Artifact GuideUKModeration and Appeals

UK Online Safety Act Moderation and Appeals

Regulated services need moderation, reporting, and complaints systems that match their assessed risks and the duties applying to their service type.

This guide separates content reports from complaints, explains what an upheld complaint requires, and shows how terms and operational evidence fit together.

Author
Sorena AI
Published
May 9, 2026
Updated
Oct 15, 2026
Overview

The Online Safety Act does not impose one universal moderation rule or a single appeal model. User-to-user and search services have different safety duties, but both need an accessible and content-reporting route for specified issues. The provider must take appropriate action when a complaint is upheld and keep its public rules aligned with the system in use.

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4 of 4 questions
Question 1

What moderation outcomes does the Act require?

For illegal content, user-to-user services need proportionate systems and processes designed to prevent users encountering , mitigate identified risks, minimise how long priority illegal content remains, and swiftly take down illegal content when the provider becomes aware of it. Search services must minimise the risk of users encountering priority illegal content and known illegal content in or via search results.

Services likely to be accessed by children have additional duties for content harmful to children. The exact moderation design depends on the service, assessed risks, applicable duties, and Ofcom codes. Measures can include detection, triage, human review, removal, visibility reduction, recommendation controls, account action, user support, and escalation, but each measure must be justified and tested in context.

  • Map each content class and risk to a detection route, decision rule, response target, reviewer, escalation path, and user-facing outcome.
  • Test automated systems for accuracy and bias, and give reviewers enough context and authority to correct errors.
  • Keep urgent routes for child sexual abuse material, terrorism content, imminent danger, and other cases requiring specialist handling or reporting.
Question 2

How do content reports and complaints differ?

A lets users and other eligible people notify the provider about content of a kind covered by the Act. A covers specified complaints about content, the provider's compliance, and certain provider decisions. For user-to-user services, sections 20 and 21 govern these duties; sections 31 and 32 cover search services.

The must allow relevant complaints, provide for appropriate action when a complaint is upheld, be easy to access and use, including by children, and be transparent. Appropriate action depends on the case. It may include removing illegal content, correcting a restriction, reinstating content removed in error, or changing an account decision. The Act does not require every complaint to produce the user's preferred result.

  • Keep reporting and complaints entry points clear, even if one intake form routes users behind the scenes.
  • Tell users what they can complain about, what information is needed, how the service will communicate, and what outcomes are possible.
  • Record the original decision, evidence, rule applied, reviewer, outcome, action taken, and any policy or model feedback.
Question 3

What should terms, metrics, and governance show?

User-to-user terms must explain how users are protected from illegal content and set out the complaints policies and procedures required by the Act. Search services must make the corresponding illegal-content statement and complaints information public. Providers must apply stated provisions consistently.

Useful evidence includes moderation guidance, training, quality sampling, model and rule versions, error analysis, response times, reversals, repeat reports, systemic issues, staffing and language coverage, vendor oversight, child accessibility, and remediation. Metrics need stable definitions and should distinguish reports, pieces of content, decisions, accounts, complaints, and successful complaints.

  • Reconcile written terms, moderator guidance, product labels, enforcement reasons, and complaint outcomes after every policy change.
  • Track error and reversal rates by content class, language, age group where lawful and appropriate, and decision method.
  • Escalate repeated reversals or reporting failures into the risk assessment and control-review process.
Question 4

Questions and answers

Does Ofcom decide an individual's content appeal?

No. Individuals should first use the service's reporting or complaints process. Ofcom says it cannot investigate or resolve an individual complaint or order a service to remove or reinstate specific content, but complaint information can inform its view of systemic compliance.

Must every moderation decision receive human review?

The Act does not create a universal human-review rule for every decision. The provider must operate proportionate systems that meet the applicable duties and a capable of taking appropriate action when a complaint is upheld. Human review may be necessary where automation cannot deliver that outcome reliably or fairly.

Does removing reported illegal content satisfy the illegal-content duties?

Not by itself. User-to-user providers must use proportionate systems designed to prevent users encountering , mitigate and manage assessed risks, minimise how long priority illegal content remains, and swiftly remove illegal content once aware of it. Search providers have corresponding encounter-minimisation and risk-management duties for search content. Reporting and removal are parts of that system, not substitutes for risk assessment, prevention, testing, and review.

Primary sources

References and citations

legislation.gov.uk2 citations
Referenced sections
  • Primary user-to-user complaints requirements.
  • Sets user-to-user complaints duties, relevant complaint types, accessibility, transparency, and appropriate action.
legislation.gov.uk2 citations
Referenced sections
  • Primary search-service complaints requirements.
  • Sets search-service complaints duties.
legislation.gov.uk
Referenced sections
  • Sets the user-to-user illegal-content safety duties.
legislation.gov.uk
Referenced sections
  • Sets the search-service illegal-content safety duties.
legislation.gov.uk
Referenced sections
  • Sets user-to-user content-reporting duties and eligible reporters.
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