Investigation into an online suicide discussion forum and its compliance with duties to protect its users from illegal content

In accordance with section 132 of the Online Safety Act 2023 (‘the Act’), we have today issued the provider of a suicide discussion forum with a Confirmation Decision in relation to its failure to comply with its duties under section 9(2), 10(2)(a), 10(3), 10(5), 20(2) (as it relates to section 20(3)), 21(2)(c) and 21(3) of the Act.

In light of this determination, Ofcom has imposed on the provider a single penalty of £950,000, to be paid by 12 June 2026. Ofcom has also directed the provider to comply with its duties by taking specified steps, as set out below, by 28 May 2026.

The Online Safety Act applies to the suicide forum
 
Ofcom has determined that the forum is a regulated user-to-user service with ‘links with the United Kingdom’ for the purposes of the Act. This is because:

• the service is capable of being used in the United Kingdom by individuals, including by registered users who can access the service from the UK without using a virtual private network (VPN) or other similar technology that may mask the user’s geographical location in the UK; and
• there are reasonable grounds to believe that user-generated content on the service presents a material risk of significant harm to individuals in the UK within the meaning of section 4(6) of the Act.

We have therefore determined that the provider remains subject to the illegal content duties in the Act as these apply in respect of illegal suicide content.

Our decision takes account of the fact that the forum implemented restrictions to prevent users with UK IP addresses from accessing the service from 1 July 2025 onwards (see our 13 October 2025 update below).

However, registered UK users can still access the service without use of a VPN or other similar technology, and we have therefore found that the provider has failed to comply, and is continuing to fail to comply, with duties in the Act relating to illegal content. We have also determined that it is appropriate in this case for Ofcom to impose a penalty and compliance steps on the provider as described below.  

Failure to comply with illegal content risk assessment duty in section 9(2) of the Act

Ofcom has determined that the provider has failed to comply with its duty under section 9(2) of the Act to carry out a suitable and sufficient illegal content risk assessment in respect of the suicide discussion forum, and that this failure is ongoing.

In respect of this failure, Ofcom has directed the provider to carry out a suitable and sufficient illegal content risk assessment in respect of the suicide discussion forum.

Failures to comply with illegal content safety duties in sections 10(2)(a),10(3) and 10(5) of the Act

Ofcom has determined that the provider has failed to comply with the following illegal content safety duties in section 10 of the Act and that these failures are ongoing:

• Its duty under section 10(2)(a) of the Act to take or use proportionate measures relating to the design or operation of the service to prevent individuals from encountering priority illegal content by the means of the service.
• Its duty under section 10(3) of the Act to operate a service using proportionate systems and processes to (a) minimise the length of time any priority illegal content is present and (b) where the provider is alerted or becomes aware of illegal content, swiftly take down such content.
• Its duty under section 10(5) of the Act to include provisions in the forum’s terms of service specifying how individuals are to be protected from illegal content, addressing each paragraph of section 10(3).

In respect of these failures, Ofcom has directed the provider to adopt the content moderation and terms of service measures recommended for all user-to-user services in ICU C1, ICU C2, ICU D7.2 (to the extent not implemented) and ICU G1.2(a) of Ofcom’s Illegal Content Codes of Practice for User-to-User services or appropriate alternative measures to comply with its duties.

Failures to comply with content reporting and complaints duties in section 20(2), 21(2)(c) and 21(3) of the Act

Ofcom has determined that the provider has failed to comply with the following content reporting and complaints duties, and that these failures are ongoing:

• Its duty under section 20(2) (as it relates to section 20(3)) of the Act to allow users and affected persons to easily report content which they consider to be illegal content.
• Its duty under section 21(2)(c) of the Act to operate a complaints procedure that is easy to access, easy to use (including by children) and transparent.
• Its duty under section 21(3) of the Act to include in its terms of service provisions which are easily accessible (including to children), specifying the policies and processes that govern the handling and resolution of complaints of a relevant kind.

In respect of these failures, Ofcom has directed the provider to adopt measures related to reporting, complaints and terms of service recommended in ICU D2 and ICU G1.2 (c) of Ofcom’s Illegal Content Codes of Practice for User-to-User services or appropriate alternative measures to comply with its duties. Ofcom has also directed the provider of the suicide discussion forum to inform us when and how it has complied with each of the above duties by 28 May 2026.

We consider the penalty amount of £950,000 is appropriate and proportionate to the non-compliance, having regard in particular to the seriousness of the contraventions and the risks of harm to individuals in the UK.

Next steps in the case

A non-confidential version of the Confirmation Decision will be published shortly.

In the most serious cases of non-compliance, where there is a continuing failure to comply with the Act, and where appropriate given the risks of harm to individuals in the UK, we can seek a court order to require third parties to take action to disrupt the business of the provider. This may require third parties to withdraw services from, or block access to, a regulated service in the UK.  

