Tech firms must improve to remove terror content.

Terrorist Content Online: What Technology Companies Must Do

Terrorist organisations and violent extremists use online services to spread propaganda, recruit supporters, glorify attacks and encourage violence.

Material can be copied and shared across numerous platforms within minutes, making rapid detection and removal important.

Technology companies are no longer being asked merely to take voluntary action. The Online Safety Act 2023 places legal duties on regulated social media platforms, search services, and other online providers operating within the scope of the UK regime.

The principal illegal-content duties became enforceable on 17 March 2025, with Ofcom responsible for monitoring and enforcing compliance.

What Does the Online Safety Act Require?

Regulated services must assess how their platforms could be used to distribute illegal content and introduce proportionate systems and processes to reduce those risks.

Terrorism is treated as a priority category of illegal content.

Depending on the type of service, providers may be required to:

• complete and maintain an illegal-content risk assessment;


• consider how the design and operation of the service may facilitate terrorism content;


• take proportionate steps to prevent users from encountering priority illegal content;


• operate systems for identifying and removing illegal material;


• act swiftly when they become aware of illegal terrorism content;


• provide appropriate reporting and complaints procedures;


• keep records of relevant risk assessments and measures; and


• review their systems when risks, technology or the service change.

The legislation focuses on the systems and processes used by a provider rather than requiring every platform to guarantee that no illegal post will ever appear.

What Is Terrorism Content?

Under the Online Safety Act, terrorism content means material amounting to one of the terrorism offences identified in the legislation.

This may include content that:

• encourages acts of terrorism;


• disseminates terrorist publications;


• provides prohibited terrorist training or instructions;


• invites support for a proscribed organisation;


• expresses or displays support for a proscribed organisation in circumstances prohibited by law;


• threatens terrorist activity; or


• assists the preparation or commission of terrorism offences.

Content is not necessarily illegal merely because it is offensive, extreme or politically controversial.

The wording, intention, audience and wider context will be important when deciding whether material crosses the criminal threshold.

Ofcom’s Role

Ofcom is responsible for regulating online services under the Act.

It publishes codes of practice and guidance explaining the measures providers can use to comply with their legal duties.

Ofcom can:

• require information from a provider;


• investigate possible breaches;


• interview relevant individuals;


• require remedial action;


• issue enforcement notices;


• impose financial penalties; and


• in serious cases, seek court orders restricting access to a service in the UK.

Ofcom can impose a penalty of up to £18 million or 10% of the provider's qualifying worldwide revenue, whichever is greater.

Can Ofcom Require the Use of Technology?

The Act includes powers allowing Ofcom, in specified circumstances, to require a regulated service to use accredited technology to identify publicly communicated terrorism content and remove it swiftly.

These powers are intended for cases where the legal conditions for a technology notice are met, and existing measures have not adequately addressed the risk.

A technology notice may relate to:

• identifying known terrorism images or videos;


• preventing repeated uploads;


• detecting matching material;


• swiftly removing identified content; and


• using technology already deployed by the provider more effectively.

Any technology required by a notice must satisfy the accreditation requirements contained in the legislation.

A provider receiving a notice may have rights to make representations or challenge the decision through the appropriate legal process.

Is There a Fixed Removal Deadline?

The UK does not impose a general rule requiring every item reported as extremist or terrorist content to be removed automatically within 24 hours.

Platforms must act swiftly against material they have reasonable grounds to regard as illegal. Still, the appropriate response will depend on the nature of the service, the level of risk and the surrounding circumstances.

The European Union operates a separate system under Regulation (EU) 2021/784. A competent authority in an EU member state can issue a removal order requiring identified terrorist content to be removed or disabled within one hour.

That European Union rule has applied since June 2022, but it is not the general legal system operating in the UK.

The Risk of Removing Lawful Speech

Rapid removal can limit the spread of dangerous propaganda, but it also creates a risk that lawful material will be removed unnecessarily.

A post discussing terrorism could form part of:

• journalism;


• academic research;


• historical reporting;


• political criticism;


• satire;


• documentary material;


• counter-extremism work; or


• evidence of war crimes or human rights abuses.

Automated systems may struggle to distinguish these uses from content that praises, encourages or assists terrorism.

Providers facing substantial penalties may be tempted to remove doubtful material rather than investigate its context carefully. This is sometimes described as over-removal or over-moderation.

Freedom of Expression

The Online Safety Act does not require technology companies to remove every unpopular, distressing or controversial opinion.

When selecting and applying safety measures, regulated services must have regard to users' rights to freedom of expression and privacy.

The challenge is to remove content that crosses the criminal threshold while protecting lawful reporting, research and debate.

Terms of service may prohibit a wider range of material than the criminal law. A platform may therefore remove content under its own rules even where the material would not result in a criminal prosecution.

