UK OSA Section 12(12) and Section 21(4)(e) - Proactive technology: terms-of-service information and complaints (with Section…
Be transparent about content moderation systems, including automated tools, human review, decision criteria, and moderation volumes, and inform users of automated decisions
Where this comes from
Provision: Section 12(12) and Section 21(4)(e) - Proactive technology: terms-of-service information and complaints (with Section 77 and Schedule 8 for transparency reporting)
Instrument: UK Online Safety Act 2023
Citation: Online Safety Act 2023, c. 50, s 12(12) (terms-of-service information about proactive technology used for children's safety compliance); s 21(4)(e) (complaints where proactive technology affected a user's content); s 72(4) (Category 1: terms written in sufficient detail and applied consistently); s 77 and Sch 8 (transparency reports on OFCOM notice - carried by UK-OSA-S64-TRANSPARENCY-REPORTS)
Text version: Online Safety Act 2023 c. 50, revised text as displayed on legislation.gov.uk on 2026-09-21 ('up to date with all changes known to be in force on or before 21 September 2026'), including the amendments made by the Crime and Policing Act 2026 in force from 29 June 2026 (S.I. 2026/689) and s 66 in force from 7 April 2026 (S.I. 2026/262). The as-enacted text is superseded.
Who it applies to
User-to-user service (any content surface) — any one of these:
- Service allows user-generated content
- Service enables direct messaging between users
…unless:
- Content moderation approach: No moderation
What engineering work it implies
Sample acceptance criteria Landfall generates for this obligation:
- Disclosure is accessible within 2 clicks from main navigation
- Content is written at appropriate reading level (8th grade for general, lower for kids)
- Disclosure includes: what data is collected, why, how long kept, who it's shared with
- Last updated date is visible on the disclosure
- Disclosure is available in all languages the product supports
Questions people ask
- Does UK OSA Section 12(12) and Section 21(4)(e) - Proactive technology: terms-of-s… apply to my service?
- It applies when at least one of: Service allows user-generated content; Service enables direct messaging between users. It does not apply where Content moderation approach: No moderation.
- From when does this apply?
- UK OSA Section 12(12) and Section 21(4)(e) - Proactive technology: terms-of-s… applies from 10 January 2024. Its current status is: in force.
Find out whether this one lands on you
Landfall's pre-scan answers the applicability question above for your product in minutes, then turns every obligation that applies into traceable engineering tickets with a citation chain your auditors can follow.
Not legal advice. Landfall maps regulatory obligations to engineering work for planning purposes. Its verdicts are not legal advice and create no attorney-client relationship — verify with qualified counsel before relying on them.