The EU’s Digital Services Act and UK Online Safety Act: where are we now?

2025 will see online service providers across the EU and UK continue to grapple with greater regulatory scrutiny, with new obligations either in force or due to apply imminently, all aimed at tackling illegal content and risk on their services.

The Digital Services Act (or ‘DSA’), the EU regulation which imposes far reaching obligations on providers of online intermediary services, has now been fully in force for over a year. In that time, the Commission has not been shy to exercise its powers, issuing numerous tech companies with requests for information and opening formal investigations into suspected non-compliance.

Meanwhile, in the UK, Ofcom is moving at pace to bring a similar regime – the Online Safety Act (‘OSA’) – into force with effect from 17 March 2025. 

In this briefing, we provide a recap of the DSA and explore the Commission’s recent enforcement action. We also look at how the OSA compares to the DSA, and outline the steps Ofcom is taking to implement the UK’s online safety regime. As we will explain, although the two Acts have similar objectives, the approaches taken by the EU and UK have significant differences – compliance with one will not guarantee compliance with the other.