UK Online Safety Act and AI Chatbots

The Online Safety Act 2023 creates duties for providers of defined online services with a UK connection. Ofcom identifies three chatbot-relevant categories: user-to-user services that let people share content; search services enabling searches across more than one website or database; and services publishing pornographic content, which have age-assurance requirements. A chatbot can be covered by itself or as part of a larger platform. Ofcom describes a chatbot as potentially outside these categories when people interact only with the bot, it does not search multiple sites or databases, and it cannot generate pornography. This is a functional boundary, not a general exemption for products marketed as AI. In February 2026 Ofcom explained it could not investigate creation of illegal images by the standalone Grok chatbot under the Act’s current scope, while it separately examined X’s social platform and handling of content. Ofcom supports government consideration of possible changes, but discussion does not itself amend legislation. For covered services, obligations depend on service type and content. User-to-user and search providers have illegal-content risk-assessment and mitigation duties, along with applicable children’s safety requirements. AI material shared by users on a covered user-to-user service counts as user-generated content, whether created there or elsewhere. Pornography-publishing services must use highly effective age assurance. Ofcom enforces the Act; explanatory pages clarify statutory scope but do not expand it beyond the definitions Parliament enacted.