A short post on why I will not be writing a long post about Ofcom’s Online Safety Act consultation

Estimated reading time: 4 minutes
UK policy

The late and desperately missed Hilary Mantel’s masterwork, her Wolf Hall trilogy, is 1,888 pages long. I savoured every moment I spent in that world, and grieved each time I was pulled out of it. Her chronicle of the politics of the Tudor court ends, for Thomas Cromwell, as his real life did: he lies on the banks of the Thames, his head freshly severed from his body, feeling his consciousness ebbing out with the tide.

Step over Cromwell’s body, walk a mile west along the Thames, and cross the river, and you will find yourself at the premises of Ofcom, whose first consultation on the rules, restrictions, and enforcement of Britain’s Online Safety Act is 1,742 pages long, and will cause you to feel much the same.

At first glance, 1,742 pages – a payload which is only the first of four consultations from Ofcom on this one single piece of legislation – might leave even the most capable professional struggling to find the will to live.

But reader, I slayed it.

Which is nbd: that’s what I do.

In fact, that’s nearly thirty years of experience doing what it should. Knowing how to turn 1,742 pages into an actionable task, read for a client’s needs, digested, turned around, and transformed into a plan of action, is just part of what I do, here on the frontlines of internet regulation on Perfectly Normal Island.

To me, that’s just part of my job.


One of my clients was both grateful for my read and turnaround, and also a bit gobsmacked that I’d done it at all.

Why aren’t you offering this as a service? They asked. To which I replied – I do. That’s what I do.

Why aren’t you getting better takeup on it? They asked. To which I replied – because I’m not in London.

I then had to explain that to them: that being as far as this country’s policy brain is concerned, if you’re not doing the work with your bum in a chair somewhere in Zones 1 and 2, you’re not doing the work at all. And not only that, but gasp, shock, I don’t even have a Ph.D, which is seen as a mark against my intellect and my professionalism.

More head-shaking from the client ensued.

For me, a bit of thinking time ensued too – both about the consultation, and about the things I have to say about it.

And then yesterday, someone asked where my blog post was. You know, the inevitable 5000 word, top-of-Hacker-News one (like the previous one) about the Ofcom consultation that they just assumed I’d have written by now.

Well, it’s not coming, because the client was absolutely correct.

As long as my magic skill is turning 1,742 pages into a plan of action based around a client’s specific business model, a skill I developed dealing with the Bill over four and a half years in multiple professional roles, none of whom supported or valued me for it, I need to make that magic skill work for me as much as it works for others.

From a personal perspective, I’m able to have a little personal perspective now, when I’m happily working for great clients, which I’ve been doing since late summer, after 51 weeks of unemployment and job searching. Fifty one. By the end of it, I was not in a good place in any sense. I’m mostly recovered now, but my energy levels are not. And if you want to talk about energy-sapping situations, well, distilling Cromwellian internet regulation into a plain English blog post, hitting publish, and then having to go live in a cave for a few days while it hits #1 on Hacker News is a lot of them at once. On second thought, I’ll pass.

From a professional perspective, as both I and other clever clogs have noted, Ofcom’s consultation process on the Online Safety Act isn’t your normal public engagement. There are a lot of politics and nuances and intrigues surrounding it. What you’re looking at, on paper, isn’t actually what’s transpiring behind the scenes. What policymakers are saying in public isn’t actually what they believe. What politicians say they want to do with this law isn’t their plan for it at all. It’s all complicated, and murky, and deeply layered.

This palace court is a dangerous place to be.

Too dangerous for most people, and that probably includes you.

(and yes, I must repeat yet again that the impact assessment for the OSA famously said that getting to grips with the scope of compliance could be done in just over four hours by a regulatory professional on a wage of £20.62 per hour. There are new figures in new impact assessment documents from Ofcom, buried deep in those 1,742 pages, which are even worse – if that was possible? – in terms of their maths and their practicality. But that is the point. They’re as much a part of the intrigues as anything else whispered along the Thames.)

So what can I tell you, really? The consultation is 1,742 pages long and every business impacted needs to read every word of it and respond by Friday 23 February 2024.

If you don’t know whether or not you’re impacted, they have a tool of sorts you can use to find out.

If you are impacted, and want to have your say, but you either don’t have someone on staff to handle it for you or don’t have an understanding of the politics of the palace court, remember that is what I do. So get in touch, and start by telling me about your budget for the work.

As for me, I’m still in the palace court. I’m there right now, in fact. Did you see me?

Of course you didn’t.

You can write on England, but what was written before will show through.Hilary Mantel, Bring Up the Bodies

Header image: from the same.

The Author

I’m a UK tech policy wonk based in Glasgow. I work for an open web built around international standards of human rights, privacy, accessibility, and freedom of expression. The content and opinions on this site are mine alone and do not reflect the opinions of any current or previous team.