United Kingdom: Office of Communications released updated guidance on file-storage and file-sharing services under Online Safety Act

On 10 December 2025, the Office of Communications (Ofcom) released updated guidance on file-storage and file-sharing services under the Online Safety Act, setting out how the Online Safety Act applies to file-storage and file-sharing services with links to the UK that qualify as a user-to-user service. The guidance explains that providers are legally responsible for assessing and mitigating risks of illegal content and content harmful to children, including terrorism content, child sexual exploitation and abuse (CSEA) content, and intimate image abuse, as identified in the Register of Risks. It requires providers to carry out illegal content risk assessments, children’s access and risk assessments where applicable, implement protections, and comply with record-keeping and review duties. The guidance confirms expectations to follow the Illegal Content Codes of Practice, including the use of perceptual hash-matching technology for high-risk services to detect and remove image-based CSAM. It also notes forthcoming reporting requirements to the National Crime Agency (NCA) for detected CSEA content from Spring 2026 and outlines safeguards for privacy, freedom of expression, human review, appeals, and data protection compliance.