Jurisdiction(s):
European Union

Standalone AI chatbots in the UK and EU: child-safety scope under OSA 2023/DSA, Ofcom and Irish oversight, Italy’s consent rule, voluntary safeguards and litigation risk

Published on: 24 September 2025

Published by an LexisNexis EU Law expert

Legal News

Article summary

AI chatbots such as OpenAI’s ChatGPT and the Google-backed Character.AI are moving into the child safety spotlight

Having until now largely slipped through the cracks of Europe’s content‑moderation laws, standalone AI chatbots are edging into the child safety spotlight. The EU’s DSA has trained its gaze on online platform operators such as social media and pornography sites, while the UK’s OSA 2023 is framed around user‑to‑user and search services, plus pornography platforms — leaving chatbots outside platform ecosystems in a regulatory grey area.

In the US, the issue has already broken into public view, with parents alleging serious harms to children from chatbot exchanges, spurring:

a congressional debate on 16 September 2025;
a US Federal Trade Commission investigation the week before; and
several lawsuits against providers over the preceding months.

That intensity of scrutiny is prompting European questions about how online moderation rulebooks should encompass AI chatbots. Providers themselves seem to be shifting too, though not obviously in response to enforcement: OpenAI’s 16 September 2025 statement unveiling a package of teen‑safety changes introduced the week prior did not reference regulatory requirements in any specific jurisdiction...

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