Ofcom has issued its first major fine under the Online Safety Act 2023. The AVS Group Ltd – which runs 18 adult websites – has been fined £1 million for not having robust age checks in place, plus £50,000 for failing to respond to information requests. The regulator has also reported on how the online safety landscape is changing, following new UK laws coming into effect this year.

Ofcom says it has opened investigations into 92 online services since the new rules came into force, and has already fined three providers. An enforcement notice was previously issued to a “nudify” app (AI-based image manipulation) for failing to block under-18s, the Guardian reports.

The UK Government is exploring new legislation or regulatory measures to extend the reach of the Online Safety Act to ensure that chatbots are covered to safeguard children from self-harm or harmful influences. Technology Secretary Liz Kendall has urged Ofcom to use its existing powers to ensure AI chatbots are child-safe amid growing concern in the Tech Department about the dangers they pose. UK Tech News and the Financial Times have more information.

Virgin Media has been fined £23.8m for putting thousands of vulnerable people “at risk of harm” when switching them from an analogue to a digital landline as many rely on the analogue system to communicate with call centres or carers. Ofcom found the company failed to protect people who relied on telecare alarms to call for help, after Virgin Media self-reported a number of “serious incidents” in November and December 2023.

Internet and Social Media

Paul Bernal’s Blog has a new article arguing why banning kids from social media is a bad idea. The piece is prompted by Australia’s new ban of under-16s from social media, which comes into force this month. Further information below.

On the same theme, the IAPP blog has an article that attempts to make sense of age verification and assurances as more children go online at younger ages. Responsibility for implementing and operationalizing these tools now rests with device manufacturers, app developers, operating systems and third-party providers: actors central to discussions on protecting the privacy of children online. The article explains how each ownership model brings distinct benefits and limitations.

The Information Commissioner’s Office (ICO) has announced a new initiative to scrutinize privacy protections in mobile games frequently played by children in the UK. As digital gaming continues to grow in popularity among children, the review by the ICO signals renewed regulatory attention as to how mobile gaming platforms safeguard personal data of young users. The Privacy and Information Security Law blog has more information here.

The Norton Rose Fulbright Inside Tech Law blog has prepared a summary of the changes that the Cyber Security and Resilience Bill proposes to the UK’s Network and Information Systems Regulations 2018. Read the mark up here and further reflections here.

Data Privacy and Data Protection

The ICO has issued a series of enforcement notices and practice recommendations to several public authorities after identifying significant failures to comply with the Freedom of Information (FOI) Act 2000.

The IAPP blog has an article that considers privacy in the age of AI. AI poses a number of questions for lawmakers to grapple with: Who is the data controller when the AI system itself determines the means of processing? How do we ensure accountability when decisions emerge from autonomous planning rather than a human-defined rule set? And above all, how do we preserve privacy rights in a world where AI is continuously inferring, adapting and acting in real time? The piece argues differential privacy is one of the strongest answers available to these questions.

Events 

UCL is hosting an event titled, ‘How does planning intensify surveillance,’ on 10 December 2025 from 16:30-18:30, exploring how expanding digital systems of control reshape planning, privacy and surveillance. Register here

IPSO

Statements in Open Court and Apologies

On 3 December 2025, GB News apologised and paid substantial damages to Islamic Relief after airing unfounded allegations by an interviewee on its Camilla Tominey Show programme. The interviewee falsely alleged that in effect the charity had funded terrorist groups in the Middle East and is part of a greater agenda promoting extremism and radicalisation. Read the full statement here [pdf]. Press Gazette and Carter-Ruck have more information. Read the apology here.

On 4 December 2025, Sheffield Hallam University retracted false claims that it had published about Hong Kong clothing business Smart Shirts Limited. The University had alleged that Smart Shirts was sourcing materials which were the product of forced labour from the Xinjiang Uyghur Autonomous Region (and that there were grounds to investigate that it knew this to be the case). The University acknowledged that the allegations were untrue. It stated that it had not intended to suggest that Smart Shirts used any materials produced by forced labour, as it had found no evidence that this was the case. Read the full statement here [pdf]. 5RB has more information here.

New Issued Cases

There were 6 new cases issued in the Media and Communications List this week, 4 libel cases and two data protection cases.

Last Week in the Courts

On 1 December 2025, the Court of Appeal delivered judgment on the whistleblower case Rogerson v Erhard-Jensen Ontological / Phenomenological Initiative Ltd [2025] EWCA Civ 1547. Speaking for the court, Lady Justice Andrews held that judicial proceedings immunity did not shield an employer from a whistleblowing detriment claim where the alleged detriment was commencing arbitration proceedings against the whistleblower in Singapore, claiming that he had breached a confidentiality agreement which contained an arbitration clause. The appeal was allowed and the decision of Judge Fowell at first instance was reinstated.

On Tuesday 2 December 2025 there was a 1-day hearing for contempt directions in the case of Foot Anstey LLP and another v Stimson KB-2024-002927.

As mentioned above, on Wednesday 3 December 2025 there was a statement in open court in the case of Islamic Relief Worldwide v GB News Limited KB-2025-003874.

On Thursday 4 December 2025 there were statements in open court in the cases of Smart Shirts Ltd v Sheffield Hallam University KB-2023-004736, mentioned above,  and Paulley v RS Tyler Ltd KB-2025-002656.

