Investigation into an online suicide discussion forum and its compliance with duties to protect its users from illegal content

Published: 9 April 2025
Last updated: 7 November 2025

Open

Investigation into

The provider of an online suicide discussion forum. Due to its nature, we have decided not to name the provider and forum.

Case opened

9 April 2025

Summary

We are investigating whether a provider of an online suicide discussion forum has failed/is failing to comply with its duties under the Online Safety Act 2023 to:

  • adequately respond to a statutory information request;
  • complete and keep a record of a suitable and sufficient illegal content risk assessment; and
  • comply with the safety duties about illegal content, the duties relating to content reporting and duties about complaints procedures, which apply in relation to regulated user-to-user services.
Relevant legal provision(s)

Sections 9, 10, 20, 21, 23 and 102(8) of the Online Safety Act 2023.

As stated in our 13 October update below, when considering a service's compliance with the Online Safety Act where it has restricted access for people with UK IP addresses, Ofcom will monitor the restrictions on a case-by-case basis to assess whether they are maintained consistently and to satisfy itself the service is not promoting ways of avoiding the access restrictions. 

If a service restricts access to people in the UK, we will take this into account when assessing whether enforcement action can be expected to result in further improvements in online safety for people in the UK, especially children.

In our 6 November 2025 update, we explained that we are progressing our enforcement investigation in this case as a priority, as we had reason to believe that the online suicide forum was available to UK users.

This update was based on evidence received from Samaritans, independently verified by Ofcom, that the service was directly available to users with UK IP addresses via a ‘mirror site’ with a different domain name, at least until 12.18 pm on 6 November 2025. We are now aware that this other domain also no longer appears to be accessible as of today. However, we are concerned that the forum’s block of UK users was not effective and/or was not consistently maintained and that similar issues may arise in the future. Therefore, we are continuing to progress our investigation as a priority.

We have been clear that we may continue to prioritise enforcement cases against service providers that do not consistently maintain access restrictions or who actively promote or encourage ways their UK users can avoid those restrictions. See: Protecting People in the UK from illegal content online: regardless of its origin

On 1 July 2025, the forum implemented a block to restrict users with UK IP addresses from accessing the service. Ofcom has been actively monitoring these restrictions to check they are maintained consistently and to make sure the service does not promote or encourage ways for UK users to avoid them.

We now have reason to believe, from evidence provided to us by Samaritans on 4 November 2025, that the service is available to UK users. We are therefore now progressing our investigation as a priority, and we aim to reach a conclusion as swiftly as we can. 

We will provide further updates on this investigation as soon as possible.

In response to our investigation opened on 9 April 2025, on 1 July 2025 the forum implemented a voluntary block to restrict users with UK IP addresses from accessing the service. Following further engagement with the service, it later removed messaging from the landing page for UK users that promoted ways to circumvent the block. Ofcom is clear that services who choose to block access by people in the UK must not encourage or promote ways to avoid these restrictions.

These restrictions have reduced the likelihood that people in the UK will be exposed to illegal or harmful content that may be present on the service, meaning safer online experiences for them.  We are actively monitoring these restrictions to check they are maintained consistently and to make sure that the service refrains from promoting or encouraging ways for UK users to avoid them. Depending on the outcome of our monitoring process, we may re-assess prioritisation of this case in line with our general approach to enforcement (set out below), including assessing whether continuing with this investigation is likely to result in further improvements in the online safety of people in the UK, particularly children.

Ofcom’s Online Safety Enforcement Guidance sets out how Ofcom will normally approach enforcement under the Online Safety Act 2023 (the ‘Act’) to support the achievement of its statutory objectives, including the adequate protection of UK citizens from harm presented by content on regulated services through the appropriate use by providers of regulated services of systems and processes designed to reduce the risks of such harm. We also have regard to the matters in section 3(3) of the Communications Act 2003, which include principles that our regulatory activities should be transparent, accountable, proportionate, consistent, and targeted only at cases in which action is needed.

