How do UK laws (e.g., Online Safety Act) affect AI moderation by platforms like Chub.ai?

1. Legal scope and primary duties: AI content is in scope and treated like user content

Ofcom and legal advisers have confirmed that generative AI outputs and chatbots fall under the OSA’s duties in the same way as human‑created posts, meaning providers must have named accountability, systems to rapidly remove illegal content, and special measures to protect children from harmful material ^{[1] [2]}. The OSA contemplates that judgments about illegality can be made by humans, automated systems or a mixture of both, which explicitly brings AI moderation systems within the statutory frame ^[6].

2. Operational impacts: scale, accuracy and resource demands

To meet the OSA’s “highly effective” expectations for age verification and content moderation, platforms will need to deploy or buy advanced AI detection tools, expand moderation capacity and document risk‑assessments—creating a large market for AI safety tech and raising significant operational costs for smaller services ^{[7] [8]}. But automated tools are imperfect: industry analysts warn they will generate false positives and overblocking, and thus platforms must combine automation with human review and appeals processes to reduce harms from wrongful takedowns ^{[4] [9] [10]}.

3. Data protection and automated decision‑making tensions

The OSA’s encouragement of proactive, automated moderation intersects tightly with UK/EU data protection law: providers must balance scanning and profiling content (and sometimes private communications for safety) against GDPR principles and limits on solely automated decision making, requiring privacy‑by‑design, DPIAs and accuracy reviews ^{[6] [4]}. Regulators and advisers explicitly flag the delicate interplay between proactive safety scanning and user confidentiality—especially where end‑to‑end encryption would make compliance technically and legally complex ^[4].

4. Enforcement, transparency and accountability pressure from Ofcom

Ofcom has signalled active enforcement with transparency notices, risk assessments and named accountability requirements, and is already preparing to issue sector‑specific transparency obligations and to scrutinise child protection and illegal content controls as enforcement priorities in 2026 ^{[3] [11] [8]}. Platforms will be required to publish transparency reporting and respond to regulator queries; failure to comply can result in sanctions that create both reputational and financial risks ^{[5] [11]}.

5. Practical trade‑offs, market effects and critiques

The OSA has accelerated demand for AI‑driven safety services—valued in reporting at multi‑billion dollar levels—while critics warn the law risks overreach, surveillance creep and disproportionate overblocking if regulators and vendors rely too heavily on fallible automated classifiers ^{[7] [10]}. Civil‑society voices emphasise that criminalising AI‑generated CSAM and enforcing age verification are important but incomplete if platforms do not invest in detection, reporting and robust appeals mechanisms ^{[12] [13]}.

6. What platforms like Chub.ai must do next

An AI‑first platform must treat the OSA as an operational design constraint: designate an accountable officer, run and publish risk assessments, implement layered moderation (automated detection plus human review), ensure data‑protection compliance for automated decisions, create rapid takedown and appeals pathways, and prepare for Ofcom transparency notices and audits—actions repeatedly advised by legal and industry guidance ^{[1] [6] [8]}. Public reporting from major AI firms shows how platforms are already aligning processes—reviewing and removing illegal content, offering reporting channels and timetables for appeals—as a template but not a legal substitute for regulator‑driven obligations ^[13].