Ofcom's Additional Duties for Category 1 Services: What Tech Companies Need to Know

Category 1 status is based on thresholds set by Government in secondary legislation, either 34 million UK users combined with a content recommender system, or 7 million UK users combined with a recommender system and content-forwarding functionality. The newly published Register confirms Category 1 services include Facebook, Instagram, Snapchat, TikTok, YouTube, X, WhatsApp, Roblox, Reddit, Pinterest and Quora.

These platforms already carry duties under the Illegal Content and Protection of Children codes. The Additional Duties consultation adds a further, distinct layer on top.

What is being proposed?

Ofcom has structured its proposals across four volumes, totaling 19 draft Code measures.

User empowerment and identity verification. Category 1 services will need to assess how likely adult users are to encounter certain categories of content, defined in the Act as content promoting suicide or self-harm, content promoting eating disorders, and content inciting hatred or abuse, and offer tools to manage exposure to it. Proposed measures include letting users choose not to encounter this content, choose instead to be alerted to its presence, and report it, alongside broader controls like blocking, muting and disabling comments that apply regardless of content type. Providers will also need to offer optional identity verification for adult users, guided by four principles Ofcom is calling relevance, reliability, inclusivity and clarity, and a filter tool letting verified users limit interaction with non-verified accounts. Critically, none of this requires users to verify their identity or use these tools, the duty is to offer the choice, not to mandate participation.

News publisher content, journalism, and democratic importance. Platforms will need processes to identify recognised news publishers and their content and can't take action against that content without notifying the publisher and allowing a response first, with limited exceptions. A parallel set of measures covers journalistic content and content of democratic importance more broadly, internal moderation policies, staff and volunteer training, an expedited complaints route for journalistic content, and a requirement for providers to actively review their own appeals data for evidence of inconsistent treatment across political viewpoints.

Terms of service and complaints. Category 1 providers will need to include specific provisions in their terms of service covering user empowerment, journalistic content, democratic content and complaints, written and presented in a genuinely clear and accessible way. Complaints systems will need to specifically handle complaints about non-compliance with these duties, not just content complaints, and be easy to find, use, and act on.

Providers will also be required to publish assessments of how their safety measures affect freedom of expression and privacy, including impacts on news and journalistic content, as a standing transparency obligation.

Why it matters

For platforms already compliant with the Illegal Content and Protection of Children codes, there's a natural starting point, Ofcom has deliberately aligned definitions and risk assessment structures across all three regimes for consistency. But this is a genuinely new layer of obligation, not an extension of existing compliance to work.

Two elements stand out as the most novel, and the most likely to generate real implementation questions: the non-verified user filter tool, and optional identity verification.

For the filter tool, Ofcom isn't prescribing which functionalities it must apply to. Instead, providers decide for themselves, weighing user safety benefit against the risk of materially interfering with the core service. For identity verification, providers design their own schemes rather than following a single prescribed model, guided only by Ofcom's four principles.

In both cases, Ofcom has deliberately given providers flexibility rather than a fixed rulebook. That's helpful in principle, but it also means the detail of implementation is still very much up for debate, which is exactly what this consultation is for.

Having your say:

The consultation closes on 2 October 2026, with final decisions expected in 2027. Given the breadth of what's proposed, engaging early, and with evidence, is likely to matter more here. techUK members are encouraged to contact [email protected] to feed into techUK’s response.

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