Ofcom's disinformation advisers admit no law defines their own report's purpose. They still use it to flag a voting-age gap in online safety law that two peers are trying to close this week.
Estimated reading time: 6 minutes
In short. On 13 October 2026, Ofcom's Online Information Advisory Committee published its first report under section 152(5) of the Online Safety Act, a duty to report "within the period of 18 months after being established" [[1]][[2]]. The report's own second page states: "The Act does not specify the purpose, content, or audience of the report" [[1]]. No section of the Act, and nothing in the report, says who checks whether a report that size, on those topics, with that audience, actually satisfies the duty. Three pages later, having quoted four footnoted warnings about disinformation from the Rycroft Review, the Chief of MI6, the Chief of Defence Staff and the former Director General of MI5, the Committee adds one claim of its own with no footnote at all: that "many claims" attributing disinformation to hostile states rest on "flimsy evidence" [[1]]. It names none. Separately, the report is right about something real: a "risk of incoherence in the statute book" between lowering the voting age to 16 and the OSA's child-safety duties, which it says Parliament has "an opportunity" to fix in the Representation of the People Bill [[1]]. That Bill is in Lords Committee stage this week, with two backbench amendments tabled on exactly this point, both still undecided [[3]][[4]]. Two documented mistakes: four stars.
Ofcom did not choose to have an Online Information Advisory Committee. Parliament built one into the Online Safety Act, a standing committee on disinformation and misinformation that Ofcom's enabling legislation requires it to appoint and consult, with members serving as individuals rather than representatives of any organisation [[2]][[1]]. The Act also requires the Committee to publish a report within 18 months of being established, then periodic reports after that [[2]]. First meeting: 16 May 2025 [[5]]. First report: 13 October 2026, comfortably inside the window [[1]]. On timing, the Committee has nothing to answer for. On what the report actually contains, it is more exposed than it needed to be.
A statutory duty with no stated test for meeting it
The report's own "About this report" section does not hedge: "The Act does not specify the purpose, content, or audience of the report. However, the Committee has a specific role prescribed by the Act and this report reflects that role. We stress that this is not a general report on disinformation and misinformation as they affect the UK, or on the OSA" [[1]]. That is the Committee explaining, in its own words, that it has written 14 pages to satisfy a legal duty whose content requirements Parliament never specified, and then narrowing its own brief further by ruling out the general-interest version of the report a reader might expect. Section 152(5) of the Act itself is a single sentence: "The committee must publish a report within the period of 18 months after being established, and after that must publish periodic reports" [[2]]. No subsection sets a minimum length, a required scope, a named recipient, or a reviewing body. Nothing in the Online Safety Act gives Ofcom, Parliament or anyone else a defined basis to say a future report fell short. The duty is self-certifying.
An unfootnoted claim sitting next to four footnoted ones
Before explaining Ofcom's actual legal powers over disinformation, the report spends a page assembling the case for why the subject matters, quoting in sequence: the Rycroft Review's finding that "we are, indeed, already experiencing 'information warfare'" [[1]]; the Chief of the Secret Intelligence Service's description of operating in "a space between peace and war" [[1]]; a warning from the Chief of Defence Staff [[1]]; and a 2024 warning from the then-Director General of MI5 [[1]]. Each carries a numbered footnote to its source. The very next paragraph adds: "We recognise that informed public debate is complicated by the amount of low-quality research and analysis in this area, and in particular analysis which seeks to attribute disinformation and misinformation activity to hostile state actors based on flimsy evidence. The threat is real, but many claims made about it are not" [[1]]. That sentence carries no footnote, no named example and no citation, the only unsupported factual claim in an otherwise heavily referenced passage, sitting directly beneath four claims the Committee has just taken at face value from exactly the kind of high-authority sources that would be hardest to subject to the scrutiny it is recommending for everyone else.
