Beyond guidance: Making the Online Safety Act work for women and girls

The brief finds that the Online Safety Act has prompted some improvements in children’s online safety, but there is little measurable evidence of progress for women. It calls for stronger legal obligations, more effective enforcement and a shift towards preventing technology-facilitated gender-based violence before harm occurs.

• Strengthen the Online Safety Act’s core protections: The Act currently allows platforms considerable discretion over their safety policies, including the ability to weaken existing protections. The UK Government should introduce minimum mandatory standards for platforms’ terms of service, prevent the rollback of safety commitments and establish an enforceable duty of care. Platforms should also be required to assess human rights and equality impacts, including the overlapping harms experienced by marginalised groups.
• Make protections for women and girls enforceable: Ofcom’s guidance on violence against women and girls is not an enforceable code of practice, limiting its ability to hold platforms accountable. The Government should place these protections on a statutory footing, introduce clear safety-by-design requirements and address harmful content, including misogyny, that may fall below the threshold of criminality but continues to cause significant harm.
• Regulate AI and prevent emerging forms of abuse: Generative AI and other emerging technologies are enabling new forms of abuse, while existing regulation has struggled to keep pace. The Government should bring emerging technologies such as AI chatbots within the scope of the Online Safety Act and introduce broader, risk-based AI and digital regulation. This should address not only illegal content but also the design features and functionalities that enable or amplify gender-based violence.
• Put survivor protection and redress at the centre: The current framework focuses primarily on platforms’ systems and processes, offering limited routes to individual redress. The Government should establish accessible mechanisms for survivors of technology-enabled violence to seek remedies. It should also provide sustainable funding for specialist support services, including through dedicated allocations from digital services tax revenue and fines imposed under the Act.
• Move from reactive enforcement to safety by design: Ofcom should use its existing powers to require platforms to identify and address the underlying causes of technology-facilitated gender-based violence, including harmful business models, algorithmic amplification and discriminatory design features. Stronger intersectional risk assessments, faster enforcement and outcome-based evaluation are essential to measuring whether regulation is genuinely reducing harm to women and girls.