ComplianceGuidance18 Dec 2025UK
Ofcom sets out when AI chatbots fall under the Online Safety Act, and is investigating two
In force now
Ofcom's explainer of 18 Dec 2025 says a chatbot is in scope when it lets users share content with each other, searches the web, or generates pornography, which then needs highly effective age assurance. AI content shared on a user-to-user service counts as user content, and many standalone chatbots fall outside the Act. Ofcom opened investigations into X over Grok deepfakes on 12 Jan 2026 and into the AI companion Joi.com over age checks on 15 Jan 2026.
Document: Map each chatbot feature against the Act's user-to-user, search and pornography definitions, and put highly effective age checks in front of any sexual output.
Who it reaches
It reaches generative AI, user-to-user, search and 1 other service types with users in the UK, at any size. Chatbots with UK users that share user content, search the web or publish pornography.
Lands on Legal & Regulatory, Policy & Standards and Engineering.
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More under Online Safety Act
Not legal advice. Read the source.