Ofcom believes its flexible approach to risk assessment and mitigation allows services to take appropriate and proportionate steps to protect UK users from illegal content. Some services might seek to prevent people in the UK from accessing their sites, such as by restricting access from UK IP addresses, instead of taking steps to protect UK users when using their service. That is their choice.

When considering a service's compliance with the Act where it has restricted access for people with UK IP addresses, Ofcom will monitor the restrictions on a case-by-case basis to assess whether they are maintained consistently and to satisfy itself the service is not promoting ways of avoiding the access restrictions.  If a service restricts access to people in the UK, we will consider the presence of the restrictions when assessing whether enforcement action can be expected to result in further improvements in online safety for people in the UK, especially children.

For more information, see Ofcom, Protecting People in the UK from illegal content online: regardless of its origin.

As part of our investigation, the subject raised a Procedural Complaint with Ofcom. We are publishing our response to that complaint as an update to the investigation.

Procedural Officer Response (PDF, 210 KB)

Ofcom has today opened an investigation into the provider of an online suicide discussion forum. The investigation will consider the provider’s compliance with its duties under the Online Safety Act 2023 (‘the Act’).

All user-to-user and search services in scope of the Act were required to undertake an illegal content risk assessment by 16 March 2025. They were required to assess the risks of users encountering illegal content on their platforms, including priority illegal content (as defined in the Act) which amounts to the offence of intentionally encouraging or assisting the suicide (or attempted suicide) of another person.

In addition, Part 3 of the Act imposes duties on providers of regulated user-to-user services to take or use:

  1. proportionate measures to effectively mitigate and manage:
    • the risk of the service being used for the commission or facilitation of a priority offence; and
    • the risks of harm to individuals.
  2. proportionate systems and processes to:
    • prevent individuals from encountering priority illegal content; and
    • minimise the length of time for which any priority illegal content is present and to swiftly take down illegal content once they become aware of it; and
  3. provisions in the terms of service specifying how individuals are to be protected from illegal content, apply those terms consistently and ensure the terms of service are clear and easily accessible.

At the same time, duties to use systems and processes to ensure users can easily report illegal content and make relevant complaints also started to apply to providers of Part 3 services. These ‘Illegal Content Duties’ came into effect on 17 March 2025.

Regulated user-to-user service providers can comply with the Illegal Content Duties by implementing measures recommended in Ofcom’s illegal content Codes of Practice for user-to-user services issued on 24 February 2025 (the ‘Codes of Practice’), or through alternative measures.

Investigation

The investigation follows an information notice that was sent to the service provider under the Risk Assessment Enforcement Programme and further correspondence with the service provider in respect of its duties under the Act. We have been clear that failure to adequately respond to our request for services to submit a record of their illegal content risk assessment may result in enforcement action and that, as soon as the duties took effect for providers, we would not hesitate to take action where we suspect there may be serious breaches which appears to pose a risk of very significant harm to UK users, and to children in particular.

Ofcom’s investigation will examine whether there are reasonable grounds to believe that the provider of the online suicide discussion forum has failed, or is failing, to comply with its duties to protect its users from illegal content, as well as the duty to respond accurately to an information notice sent under the Act.

We will provide an update on this investigation in due course. Ofcom’s Online Safety Enforcement Guidance sets out how Ofcom will normally approach enforcement under the Act. This includes our approach to information gathering and analysis and the procedural steps we must take to fairly determine the outcome of the investigation.

Where we identify compliance failures, we can impose fines of up to £18m or 10% of qualifying worldwide revenue (whichever is greater). In the most serious cases of non-compliance, and where appropriate given the risks of harm to individuals in the UK, we can seek a court order to require third parties to take action to disrupt the business of the provider. This may require third parties (such as providers of payment or advertising services, or Internet Service Providers) to withdraw services from, or block access to, a regulated service in the UK.


Case reference

CW/01293/04/25