Ofcom commissioned a 30-person study, then told readers not to treat it as proof its online safety tools work. Its own consultation on mandatory user empowerment duties cites that study anyway.
Estimated reading time: 7 minutes
.jpg){kind=link}
In short. Ofcom commissioned a qualitative study of 30 adults' experiences of suicide, self-harm and eating disorder content, and that report states on page 8 that "perceptions of online safety tools and features should not be seen as a validation of technical feasibility, proportionality or effectiveness of these" [2]. Ofcom's own consultation on mandatory user empowerment duties for Category 1 services cites that same study, by name, as evidence that encountering this content "can have negative impacts" (Volume 2, paragraph 3.7, page 5) [4], immediately before setting out the tools and Code measures that evidence is said to support. Three documented mistakes: four stars.
On 17 September 2026, Ofcom published a page summarising "three pieces of research" into how adults encounter distressing content online, and said plainly what the research was for: "these insights have contributed to our evidence base and helped to inform our policy development for our recent consultation, Giving users more choice, control and trust in their online experience" [1]. That consultation, on mandatory user empowerment and identity verification duties for the UK's biggest online services, closed on 2 October 2026 with a decision still pending [6]. This site has already torn down a different part of the same consultation, the claim that its identity verification duty is already law [7]. This is a second, separate problem: what the consultation says its proposals rest on.
A 30-person study with its own warning label
One of the three pieces of research behind the 17 September page is a qualitative study: "this report looks at the perspectives of 30 adults who had been exposed to, and in some cases sought out," content promoting suicide, self-harm or eating disorders, plus "interviews with 5 professionals whose jobs include supporting people who encounter this content online" (page 6) [2]. The report is explicit about what that kind of sample can and cannot show. Its own "Context and notes on interpretation" section states: "the findings from this research should not be considered a reflection of any policy position that Ofcom may adopt as part of our role as the online safety regulator... Perceptions of online safety tools and features should not be seen as a validation of technical feasibility, proportionality or effectiveness of these" (page 8) [2].
A second passage, headed "How to read this report and consider the research findings," goes further on the sample itself: "the sample was weighted towards individuals with lived experience of harm, which mirrors those most likely to encounter SSHED content, but may not fully represent all types of online engagement. The exclusion of individuals currently in crisis, while necessary for safeguarding, may also mean that those engaging most frequently or intensely with harmful content are underrepresented" (page 19) [2]. Two separate, named limitations, in the report Ofcom itself commissioned: it cannot validate a tool, and its sample is skewed in a specific, acknowledged direction.
The same study, cited as the reason for the rules
Volume 2 of Ofcom's consultation sets out the proposed user empowerment Code measures for Category 1 services. Paragraph 3.7 states that Ofcom has evidence adults encounter this content, "that it can have negative impacts on them if they do encounter it" (page 5), with a footnote naming the source directly: "Our Register of Risks for illegal content... include evidence on the negative impacts of relevant content on adults. In more recent research on experiences of suicide, self-harm and eating disorder content, adults described impacts that included initiating attempts at suicide, suicidal ideation, as well as carrying out self-harm and disordered eating behaviours. Source: Ofcom, 2026. Exploring adult engagement with suicide, self-harm and eating disorder content" [4]. That is the 30-person study, cited by its own title. The very next paragraph moves straight to the policy conclusion: "our proposed user empowerment guidance and Code measures look to support providers to identify what constitutes relevant content, assess the likelihood of users encountering that content, and offer users a range of tools and features to better exercise choice and control over their online experience" (page 5) [4]. The report's own disclaimer covers precisely this move: a finding about adults' described impacts, used as evidence feeding directly into a justification for mandating tools and features, is the "validation" the report's authors said their findings should not be seen as providing.
None of this appears in the five-page Overview document that Ofcom publishes for stakeholders who will not read all 141 pages of Volume 2. The Overview does not mention the SSHED study, its sample size, or its disclaimer at all [5]. A reader relying on the document Ofcom designed to be read would never learn that part of the evidence base behind the rules comes with a label saying it should not be used this way.
Two studies, one undifferentiated "the research"
The 17 September synthesis page does not only use the 30-person study. It places it alongside a second, much larger piece of research: "Ofcom has commissioned a survey of UK adults aged 18+ about their experiences of encountering hateful content online," conducted "by YouGov among a nationally representative sample of 4,443 UK adults aged 18+, in February 2026" [3]. That survey is the kind of evidence that can support a population-level claim, and Ofcom's consultation documents generally treat it that way, citing specific percentages with care, for example flagging in one footnote that "it should be noted however that there is also evidence of internet users engaging with relevant content in more intentional ways" alongside the headline figures [4].
The 17 September page does not extend that care to the SSHED study. It introduces the hate survey's finding, then adds: "this trend was also clear in another recent study looking at how people come across content promoting suicide, self-harm and eating disorders," before describing its content in the same register as the 4,443-person survey: "even when people had initially sought out this content intentionally... this kind of material could continue appearing long after they no longer wanted to see it" [1]. A reader is never told that one of these studies surveyed 4,443 people and the other interviewed 30, or that one of the two carries its own written warning against using it to judge whether a tool works.