In this case, given the risk of significant harm to people in the UK from continuing non-compliance, we are preparing an application to the court for business disruption measures in the event that the provider does not now take the above steps to bring themselves into compliance.

Investigation into the provider of a suicide forum’s failure to comply with its illegal content risk assessment duty, illegal content safety duties, and content reporting and complaints duties

In accordance with section 130 of the Online Safety Act 2023, we have today issued the provider of a suicide forum with a provisional notice of contravention.

Ofcom considers that there are reasonable grounds for believing the provider has contravened:

• its duty to conduct a suitable and sufficient illegal content risk assessment in respect of the suicide forum, under section 9(2) of the Act;
  
  
• its illegal content safety duties to:

• • take or use proportionate measures to prevent individuals encountering priority illegal content, under section 10(2)(a) of the Act;
    
    
  • operate a service using proportionate systems and processes designed to minimise the length of time priority illegal content is present and swiftly take down illegal content when it is alerted to or becomes aware of it, under section 10(3) of the Act;
    
    
  • specify in its terms of service how individuals are to be protected from illegal content, under section 10(5) of the Act; and

• its duties relating to content reporting and complaints procedures in relation to illegal content under sections 20(2) (in respect of illegal content under section 20(3)), 21(2)(c) and 21(3) of the Act.

The notice explains how Ofcom has reached its provisional view and the actions we propose to take if the above breaches are confirmed. The provider of the suicide forum will now have a period of 10 working days to make representations to Ofcom, which will be carefully considered before we reach a final decision. 

We will provide further updates on the investigation in due course.

Ofcom has today (6 January 2026) informed the provider of this suicide forum that, having reviewed the available evidence, we are working towards issuing a provisional notice of contravention (‘Provisional Decision’) in relation to breaches of the Online Safety Act (‘the Act’). This is part of the legal process we must follow as part of any investigation. While no formal decision has yet been reached, we are working to issue this in the first quarter of this year. The provider will then have an opportunity to make representations on our Provisional Decision, as required by the Act.

Unless our concerns are fully addressed, we will consider using all of the powers available to us. These include imposing fines of up to £18m or 10% of qualifying worldwide revenue (whichever is greater). In the most serious cases of non-compliance, where there is a continuing failure to comply with the Act, and where appropriate given the risks of harm to individuals in the UK, we can seek a court order to require third parties to take action to disrupt the business of the provider. This may require third parties to withdraw services from, or block access to, a regulated service in the UK.  

As such, we have informed the provider of this forum that we would be prepared to make an application to the court for business disruption measures, where appropriate and proportionate, swiftly after the period for making representations on the Provisional Decision has elapsed, if any non-compliance we may identify in our Provisional Decision continues.

We will provide further updates on this investigation as soon as possible.

As stated in our 13 October update below, when considering a service's compliance with the Online Safety Act where it has restricted access for people with UK IP addresses, Ofcom will monitor the restrictions on a case-by-case basis to assess whether they are maintained consistently and to satisfy itself the service is not promoting ways of avoiding the access restrictions. 

If a service restricts access to people in the UK, we will take this into account when assessing whether enforcement action can be expected to result in further improvements in online safety for people in the UK, especially children.

In our 6 November 2025 update, we explained that we are progressing our enforcement investigation in this case as a priority, as we had reason to believe that the online suicide forum was available to UK users.

This update was based on evidence received from Samaritans, independently verified by Ofcom, that the service was directly available to users with UK IP addresses via a ‘mirror site’ with a different domain name, at least until 12.18 pm on 6 November 2025. We are now aware that this other domain also no longer appears to be accessible as of today. However, we are concerned that the forum’s block of UK users was not effective and/or was not consistently maintained and that similar issues may arise in the future. Therefore, we are continuing to progress our investigation as a priority.

We have been clear that we may continue to prioritise enforcement cases against service providers that do not consistently maintain access restrictions or who actively promote or encourage ways their UK users can avoid those restrictions. See: Protecting People in the UK from illegal content online: regardless of its origin. 

On 1 July 2025, the forum implemented a block to restrict users with UK IP addresses from accessing the service. Ofcom has been actively monitoring these restrictions to check they are maintained consistently and to make sure the service does not promote or encourage ways for UK users to avoid them.

We now have reason to believe, from evidence provided to us by Samaritans on 4 November 2025, that the service is available to UK users. We are therefore now progressing our investigation as a priority, and we aim to reach a conclusion as swiftly as we can. 

We will provide further updates on this investigation as soon as possible.

In response to our investigation opened on 9 April 2025, on 1 July 2025 the forum implemented a voluntary block to restrict users with UK IP addresses from accessing the service. Following further engagement with the service, it later removed messaging from the landing page for UK users that promoted ways to circumvent the block. Ofcom is clear that services who choose to block access by people in the UK must not encourage or promote ways to avoid these restrictions.