On Friday 5 December 2025 there was an appeal hearing in the case of Baig v Hassan KA-2025-000086.

Media Law in Other Jurisdictions

Australia

From 10 December 2025, Australians under 16 will be banned from holding accounts on major social media platforms — including YouTube, TikTok, Instagram, Snapchat, X, Reddit, Kick (and others identified by the national regulator). Platforms must take “reasonable steps” to remove or block under-16 accounts; if they fail they could face fines up to about AUD $50 million. Account features (uploading, commenting, subscribing, playlists, personalised recommendations) will be disabled for under-16s — they may still watch public content while logged out. ABC News, Australian Times, Sky News and Digital Watch are some of the many news outlets to provide coverage.

A legal challenge has already been filed against the under-16 ban by a group including two 15-year-olds and advocacy organisation Digital Freedom Project. They argue the ban violates the implied constitutional right to political communication. Inforrm had an article on the challenge.

The Australian government has unveiled the National AI Plan, an artificial intelligence roadmap with a heavy focus on investment and economics after previously pursuing a more safety-oriented strategy. The plan seeks to boost Australia’s reputation as a place to invest in AI through digital and physical infrastructure while promoting goals to use AI to improve public services and AI adoption across the country. The plan also outlines how the recently announced AI Safety Institute will be used to monitor, test and share information on AI capabilities, risks and harms. IAPP has more information here.

Canada

The government of Québec has amended its digital-content legislation so that social media platforms and other online streaming services will become subject to mandatory French-language content quotas and discoverability requirements. The law removes a previous exemption for social media services — meaning user-generated content platforms such as video or audio-sharing platforms could be covered. The Michael Geist blog has described the Bill as the most unworkable internet law in the world.

Europe

On 2 December 2025, the Grand Chamber of the Court of Justice of the European Union (CJEU) delivered a landmark judgment in the case X v Russmedia Digital and Inform Media Press (C-492/23). The CJEU has removed the neutrality cover for online marketplaces and made them responsible for leaks of user-posted content and other misuses of personal data. Now platforms which control how content appears, set the rules for its use and profit from its visibility, stop being a neutral host and become a data controller under EU privacy law; meaning it decides why and how people’s information is processed and must answer for it. Read the decision press release here. Courthouse News has more information here. Bird & Bird, SCL and PWC also cover the judgment.

India

India has dropped plans to require smartphone makers to pre-install a government-backed “cyber safety” app on all new devices, following criticism over surveillance concerns. The Communications Ministry said it will no longer force Apple, Samsung, Xiaomi and other manufacturers to load the Sanchar Saathi app onto new phones. Officials said they rolled back the mandate because of the “increasing acceptance” of the tool, which has reportedly been downloaded by 14 million users so far, including 600,000 new registrations on Tuesday alone. The reversal came less than a week after New Delhi ordered manufacturers to add the app to every new handset within 90 days — and ensure it could not be deleted — sparking concerns among privacy groups that the policy would give authorities access to hundreds of millions of phones. The Record has more information here.

United States

The Supreme Court heard oral arguments this week in a case where First Choice — a faith-based non-profit running “crisis pregnancy centers” — is challenging a subpoena from the state of New Jersey demanding donor names and other internal records. First Choice argues that being forced to produce donor and internal data chills its free-speech and free-association rights under the First Amendment. Legal Information Institute has more information here.

OpenAI has been ordered to share 20 million anonymised ChatGPT user logs with news publishers who are suing for breach of their copyright. OpenAI is currently removing anything that can identify its users from 20 million output logs (out of the tens of billions it has stored in total) and has been ordered to hand these over to the news publishers within seven days of completing that process. Lawyers for the news publishers will then be able to analyse the 20 million conversations looking for responses that reproduce their copyrighted work in whole or part. The Press Gazette has more information here.

Privacy International has an article that examines the emerging trend of pushback within the US against companies that collect and monetise health data via the use of class actions as a legal route to seek redress for the exploitation of health data.

Research and Resources

Next Week in the Courts 

On Monday 8 December 2025 the trial in the case of Feldman v Gambling Commission KB-2024-003588 will begin.  The trial is listed for 5 days.

On the same day there will be a hearing of consequential arguments before Richard Spearman KC in the case of Nasser v Raja, QB-2022-002648.

On Tuesday 9 December 2025 there will be a consequentials hearing in the case of Ness v Miller KB-2025-000232 and a hearing of applications in the case of QRT v JBE.

On Wednesday  10 December 2025 there will be the hearing of an application in the case of TSE, (A Minor, By His Litigation Friend, UTF) v Dahan KB-2025-003183/

On Friday 12 December 2025 there will be hearings in the cases of Amersi v BBC KB-2022-003244 and Bruce v High Speed Two Ltd KB-2025-002422.

Reserved Judgments

Hurst v Solicitors Disciplinary Tribunal, heard 27 and 28 November 2025 (Collins Rice J).

Ali v Hussain, heard 26 and 27 November 2025.

Optosafe Ltd v Robertson, heard 11 and 12 November 2025 (Steyn J).

This Round Up was prepared by Colette Allen, the host of Newscast on Dr Thomas Bennett and Professor Paul Wragg’s The Media Law Podcast (@MediaLawPodcast).