Explained: Ofcom Consultation on Online Safety
for Women and Girls
7 min read
'Making the online world safer for women and girls'
TL;DR: Ofcom has published draft guidance on how to meet your Online Safety Act obligations when it comes to the safety of women and girls, and they want your thoughts by 23rd May 2025.
Here's our overview of the guidance and how it might affect the video games industry. If you enjoy this article and want deeper analysis, tailored advice and support, or help writing a response or strategy, then get in touch – we’d be happy to discuss how Flux Digital Policy’s expertise can meet your needs. Even if you’re just curious about it all, we'd love to chat.
Why has Ofcom written this guidance?
The Online Safety Act makes tech companies legally responsible for protecting their users from illegal content and children from harmful content, with Ofcom appointed as the regulator. To help companies fulfil their responsibilities, the Act requires Ofcom to publish guidance and Codes of Practice that cover how services should keep their users safe, with specific guidance on addressing the illegal and harmful content that disproportionately affects women and girls.Consulting on the draft guidance is part of Phase 2 of Ofcom’s implementation of the Act.
Why should games companies get involved?
Most obviously, because the guidance forms part of the regulatory framework around the Online Safety Act – how you're expected to design and administer your services. Since you’re already required to address this type of content, the guidance will help you understand how to meet and exceed those standards. It’s therefore in your interest to ensure the guidance is clear and practical: this consultation is your chance to tell Ofcom if you think changes are needed.
However, this aspect of online safety is about more than just understanding compliance with the law – it's part of a wider industry issue that affects everyone.
The video games sector has an ongoing problem when it comes to the online safety of women and girls: sadly, research consistently shows that many women and girls are exposed to gendered abuse while gaming online. For some, this leads to disengagement with online gaming and feeling ostracised from a pastime and community that they used to enjoy; others might never start playing online or streaming, for fear of what they might encounter. This isn’t good for players, and it isn’t good for you.
No-one should be ok with their game becoming a platform for abuse and harm, where players feel unsafe in the world you have worked so hard to create. And, for those whose primary concern is the bottom line, alienating a whole demographic means fewer customers wanting to play your game. Either way, no-one should want to let the industry be tarnished by these risks of harm. Ofcom guidance on how to protect women and girls from online harm can provide the sector with the framework and tools to address these issues from within, but feedback from the companies who will actually use it is vital to making it effective.
Ofcom has set out their proposal and this is your opportunity to make it work for video games. For those of you who are already doing a great job, it’s also your chance to encourage others to step up by sharing your best practice. The result should be a guide that shows clear, feasible ways for games companies of all types to embed safe experiences so that all players feel welcome.
If you want to get involved, but you’re not sure how, then come and talk to us about how we can help.
What is Ofcom proposing?
At its heart, the guidance explains how companies can embed safety for women and girls in their services to meet their obligations under the Online Safety Act. It does not mandate any new requirements, but is set within the context of the recommended processes and actions that Ofcom has already set out in their Codes of Practice and risk assessment guidance. To encourage the tech industry to do more and achieve the best safety outcomes, it also provides practical examples of how to take this further than basic compliance.
Ofcom has taken a ‘safety-by-design' approach: the proposed actions are intended to form part of designing policies and services to prevent harm and proactively address it, rather than just reacting to harms that have already been enabled through the service.
The guidance sets out 9 actions under 3 headings:
Taking Responsibility
1
Ensure that governance and accountability processes address online gender- based harm.
2
Conduct risk assessments that focus on harms to women and girls.
3
Be transparent about women and girls’ online safety.
Preventing Harm
4
Conduct abusability evaluations and product testing.
5
Set safer defaults.
6
Reduce the circulation of online gender-based harm.
Supporting Women and Girls
7
Give users better control over their experiences.
8
Enable users who experience online gender-based harm to make reports.
9
Take appropriate action when online gender-based harm occurs.
For each action, the guidance sets out ‘foundational’ steps that companies can take, which give practical details on expectations that have already been set out through risk assessment guidance and the Codes of Practice on illegal content and protecting children. It also provides ‘good practice’ steps, which show how services can go above and beyond to further enhance the safety of women and girls on their platforms.
For example, Action 2 (risk assessments) explains that companies are already required to conduct risk assessments in relation to illegal and harmful content, which includes content and activities disproportionately affecting women and girls. The 'foundational’ steps give examples of how providers can ensure that such content is adequately considered, such as assessing a user base to understand what gender-based harms are likely to be more prevalent. The ‘good practice’ steps explain how this can be enhanced by using external assessors with specific expertise, engaging with victims, and surveying users, to understand more deeply how a service might carry specific risks for women and girls.
In early 2027, Ofcom intends to publish an assessment of how providers are keeping women and girls safe on their services, which will include a view on how providers are using the guidance. Although Ofcom strongly encourages companies to take ‘good practice’ steps wherever they can, there are no specific obligations on companies to do so. However, it's pretty likely that they will take a dim view of providers (especially the largest companies) who are able to take the ‘good practice’ steps but decide not to.
What's the consultation for?
Ofcom is asking all interested parties for their feedback on the guidance, including whether they have taken the right approach, and for further examples of good practice.
They are not asking for feedback on the ‘foundational’ steps, as these are based on parts of the Codes of Practice and other pieces of guidance that have already been the subject of their own consultation process.
How can Flux help me?
Tech regulation is undergoing big changes, which means that many companies are finding for the first time that they want to take part in the process or that they need to up their current engagement. The sheer variety of business models and services in the video games industry means that it’s really important for all voices to be heard, from the biggest to the smallest and from mobile, to console and desktop.
Regardless of your size, reach or platform, Flux can help you understand what changes are happening, how the process works, and what it means for you in practice. We can work with you to prepare a response to consultations like this, and we can look at what else might be coming down the track.
If you already have an embedded public policy strategy or team, but you want additional support on this (or any other) issue, then we can help with that too. Our team has experience leading on sector-wide policy campaigns and individual public affairs strategies, so let us know what you need and we’ll take it from there.
Author: Dr Celia Pontin, Director of Policy and Public Affairs