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United Kingdom

UK–EU online safety comparator: OSA 2023 and EU DSA—scope, service categorisation, risk assessments, child protection, content moderation, transparency, enforcement and sanctions

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Practice notes
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This Practice Note offers a concise overview of the principal points of comparison between the UK and EU online safety regimes. In particular, it sets side-by-side the regulatory frameworks of the Online Safety Act 2023 (OSA 2023) and Regulation (EU) 2022/2065, the EU Digital Services Act (EU DSA), examining their scope, the obligations they impose, and the potential penalties for breach.

Background

Online spaces increasingly face threats including misinformation and harmful material, heightening risks to users, especially vulnerable audiences such as children. To safeguard people on the internet and foster a more secure digital ecosystem, both the UK and the EU have introduced laws to govern online services: the OSA 2023 and the EU DSA. The OSA 2023 establishes risk-based duties of care that service providers are required to meet. The EU DSA mirrors this philosophy, setting out a framework aimed at keeping users of online services safe and upholding their fundamental rights, while delineating responsibilities for businesses operating online...

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Web page updated on 21/05/2026

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