The claims, tested
| Ofcom's own words | What the record shows | Verdict |
|---|---|---|
| The SSHED study's findings "contributed to our evidence base and helped to inform our policy development for our recent consultation" (17 Sep 2026 synthesis page) [1] | The same study states "the findings from this research should not be considered a reflection of any policy position that Ofcom may adopt" and should not validate "technical feasibility, proportionality or effectiveness" of tools (page 8) [2] | A disclaimer against policy use, followed by exactly that use |
| Volume 2 cites the SSHED study to support that this content "can have negative impacts" immediately before announcing the proposed Code measures (page 5) [4] | The study's own sample is "weighted towards individuals with lived experience of harm" and excludes "individuals currently in crisis," which "may mean that those engaging most frequently or intensely with harmful content are underrepresented" (page 19) [2] | The limitation attached to the evidence is not carried into the document that relies on it |
| The 17 September page presents the SSHED study and the hate survey together as "the research" informing policy, with no distinction drawn between them [1] | The hate survey is a nationally representative sample of 4,443 adults [3]; the SSHED study is 30 adults and 5 professionals (page 6) [2] | Two studies of very different evidential weight, presented to the public without the difference |
The mistakes, counted
A disclaimer against using this research to validate online safety tools is not carried into the consultation that uses it for exactly that (1). The SSHED study says its findings "should not be seen as a validation of technical feasibility, proportionality or effectiveness" of tools and features (page 8); Volume 2 cites it in the paragraph immediately before announcing the Code measures those findings are said to support [2] [4].
The study's own stated sample limitation does not travel with its findings (2). Page 19's warning that the sample "may not fully represent all types of online engagement" and may underrepresent the most intensive content engagement appears nowhere in Volume 2's citation of the study, or in the five-page Overview document stakeholders are pointed to first [2] [5].
A 4,443-person survey and a 30-person qualitative study are presented to the public as one undifferentiated evidence base (3). The 17 September synthesis page moves from the hate survey's findings to the SSHED study's findings under a shared "the research" framing, without stating either sample size [1] [3] [2].
Credit where due
The SSHED report itself is unusually careful. Its disclaimers are not buried; they sit in a dedicated section near the front, and a second methodology section repeats and extends them before any findings are presented [2]. Ofcom also commissioned the study in the first place to hear directly from people with lived experience of harm, including those excluded from the quantitative tracker surveys that drive most of its other evidence, and said as much in its own foreword: "it is hugely important to understand firsthand what people's online lives are like, including people whose experiences might be less common" (page 6) [2]. And Volume 2's use of the larger hate survey elsewhere shows Ofcom can and does caveat its own evidence carefully when it chooses to [4].
Verdict
Four stars, from three documented mistakes. Nothing here suggests Ofcom's proposed user empowerment duties are wrong on their merits, or that the underlying harm is not real; the hate survey alone, at 4,443 respondents, stands on its own. The finding is narrower and more specific: Ofcom's own commissioned researchers wrote down, twice, what their 30-person study could not be used to prove, and the consultation built to decide a question that study cannot answer, whether specific tools and features work, cites it anyway.
The star score counts three documented mistakes against the SSHED report's own stated terms: Volume 2 of the consultation citing the study as support for its proposed Code measures despite the report's own page 8 disclaimer against using it to validate tools; the report's page 19 sample limitation not appearing anywhere the study is cited or summarised for the public; and the 17 September synthesis page presenting the 30-person study and a 4,443-person survey as one undifferentiated evidence base. Three falls in the 1 to 3 band: four stars; the bands are on the ratings page. This piece makes no finding against the hate survey's methodology, against the reality of the harms described by SSHED participants, or against the merits of the proposed Code measures themselves, which remain open questions for the pending consultation decision. Checked directly against the SSHED PDF report, the Overview PDF, Volume 2 of the consultation, and the Experiences of hateful content research page, all fetched 3 October 2026.
Sources
- Understanding people's experiences of distressing and harmful content online, Ofcom, published 17 September 2026
- Exploring Adults' Engagement with Suicide, Self-Harm, and Eating Disorder Content Online (PDF), MEL Research for Ofcom, 10 July 2026
- Experiences of hateful content, Ofcom, published 10 July 2026
- Volume 2: User empowerment and user identity verification (PDF), Ofcom, 10 July 2026
- Overview: Giving users more choice, control and trust in their online experience (PDF), Ofcom, 10 July 2026
- Giving users more choice, control and trust in their online experience (consultation), Ofcom, published 10 July 2026
- "Ofcom's consultation on the Online Safety Act's identity verification duty closes at five o'clock this evening. Three years after Parliament created that duty, it still is not law.", Tracked Changes, 2 October 2026