In 2025, it’s not a hot take to state that the internet is integral to all our lives. Put bluntly - it is something that we now cannot do without: we use it to pay our bills, freely access information from all over the world, find communities and stay connected. Yet for women and girls this same internet can be an equally hostile and even dangerous place. Women and girls are regularly receiving misogynistic abuse online, suffering deepfake image abuse or even being manipulated in the context of coercive behaviour within an intimate relationship.
It’s therefore no surprise that making the internet a safer place for women and girls has been a long-standing priority for Ofcom as it implements the Online Safety Act (OSA). Today, it moves one-step closer to realising this important goal, proposing draft guidance for ‘a safer life online for women and girls’ as part of its OSA consultation process.
What’s been published?
The main documents published include a detailed document on how Ofcom will undertake and feedback on this consultation. It also includes the key draft guidance setting out the measures that online service providers need to implement to protect women and girls. The guidance is helpfully available “at a glance” and in more detail. At its core, online service providers such as social media, gaming, dating apps, discussion forums and search engines (amongst others) will have responsibilities to assess the risk of gender-based illegal harms and then swiftly respond to these harms by taking down illegal content as soon as they become aware of it. Providers must also protect children from harmful material, such as abusive, hateful, violent and pornographic content.
What are online gender-based harms?
The consultation focuses on 4 key issues throughout:
- Online misogyny - i.e., cracking down on content which encourages misogynistic ideas.
- Pile-ons and online harassment - especially in fields where women are particularly targeted e.g., women journalists and politicians.
- Online domestic abuse - where technology is manipulated to perpetuate domestic violence and coercive control.
- Intimate image abuse - including through revenge porn, deepfakes and cyberflashing.
Taking responsibility: What concrete measures should providers actually implement?
Ofcom has divided the concrete measures that should be implemented into: (1) “foundational measures” and (2) “good practice steps”. Foundational measures are those which if adopted will be treated as evidence of complying with the relevant legal duties under the OSA. Good practice steps include additional ways providers could improve women and girls’ online safety. Providers can think of the foundational measures as “must-haves” while the good practice steps are in the “nice-to-have” territory.
The guidance goes on to identify nine areas where technology firms should take practical steps to improve women and girls’ online safety, highlighting a “safety-by-design” approach. Examples of the relevant measures include:
- Implementing technologies which prevent intimate abuse e.g., by removing non-consensual images based on databases.
- More control over user accounts e.g., by implementing greater account security, removing geolocation by default and allowing for the bundling of default settings to make it easier for women experiencing pile-on harassment to protect their accounts with one selection.
- Abusability testing to identify how a service or feature could potentially be exploited by a harasser or malicious user.
It is great to see careful consideration of the unique challenges that women and girls face disproportionately online - and this is reflected in a glossary, which defines various important concepts that are key to gendered harassment online, including cyberflashing, deepfakes, doxing, gaslighting and gendered disinformation. There is also specific consideration of the intersection between new technologies such as generative AI and the issues women face e.g., where consensually taken images may be manipulated using generative AI to create non-consensual images.
Ofcom is now inviting feedback on the draft Guidance, which must be submitted by 23 May 2025. Once Ofcom has examined all the responses, it will publish a statement with its decisions and final guidance later this year.
It will be interesting to see how Ofcom approaches enforcement in this particularly sensitive area - especially given the high-profile campaigns recently seen from celebrities such as Cally Jane Beech, Zara McDermott and Georgia Harrison, who all suffered horrific abuse through the perpetuation of deepfakes and/or revenge porn against them. The tone that Ofcom has taken has been particularly strong with Melanie Dawes (CEO) noting that the proposed measures are not “rocket-science” and that Ofcom intends to transparently report on how well leading online service providers have tackled harms to women and girls around 18 months after the final guidance comes into effect. This means that users can clearly “vote with their feet” against online service providers that do not take this area of safety seriously.