Summary

  • Ofcom recommends elevating body-stigma and depression content into the section 62 priority list.
  • COST measured these non-designated categories only after child-safety duties began, so they lack a pre-duty baseline.

The proposal comes with an awkward calendar. Ofcom’s Children’s Online Safety Tracker (COST) began in March–April 2025, before the child-safety duties took effect on 25 July. Wave 1 measured priority and primary-priority content. It did not ask about non-designated content (NDC), including the two categories now proposed for elevation. The tracker added NDC questions in Wave 2, in November–December 2025. Wave 3 followed in March–April 2026. That gives Ofcom post-duty observations, but no pre-duty COST baseline for body-stigma or depression content.

The distinction matters: a series that starts after a rule takes effect can describe what followed; it cannot show what the same measure would have recorded before the rule. The report’s clearest number is specific. In Wave 3, 42% of 11–17-year-olds said they had encountered body-stigma content during the previous four weeks. Ofcom reports no significant change in that category between Waves 2 and 3, and no significant overall change in reported incidence or severity of harmful-content exposure during the first nine months of the duties. That is evidence of continuing exposure, not a before-and-after estimate of the duties’ effect.

The samples also changed: COST Module 2 included 1,396 respondents aged 11–17 in Wave 1, 1,625 in Wave 2 and 865 in Wave 3. The survey records young people’s reported exposure over recall periods; it is not a census of everything services carried. Ofcom says information supplied by six services covers material they detected and actioned, so those records cannot directly measure total incidence. Section 63 gives Ofcom a reporting and recommending role. Section 62 contains the statutory priority-content list; section 219 gives the Secretary of State power to amend it by regulations. Ofcom’s report asks for two additions.

The list has not changed merely because the report was published. Ofcom says it will update its regulatory material if the Secretary of State decides to amend the list.

Sources