The claims, tested
| The report's own words | What the evidence shows | Verdict |
|---|---|---|
| "The Act does not specify the purpose, content, or audience of the report" (p.2) [[1]] | Section 152(5) OSA is a single sentence requiring a report within 18 months, with no content, scope or review requirement attached [[2]] | Confirmed in the Act's own text; the duty is genuinely self-certifying, with no body given a role in checking what the report should contain |
| "Analysis which seeks to attribute disinformation and misinformation activity to hostile state actors based on flimsy evidence. The threat is real, but many claims made about it are not" (p.5) [[1]] | The same page footnotes four other claims (Rycroft Review, MI6, Chief of Defence Staff, former MI5 Director General) individually to their sources; this sentence cites none and names no example [[1]] | The one unsupported assertion in a page built entirely from attributed sources, applying no evidentiary test to the warnings it has just quoted |
| "A risk of incoherence in the statute book... There is an opportunity for Parliament to address this during the passage of the Representation of the People Bill" (p.13) [[1]] | The Bill is in Lords Committee stage, sittings 2 and 4 November 2026; two tabled amendments (33, 39) address the exact OSA child-safety/voting-age overlap, both marked "No decision" [[3]][[4]] | Accurate and current: the opportunity the report names is live this week, though resolved by neither government amendment nor decision so far |
The gap it is right about
Section 214A of the OSA gives the Secretary of State power to make regulations requiring internet services to restrict access by a "relevant child", defined only as "a child who is of, or under, a specified age" [[6]]. The Representation of the People Bill, now at Lords Committee stage, extends the parliamentary vote to 16- and 17-year-olds [[3]]. Put those together and a 16-year-old registered to vote can, depending on how a future regulation under section 214A sets its age threshold, simultaneously be treated by election law as old enough to choose a government and by online safety law as a child to be restricted from seeing content about that choice. The Committee's report flags exactly this: "a risk of incoherence in the statute book where the planned legislation to lower the voting age to 16 will connect with the child safety duties in the OSA" [[1]]. The Lords' own marshalled list for Committee, published 29 October 2026, shows the point has not gone unnoticed: Lord Fuller's amendment 39 would carve registered teenage voters out of the section 214A "relevant child" definition specifically for election-related content, and Lord Udny-Lister's amendment 33 would require the Secretary of State to publish, within eight months of Royal Assent, an assessment of how susceptible 16- and 17-year-olds are to election disinformation and foreign interference [[4]]. Both are listed with the decision status "The House has not considered this amendment" as of this week [[4]]. Neither carries government sponsorship. The report could not have known about either amendment when it published on 13 October, three weeks before they were tabled, so this is not a mistake on the Committee's part. It is simply where things stand: a gap correctly identified, a fix attempted by two backbenchers, and a bill still in committee.
Credit where due
The incoherence finding holds up entirely: checked directly against the Bill's current Lords stage and its marshalled amendment list, the Committee named a real, unresolved legislative collision, and named the right vehicle for fixing it. The report is also candid rather than evasive about its own limits: rather than padding out a report Parliament gave it no template for, it says plainly that it is not attempting a general account of disinformation in the UK, and sticks to that. Its account of Ofcom's own powers, that Ofcom "does not have any direct powers to require companies to act on misinformation or disinformation as they are not defined as illegal content" under the Act, is a straightforward and accurate statement of the regulator's actual remit, not an overstatement of what the Committee or Ofcom can do [[1]].
Verdict
Two documented mistakes, four stars. A committee Parliament built into law, discharging a duty Parliament wrote so loosely that the committee itself has to say so on page two, is a design problem in the Online Safety Act more than a failure by the people appointed to it. But a report that opens by admitting it has no defined yardstick, and then makes its single least-supported claim a swipe at other people's evidence standards, has earned both documented findings.
The star score counts two documented mistakes: (1) the report states (p.2) that the Online Safety Act does not specify the purpose, content or audience of its own mandatory section 152(5) report, and no provision in the Act gives any body a role in checking whether a report meets any standard; (2) the report asserts (p.5, unfootnoted) that "many claims" attributing disinformation to hostile states rest on "flimsy evidence", directly beneath four footnoted national-security warnings it has just quoted without applying that same test to any of them or naming a single example. Two falls in the 1 to 3 band: four stars; the bands are on the ratings page. This piece makes no finding about the competence or motives of any named Committee member, MI6 officer, military officer or peer; the criticism is of a statutory duty's drafting and of one unsupported sentence in the report, not of any person's conduct. Checked directly against the report PDF, the Online Safety Act's text, and Parliament's Bills API and Lords marshalled list, each fetched 2 November 2026.
Sources
- Report of the Online Information Advisory Committee, October 2026, Online Information Advisory Committee, published 13 October 2026
- Section 152, Online Safety Act 2023, legislation.gov.uk
- Representation of the People Bill, UK Parliament Bills, current stage: Lords Committee stage (sittings 2 and 4 November 2026)
- HL Bill 47-I Marshalled list for Committee, House of Lords, published 29 October 2026
- Online Information Advisory Committee, Ofcom
- Section 214A, Online Safety Act 2023, legislation.gov.uk