Draft amendments to Illegal content Codes of Practice for search services
Published 1 June 2026
Draft of amendments to lie before both Houses of Parliament for the 40-day period in accordance with section 43 of the Online Safety Act 2023, during which time either House may resolve that the draft be not approved.
Draft of amendments prepared under section 41 of the Online Safety Act 2023 and submitted to the Secretary of State in accordance with section 43(1) on 15 May 2026.
Presented to Parliament pursuant to section 43(2) of the Online Safety Act 2023
June 2026
© Ofcom copyright 2026
978-1-5286-6520-9
E03610761
1. Preamble
1.1 On 24 February 2025 Ofcom issued the Illegal content Codes of Practice for search services in accordance with section 41 of the Online Safety Act (‘the Act’).[footnote 1]
1.2 Ofcom issues the amendments set out in section 2 of this notification in accordance with section 43(4) of the Act.
1.3 In the course of preparing the draft of amendments to those Codes, Ofcom consulted the persons mentioned in section 41(6) and (7) of that Act.
1.4 In accordance with section 43(2) and (3) of the Act, the draft has been laid before Parliament for the 40-day period, during which time neither House of Parliament resolved not to approve the draft.
1.5 The amendments come into force [at the end of the period of 21 days beginning with the day on which they are issued] in accordance with section 43(4) of the Act.
1.6 Ofcom will publish the amended code of practice on its website in accordance with section 46 of the Act.
Signed by
Oliver Griffiths Group Director, Online Safety
A person authorised by Ofcom under paragraph 18 of the Schedule to the Office of Communications Act 2002
15 May 2026
2. Amendments
2.1 The Illegal content Codes of Practice for search services are amended as follows.
Amendments to index of recommended measures
2.2 In Section 3 (Index of recommended measures), in the appropriate place, insert the following entry–
| ICS C8 | Using hash matching to detect intimate image abuse content | Large general search services. | Other duties | Section 27(2) and (3) |
Amendments to recommended measures
2.3 In Section 4 (Recommended measures), after Recommendation ICS C7 (Removing listed CSAM URLs from search results), insert–
| “ICS C8 | Using hash matching to detect intimate image abuse content |
| Application | |
| ICS C8.1 | This measure applies to aproviderin respect of eachlarge general searchserviceit provides. |
| Key definitions | |
| ICS C8.2 | In this Recommendation ICS C8: “relevant content” means anysearch contentin the form of photographs, videos or visual images (whether or not combined with written material) thatUnited Kingdom userscanencounterin orviasearch results; “unverified hash” means a hash which is not a verified hash; “verified hash” means a hash which was determined to be ofintimate image abuse contentat the time the hash was uploaded to a database. |
| Recommendation | |
| ICS C8.3 | The provider should ensure thathash matching technologyis used effectively (see ICS C8.8) to analyse relevant content to assess whether it isintimate image abuse content. For this purpose, the provider should use: a)perceptual hash matching technology; or b) where the provider’s appropriate set of hashes (as defined in ICS C8.9) does not enable perceptual hash matching for videocontent,cryptographic hash matching. |
| ICS C8.4 | In circumstances where: a) relevant content matches with an unverified hash; and b) either of the following apply: i) ifperceptual hash matching technologyis used, it is the first time there has been a positive match with that hash at that configuration of the technology (see ICS C8.8(b)); or ii) ifcryptographic hash matchingis used, it is the first time there has been a positive match with that hash; the provider should treat this as reason to suspect that the relevant contentmay beillegal contentand review the relevant contentin accordance with Recommendation ICS C1. |
| ICS C8.5 | Where relevant content matches with a hash in circumstances other than those set out in ICS C8.4, the provider: a) may, depending on the level of assurance the provider has in the detection outcomes achieved by thehash matching technology,treat the relevant content asillegal contentand take appropriate moderation actionin relation to the relevant content in accordance with Recommendation ICS C1; or b) should otherwise treat the match as reason to suspect that the relevant content may beillegal contentand review the relevant content in accordance with Recommendation ICS C1. |
| ICS C8.6 | The provider should ensure human moderators review and assess an appropriate proportion ofdetected content, having regard to: a) the level of assurance the provider has in the detection outcomes achieved by thehash matching technologyand any associatedsystems and processes(as indicated by the ongoing monitoring, evaluation and quality assurance (including human quality assurance) of the performance of the technology); and b) to the extent thatdetected contentis subject to review for the purpose of Recommendation ICS C1: i) the potential severity of the harm to those depicted in orencounteringintimate image abuse content; and ii) the overall impact of an incorrect decision that the relevant content isillegal contenton aninterested personto whom the content relates. |
| ICS C8.7 | For the purposes of ICS C8.3, the provider should ensure that: a) all relevant content present on the service at the time thehash matching technologyis implemented is analysed within a reasonable time; and b) relevant content that may beencounteredin orvia search resultsbyUnited Kingdom usersafter thehash matching technologyis implemented is analysed before or as soon as practicable after it can be soencountered. |
| ICS C8.8 | For the use ofhash matching technologyto be effective, it should: a) use a suitable hash function to compare relevant content to an appropriate set of hashes (see ICS C8.9 to ICS C8.12); and b) whereperceptual hash matching technologyis used,be configured so that its performance strikes an appropriate balance betweenprecisionandrecall(see ICS C8.13 to ICS C8.15). |
