Industry S4 EP1: Fictional drama meets real world law

WARNING: This article contains spoilers about the Season 4 premiere of Industry.

The Season 4 premiere of the HBO and BBC drama series, Industry, wasted no time throwing its characters into the deep end of tech regulation and the commercial fallout. The show usually focuses on the financial sector and investment banking, and while that continues to be the common theme, the first episode of the latest season had an interesting focus for the lawyers among us, and one that is increasingly relevant for tech businesses today: compliance with the Online Safety Act; and the consequences of terminating a commercial contract without warning.

Online Safety

Early in the episode, “Siren”, a fictional pornography platform, finds itself under intense scrutiny with the introduction of the Online Safety Bill. The real Online Safety Bill was debated extensively throughout 2022 and was eventually passed into law in 2023 creating the Online Safety Act, the UK’s regulatory framework for online platforms aimed at reducing illegal and harmful content. The characters on Industry talk about regulatory pressure, looming enforcement, and the need to get ahead of the Online Safety regime. It’s a compelling narrative device, but how does it compare to the real obligations that UK platforms now face?

The show depicts characters considering imminent regulatory intervention, while Siren’s share price drops steadily as the bill is debated in Parliament. Siren's payment processor worries about its association with Siren, anticipating reputational damage both with government stakeholders and in the court of public opinion (given its ambition to be taken seriously as a competitor to large, global financial and wealth management institutions).

The actual Online Safety Act does impose significant duties on regulated platforms (i.e. for those providing search, user-to-user and pornography services), but the process is more structured and less sudden than the show suggests. Its rollout has been a phased process over the last year, and only now are we beginning to see some of the larger issues arising for these platforms.

Key obligations on regulated platforms include:

There is no outright ban on providing the regulated services governed by the Online Safety Act. However, the episode captures an important truth that many technology companies recognise: reputational and commercial pressure often hits long before regulators do. Investors, partners, and users increasingly expect platforms to demonstrate responsible content governance, and it is often this dynamic (rather than the letter of the law alone) which drives urgency.

That said, the legal consequences should not be underestimated. Ofcom has already begun exercising its enforcement powers under the Online Safety regime, with early regulatory focus directed in particular at failures to prevent children from accessing sexual content and failures to prevent CSAM.

Immediate Termination Rights

One of the episode’s sharper moments comes during an in-person meeting when Siren's payment processor, “Tender”, abruptly terminates its contract with Siren effective immediately. It’s a classic TV power move, but would it hold up in the real world?

The show depicts a unilateral instantaneous termination without reference to any notice period, breach allegations or contractual mechanisms. The closest thing to a legal justification appears to be reputational risk arising from Tender’s association with pornographic platforms, coupled with Siren’s perceived lack of commitment to age-verification processes under the Online Safety regime. This has immediate consequences for Siren as they will no longer be able to process any payments on their platform, not to mention the operational challenges of trying to switch to a new payment provider.

In commercial contracts, termination is rarely that simple. Most agreements include:

If Tender attempted to terminate without following the contract’s procedures, it could itself be in breach of contract, potentially exposing it to damages. However, if the agreement between the two contained:

then an immediate termination might be contractually justified.

The storyline reflects a real commercial risk, that regulatory issues can trigger contractual consequences. Many modern agreements include compliance-related termination rights, particularly where user safety, data protection, or platform integrity is involved. Businesses should ensure these clauses are clear, proportionate, and aligned with operational realities.

In theory, there is a risk a provider might terminate first and "let the lawyers fight for years" about it, as the Tender CFO states. While that may be legally possible in some cases (injunctive relief notwithstanding), in practice it would often be commercially damaging, particularly if other customers became aware of such conduct.

Closing Thoughts

Industry thrives on tension, and while the show takes creative licence, the underlying issues it highlights are real. The Online Safety Act is reshaping expectations for platforms, and commercial partners are increasingly sensitive to regulatory risk.

For businesses operating in this space, robust compliance and well-drafted contracts aren’t just legal necessities, they’re strategic safeguards.