If your brand engages UK consumers on social media, the comment sections under your posts and ads now sit inside the UK’s most significant online-safety regime: the Online Safety Act. The Act does not make your brand a regulated platform, but it sets the direction for the whole UK online environment and tightens the rules the platforms apply to everyone on them. Understanding it helps you moderate in a way that is aligned with, rather than exposed to, where regulation is heading.
This guide explains what the Act is, who it applies to, the duties it imposes, and what it means specifically for the comments on your posts, followed by a practical 2026 alignment checklist. For a concise definition, see our glossary entry on the Online Safety Act, and our companion guide on the EU Digital Services Act for the European side.
What the Act Is
The Online Safety Act is the UK’s primary framework for regulating user-generated content and online safety. It places legal duties on user-to-user and search services to tackle illegal content, protect children from harmful material, and apply their own terms of service consistently. Ofcom, the UK communications regulator, enforces the Act and publishes the codes of practice that explain how services should comply. Rather than prescribing a single fix, the Act uses a risk-based model: services must understand the risks their platform carries and put proportionate, demonstrable systems in place to reduce them.
Who It Applies To
The Act’s duties fall on the in-scope services, the user-to-user platforms and search services that host or surface content, not on the individual brands that advertise on them. For the comments under your Instagram or Facebook post, the platform is the regulated service, not your brand. As with the EU DSA, the most common misconception is that a brand running ads inherits these duties directly. It does not.
Why brands still need to care:
The harms the Act targets, fraud, scams, threats, and content harmful to children, are the same harms that flood brand comment sections, especially on paid ads. As platforms tighten their systems to meet their own duties, they expect advertisers to keep their ad environments clean. A brand with reliable, systematic moderation is aligned with the Act’s direction and protected from platform-level enforcement.
The Core Duties
Tackling Illegal Content
In-scope services must take proportionate steps to prevent and remove illegal content, including fraud, threats, and other criminal material. Scam links, fraudulent investment pitches, and impersonation in comment sections all fall squarely into this category. The brand equivalent is to detect and remove this content quickly and reliably rather than letting it sit under your ads.
Protecting Children
The Act places strong emphasis on protecting children from content that is harmful to minors. Brands whose products or audiences skew young should be especially mindful of what appears in their comment sections and filter abusive or inappropriate content systematically.
Risk Assessment and Consistent Enforcement
The defining feature of the Act is its risk-based model: services must assess the risks they carry and put proportionate systems and processes in place to mitigate them, then enforce their rules consistently. For a brand, the parallel is to recognise the comment risks your campaigns attract, scams on high-reach ads, abuse on sensitive topics, and address them with consistent, documented rules rather than reacting differently each time. Our moderation policy template helps you write those rules down.
What the Act Means for Your Comment Sections
The Online Safety Act rewards systems over reactions. Translated to comment management, that means three things:
- Reliable detection. Illegal and harmful comments should be caught dependably, not just when someone happens to notice them.
- Consistency. The same rules should apply across every campaign, the even-handed enforcement the Act expects.
- Demonstrability. You should be able to show how you keep your comment sections safe, with a record of what was actioned.
Achieving reliable, consistent, demonstrable moderation across Instagram, Facebook, TikTok, and YouTube by hand is not realistic at advertising scale, which is why brands turn to AI comment moderation to make it systematic.
Penalties
Ofcom can fine in-scope services up to £18 million or 10% of qualifying worldwide revenue, whichever is greater, and in serious cases pursue business-disruption measures. These penalties target the platforms and services within scope, not individual advertisers. As with the DSA, the practical effect for brands is indirect but real: platforms under this level of pressure tighten the requirements they place on the businesses advertising and building communities on them.
Online Safety Act vs the EU DSA
Both laws make platforms more accountable for user content, but they are distinct regimes a multi-market brand must treat separately.
| Dimension | UK Online Safety Act | EU Digital Services Act |
|---|---|---|
| Jurisdiction | United Kingdom | European Union |
| Regulator | Ofcom | European Commission and national coordinators |
| Core model | Risk assessment and child safety | Notice-and-action and statements of reasons |
| Max penalty | £18m or 10% of global revenue | 6% of global turnover |
2026 Online Safety Act Alignment Checklist
- Assess your comment risk. Identify which campaigns and topics attract scams, abuse, or content harmful to younger audiences.
- Put a system in place. Use reliable, real-time detection rather than spot-checking comments manually.
- Enforce consistently. Apply the same documented rules to every campaign and platform.
- Keep a record. Log moderation actions so you can demonstrate how you keep comment sections safe.
- Protect younger audiences. Filter abusive and inappropriate content systematically where your audience may include minors.
- Cover the EU too. If you also sell into the EU, align with the DSA in parallel.
How FeedGuardians Helps
FeedGuardians gives brands the reliable, systematic, demonstrable moderation the Online Safety Act’s risk model favours. It scans every comment across Instagram, Facebook, TikTok, YouTube, and Bluesky, hides fraud, scams, and abuse the moment they appear, applies the same brand-defined rules everywhere, and logs every action, so you can show exactly how your comment sections are kept safe. An approval mode routes sensitive cases to your team, keeping moderation diligent. The result is a comment environment that is clean by default and aligned with where UK regulation is heading.
Frequently Asked Questions
This article is general information, not legal advice. For obligations specific to your business, consult a qualified lawyer.
Make Your Comment Moderation Systematic
FeedGuardians detects and hides illegal and harmful comments in seconds, enforces consistent rules, and logs every action, the demonstrable moderation the Online Safety Act rewards.
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