| The set of hashes | |
| ICS C8.9 | For the set of hashes to be appropriate, it should: a) contain hashes of a significant number of original items ofcontent; b) be proactively updated with reasonable regularity; and c) be secured from unauthorised access, interference and (to the extent the database is comprised of verified hashes) exploitation (whether by persons who work for that person or are providing a service to that person, or any other person). |
| ICS C8.10 | Where the provider becomes aware ofintimate image abuse contenta hash of which is not included on any database used by the provider, the provider should take reasonable steps to secure that a hash of thatcontentis added to each such database. |
| ICS C8.11 | The provider should take reasonable steps to secure the removal of a hash from any hash database used by the provider where it has determined that the hash is not ofintimate image abuse content(see ICS C8.12). |
| ICS C8.12 | For the purposes of ICS C8.11, the provider determines that the hash is not ofintimate image abuse contentin any of the following circumstances: a) the provider views thecontentused to generate the hash and determines it is notintimate image abuse content; b) the provider otherwise reasonably believes that the hash is ofcontentthat is notintimate image abuse content; c) the provider viewsdetected contentmatched with the hash usingcryptographic hash matching technologyand determines that thatcontentis notintimate image abuse content; or d) the provider viewsdetected contentmatched with the hash usingperceptual hash matching technologyand determines that thatcontentis notintimate image abuse content,provided that the provider reasonably believes that there is an exact match between the hash of thedetected contentand the hash included on the database. |
| Technical configuration | |
| ICS C8.13 | In configuring thehash matching technologyso that its performance strikes an appropriate balance betweenprecisionandrecall, the provider should ensure that the following matters are taken into account: a) the service’sriskof harm relating tointimate image abuse, reflecting therisk assessmentof the service and any information reasonably available to the provider about the prevalence of relevant content that isintimate image abuse contenton the service; b) the proportion ofdetected contentthat is afalse positive; and c) the effectiveness of thesystems and/or processesused to identifyfalse positives. |
| ICS C8.14 | The provider should ensure that the performance of thehash matching technology, and whether the balance betweenprecisionandrecallcontinues to be appropriate, is reviewed at least every 6 months. |
| ICS C8.15 | The provider should ensure that a written record is made of how this balance has been struck in configuring thehash matching technology, including what information has been considered, and information about reviews and steps taken in response. |
| Safeguards for freedom of expression and privacy | |
| ICS C8.16 | Paragraphs ICS C8.4 to ICS C8.6 and ICS C8.8 to ICS C8.15 of this Recommendation ICS C8 are safeguards to protectUnited Kingdom users’andinterested persons’right to freedom of expression and the privacy ofUnited Kingdom usersandinterested persons. |
| ICS C8.17 | The following measures are also safeguards to protectUnited Kingdom users’andinterested persons’right to freedom of expression and the privacy ofUnited Kingdom usersandinterested persons: a) Recommendation ICS C1, and where they are applicable, Recommendations ICS C2, ICS C3, ICS C5 and ICS C6 (in relation to search moderation); b) Recommendations ICS D1 and ICS D2, so far as they relate toappealsor complaints byUnited Kingdom usersandinterested personsif they consider that the provider is not complying with its duties in relation to freedom of expression or privacy; c) Recommendations ICS D7 or ICS D8 (whichever is applicable), ICS D9 (in relation toappeals) and ICS D11; and d) Recommendation ICS G1 (publicly available statements: substance (all services)).”. |
Amendments to definitions and interpretation
2.4 In Section 5 (Definitions and interpretation), in Table A, in the appropriate places, insert the following entries–
| Cryptographic hash matching technology | Technology that detects exact matches to digitalcontentby comparing cryptographic hash values of thecontentagainst a reference database of cryptographic hash values. A match is identified only where the hash values are identical. |
| Detected content | Search contentdetected by the use of arelevant technologyas being (or as likely to be)target content(and related expressions are to be read accordingly). |
| False positive | Detected contentthat is nottarget content. |
| Hash matching technology | Eitherperceptual hash matching technologyorcryptographic hash matching technology. |
| Intimate image abuse content |
Search contentwhich amounts to an offence: a) under section 66B of the Sexual Offences Act 2003 (sharing or threatening to share intimate image or film); or b) under section 2 of the Abusive Behaviour and Sexual Harm (Scotland) Act 2016 (asp 22) (disclosing, or threatening to disclose, an intimate photograph or film). |
| Perceptual hash matching technology | Image matching technology which compares the similarity between hashes created from images by means of an algorithm known as a perceptual hash function, to assess whether those images are perceptually similar to each other. This does not include technology which compares similarity through the use of machine learning. |
| Precision | A measure of statistical accuracy, calculated as the proportion ofdetected contentthat arelevant technologyhas correctly identified astarget content. |
| Recall | A measure of statistical accuracy, calculated as the proportion oftarget contentanalysed by arelevant technologythat the technology hasdetected. |
| Relevant technology | The kind of technology specified in the measure in question. |
| Target content | Contentof the kind the use of arelevant technologyis designed to identify. |
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Ofcom,(24 February 2025).↩