United Kingdom: Office of Communications closes consultation on updated draft Illegal Content Codes of Practice for Search Services

On 20 October 2025, the Office of Communications (Ofcom) closes its consultation on the draft Illegal Content Codes of Practice for Search Services, which began on 30 June 2025. These codes introduce the Search moderation measure ICS C8 – Hash matching for intimate image abuse content, which mandates large general search services to implement perceptual hash matching technology to detect intimate image abuse content. The measure requires providers to analyse relevant content, defined as photographs, videos, or visual images encountered by United Kingdom users, using a suitable perceptual hash function and an appropriate set of hashes. Providers must review detected content, prioritising cases with higher likelihood of false positives, and ensure the technology balances precision and recall. The hashes must be sourced from verified databases or the provider’s own records, with regular updates and security measures to prevent unauthorised access. Safeguards for freedom of expression and privacy are integrated, including human review processes and alignment with complaints procedures under section 33 of the Online Safety Act 2023.