Automated Content Moderation

Artificial intelligence, image-matching technology and automated detection systems can help identify material previously connected with terrorist organisations or attacks.

Technology may be used to:

• detect previously identified images and videos;


• recognise repeated uploads;


• limit algorithmic recommendations;


• identify suspicious accounts and networks;


• detect coded patterns of behaviour; and


• refer high-risk material for human review.

Automated decisions are not infallible.

Edited footage, coded language and changing tactics can avoid detection, while legitimate news, research or educational material may be incorrectly flagged.

Human oversight and effective review procedures remain important, particularly where the context is unclear.

Reporting Terrorist Material

A person who encounters content promoting or encouraging terrorism should avoid sharing it further.

The material can normally be reported directly to the platform using its reporting procedure.

Potential terrorist or extremist material can also be reported through the official government reporting service.

Reports may concern:

• articles encouraging terrorism;


• images or videos glorifying terrorist attacks;


• terrorist speeches or propaganda;


• websites operated by terrorist or extremist organisations;


• material encouraging violence; or


• instructions or publications supporting terrorism.

A report can be made without providing a name or contact details.

Where there is an immediate threat to life or property, the police should be contacted urgently.

Complaints About Platform Decisions

Regulated services must provide accessible procedures allowing users to complain about certain online-safety decisions.

Depending on the circumstances, a complaint may concern:

• failure to remove illegal material;


• removal of content believed to be lawful;


• suspension or termination of an account;


• restrictions placed on an account or post;


• failure to apply published terms consistently; or


• failure to operate a reporting system properly.

A person challenging a decision should retain:

• a copy of the content;


• the platform’s decision notice;


• screenshots;


• the relevant terms of service;


• correspondence with the provider; and


• details of any appeal or complaint submitted.

Preserving material should be approached carefully. Possession of certain terrorism material can itself be an offence in particular circumstances, so that legal advice may be required.

Criminal Responsibility of Users

The removal of material by a platform is separate from the possible criminal liability of the person who created, possessed or shared it.

A person may commit an offence by:

• encouraging terrorism;


• distributing a terrorist publication;


• inviting support for a proscribed organisation;


• displaying support for a proscribed organisation in prohibited circumstances;


• providing terrorist training;


• possessing specified material for a prohibited purpose; or


• collecting information likely to be useful to a terrorist.

Sharing, reposting or forwarding content can have legal consequences even where the person did not create it.

The precise offence will depend on the nature of the material, the person's knowledge or intention and the surrounding circumstances.

Journalists, Researchers and Academics

Journalists, researchers, lawyers and academics may have legitimate reasons for viewing or retaining material connected with terrorism.

However, professional or research activity does not provide an unlimited exemption from terrorism legislation.

Anyone handling sensitive material should consider:

• why the material is needed;


• how it is stored;


• who can access it;


• whether retaining the full material is necessary;


• whether identifying details should be removed;


• the organisation’s security procedures; and


• whether specialist legal advice is required.

Does Removing Content Solve the Problem?

Removing extremist content can reduce its audience and make recruitment more difficult, but it cannot eliminate terrorism by itself.

Material may move to:

• smaller platforms;


• private messaging groups;


• encrypted services;


• closed forums;


• foreign-hosted websites; or


• offline networks.

Effective prevention also requires policing, intelligence work, education, community engagement and measures addressing radicalisation outside the internet.

Online regulation is therefore one part of a wider counter-terrorism strategy.

Holding Technology Companies Accountable

The debate has moved beyond asking technology companies to demonstrate voluntary goodwill.

Regulated providers now have enforceable duties and can face substantial financial penalties when their risk assessments, systems or processes fail to comply with the law.

At the same time, regulation must not encourage indiscriminate deletion of lawful political, journalistic or academic material.

Effective enforcement requires:

• speed;


• accuracy;


• transparency;


• proportionate decision-making;


• human oversight; and


• a meaningful process for challenging incorrect decisions.

Getting Legal Advice

A criminal law solicitor can advise a person being investigated for publishing, possessing or sharing alleged terrorist material.

Legal advice may also be required where:

• a platform removes lawful content;


• an account is suspended or terminated;


• information is disclosed to law enforcement;


• a person receives a police request or production order;


• terrorism material is discovered on a device;


• a business is affected by Ofcom enforcement action; or


• a platform fails to respond properly to illegal threats or extremist content.

Use the search facility at the top of this page to find a criminal, media, technology or regulatory solicitor who can advise on online content and terrorism law.

Disclaimer

Solicitors.com is not a firm of solicitors and does not provide legal advice. This article provides general information about online safety and terrorism law in the United Kingdom. The law is complex, and the position will depend on the content, the person's intentions and the surrounding circumstances.

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