These restrictions have reduced the likelihood that people in the UK will be exposed to illegal or harmful content that may be present on the service, meaning safer online experiences for them.  We are actively monitoring these restrictions to check they are maintained consistently and to make sure that the service refrains from promoting or encouraging ways for UK users to avoid them. Depending on the outcome of our monitoring process, we may re-assess prioritisation of this case in line with our general approach to enforcement (set out below), including assessing whether continuing with this investigation is likely to result in further improvements in the online safety of people in the UK, particularly children.

Ofcom’s Online Safety Enforcement Guidance sets out how Ofcom will normally approach enforcement under the Online Safety Act 2023 (the ‘Act’) to support the achievement of its statutory objectives, including the adequate protection of UK citizens from harm presented by content on regulated services through the appropriate use by providers of regulated services of systems and processes designed to reduce the risks of such harm. We also have regard to the matters in section 3(3) of the Communications Act 2003, which include principles that our regulatory activities should be transparent, accountable, proportionate, consistent, and targeted only at cases in which action is needed.

Ofcom believes its flexible approach to risk assessment and mitigation allows services to take appropriate and proportionate steps to protect UK users from illegal content. Some services might seek to prevent people in the UK from accessing their sites, such as by restricting access from UK IP addresses, instead of taking steps to protect UK users when using their service. That is their choice.

When considering a service's compliance with the Act where it has restricted access for people with UK IP addresses, Ofcom will monitor the restrictions on a case-by-case basis to assess whether they are maintained consistently and to satisfy itself the service is not promoting ways of avoiding the access restrictions.  If a service restricts access to people in the UK, we will consider the presence of the restrictions when assessing whether enforcement action can be expected to result in further improvements in online safety for people in the UK, especially children.

For more information, see Ofcom, Protecting People in the UK from illegal content online: regardless of its origin.

As part of our investigation, the subject raised a Procedural Complaint with Ofcom. We are publishing our response to that complaint as an update to the investigation.

Procedural Officer Response (PDF, 210 KB)

Ofcom has today opened an investigation into the provider of an online suicide discussion forum. The investigation will consider the provider’s compliance with its duties under the Online Safety Act 2023 (‘the Act’).

All user-to-user and search services in scope of the Act were required to undertake an illegal content risk assessment by 16 March 2025. They were required to assess the risks of users encountering illegal content on their platforms, including priority illegal content (as defined in the Act) which amounts to the offence of intentionally encouraging or assisting the suicide (or attempted suicide) of another person.

In addition, Part 3 of the Act imposes duties on providers of regulated user-to-user services to take or use:

1. proportionate measures to effectively mitigate and manage:
   • the risk of the service being used for the commission or facilitation of a priority offence; and
   • the risks of harm to individuals.
2. proportionate systems and processes to:
   • prevent individuals from encountering priority illegal content; and
   • minimise the length of time for which any priority illegal content is present and to swiftly take down illegal content once they become aware of it; and
3. provisions in the terms of service specifying how individuals are to be protected from illegal content, apply those terms consistently and ensure the terms of service are clear and easily accessible.

At the same time, duties to use systems and processes to ensure users can easily report illegal content and make relevant complaints also started to apply to providers of Part 3 services. These ‘Illegal Content Duties’ came into effect on 17 March 2025.

Regulated user-to-user service providers can comply with the Illegal Content Duties by implementing measures recommended in Ofcom’s illegal content Codes of Practice for user-to-user services issued on 24 February 2025 (the ‘Codes of Practice’), or through alternative measures.

Investigation

The investigation follows an information notice that was sent to the service provider under the Risk Assessment Enforcement Programme and further correspondence with the service provider in respect of its duties under the Act. We have been clear that failure to adequately respond to our request for services to submit a record of their illegal content risk assessment may result in enforcement action and that, as soon as the duties took effect for providers, we would not hesitate to take action where we suspect there may be serious breaches which appears to pose a risk of very significant harm to UK users, and to children in particular.

Ofcom’s investigation will examine whether there are reasonable grounds to believe that the provider of the online suicide discussion forum has failed, or is failing, to comply with its duties to protect its users from illegal content, as well as the duty to respond accurately to an information notice sent under the Act.

We will provide an update on this investigation in due course. Ofcom’s Online Safety Enforcement Guidance sets out how Ofcom will normally approach enforcement under the Act. This includes our approach to information gathering and analysis and the procedural steps we must take to fairly determine the outcome of the investigation.

Where we identify compliance failures, we can impose fines of up to £18m or 10% of qualifying worldwide revenue (whichever is greater). In the most serious cases of non-compliance, and where appropriate given the risks of harm to individuals in the UK, we can seek a court order to require third parties to take action to disrupt the business of the provider. This may require third parties (such as providers of payment or advertising services, or Internet Service Providers) to withdraw services from, or block access to, a regulated service in the UK.