child safety duties (section 12 and section 29 of the OSA) as well as their duties on content reporting and complaints procedures (sections 20, 21, 31 and 32 of the OSA)."
"Section 47(1) of the OSA require Ofcom to keep under review each code of practice."
"Providers must use risk and evidence-based approaches to ensure there is no room for illegal content and activity on their platforms."
"Service providers are best placed to respond to individual complaints"
Decide whether children are likely to access a regulated service or part of it, document the evidence, and identify when a children's risk assessment follows.
Assess illegal-content risks by offence kind, likelihood, severity, affected users, service design, controls, evidence, and review triggers.
Decide whether an online service is a regulated user-to-user service, search service, combined service, or exempt service under the UK Online Safety Act.
Compare age verification and age estimation methods by assurance, privacy, accessibility, bias, evasion risk, and operational evidence.
When Online Safety Act services need age assurance, what highly effective age assurance means, and how safety duties interact with data protection.
Choose an age-assurance method for an Online Safety Act duty by testing effectiveness, privacy, accessibility, evasion risk, and the consequence of error.
Test whether a service is covered by the UK Online Safety Act by checking service functionality, UK links, exemptions, and the duties that follow.
Apply the UK Online Safety Act Category 1, 2A, and 2B thresholds, calculate active UK users, and use Ofcom's register first published in June 2026 and most recently updated in September.
Verify UK Online Safety Act scope, assessments, controls, reporting, complaints, records, child safety, and category-specific work.
Apply the UK Online Safety Act children's access, risk-assessment, safety, age-assurance, reporting, complaints, and record-keeping duties.
Build a UK Online Safety Act compliance program from service scope through assessments, controls, evidence, review, and Ofcom response.
Design UK Online Safety Act moderation, content-reporting, complaints, and review processes for illegal content and content harmful to children.
UK Online Safety Act compliance dates for risk assessments, child safety, categorised services, fees, and event-based deadlines.
How Ofcom investigates Online Safety Act breaches, issues decisions, requires remedies, imposes penalties, and seeks court orders.
Standalone answers and decision paths for UK Online Safety Act scope, risk assessments, child protection, age assurance, categories, reporting, and enforcement.
Apply the Online Safety Act and UK data protection law together for age assurance, moderation, profiling, recommender systems, and safety-data sharing.
Understand the illegal-content risk assessment, safety, reporting, complaints, record-keeping, and review duties for regulated user-to-user and search services.
Build moderation, content-reporting, and complaints procedures for regulated services, and understand where the Online Safety Act does and does not require an appeal.
How Ofcom assesses Online Safety Act concerns, gathers information, investigates suspected breaches, and reaches enforcement decisions.
The Online Safety Act penalty ceiling, qualifying worldwide revenue, daily penalties, penalty factors, and payment consequences.
Understand which user-to-user, search, combined, and provider-pornography services the UK Online Safety Act regulates and which exemptions narrow scope.
See which UK Online Safety Act requirements apply to Part 3 services, child-accessible services, provider pornography, and categorised services.
A field-by-field template for recording service facts, statutory risks, evidence, controls, residual risk, approval, and reassessment triggers.
Run illegal-content and children's risk assessments in the right order, with evidence for risks, controls, governance, and reassessment triggers.
Organise recurring Online Safety Act risk assessments across product, safety, data, engineering, legal, and governance teams.
Understand when a named senior manager or corporate officer can face personal liability for Online Safety Act information offences and how to control the risk.
Decide whether a service is regulated, whether it is user-to-user or search, which exemptions apply, and whether Ofcom categorisation adds duties.
Move from UK Online Safety Act service scope to Category 1, 2A, or 2B threshold analysis without confusing categorisation with basic coverage.
Understand who must publish an Online Safety Act transparency report, what an Ofcom notice controls, and how to prepare traceable reporting data.
Compare UK Online Safety Act and EU DSA scope, service classes, child-safety and platform duties, dates, evidence, exemptions, and enforcement.
A practical scope test for user-to-user, search, and provider-pornography services under the UK Online Safety Act, including UK links and exemptions.
How the UK Online Safety Act, UK GDPR, Data Protection Act 2018, and Children's Code apply together to safety technologies and children's data.
Ofcom information notices, investigations, representations, confirmation decisions, penalties, remediation, and court-based service restrictions.
The two-stage UK Online Safety Act children's access assessment, evidence, timing, reassessment triggers, and next duties.
UK Online Safety Act illegal content risk assessment scope, required elements, deadlines, review triggers, records, and resulting safety measures.
Classify user-to-user, search, and combined services under the UK Online Safety Act, apply the UK-links and exemption tests, and identify the next duties.
Who receives Ofcom transparency notices, what Schedule 8 can require, the 2026 notice process, first-report timing, and evidence controls.
How UK Online Safety Act duties shape content moderation, user reporting, complaints, reinstatement, terms, records, and human oversight.
How Category 1, 2A, and 2B thresholds work, how Ofcom categorises services, and what the register updated in September 2026 means.
When section 110 can make a named senior manager liable for an Online Safety Act information offence, the available defences, and the controls to keep.
When UK Online Safety Act services need highly effective age assurance, what Ofcom expects, and how UK data protection law applies.