Single-source acquisition closed on 9 September 2026. The [regulator-hosted response](http[local research file] is dated 17 October 2025 on PDF20. Ofcom's response index displays 11 December 2025, a separate publication/listing date.
Full Fact advocated a broader crisis framework and stronger Ofcom supervision, coupled with constraints on discretion. The cited page 17 principally requests expansion/alignment of the crisis definition with section 175. It does not expressly propose automatic activation of a platform protocol on receipt of a ministerial notice, nor supply the wording eventually added by Ofcom. It also is not merely a request to constrain government: the wider response seeks materially broader regulatory coverage and coordination.
At paragraph76, PDF17, Full Fact argues that the proposed definition is too narrowly directed at public safety. It asks to include public health and national security, aligning the definition with section 175 and comparing the EU Digital Services Act's crisis definition. It describes the existing Secretary of State route to Ofcom's media-literacy priorities or public statement notices. This is a scope-alignment argument using an existing power as a benchmark, not a newly drafted executive activation power.
At paragraph77, PDF17, it asks for a clear, transparent, widely understood crisis definition, evidence and proportionality, and severity indicators. It also proposes covering clusters of misleading claims/narratives and slow-onset incidents, as well as discrete sudden events.
At paragraph78, PDF17–18, it says government bodies likely already have incident definitions, criticizes the lack of transparency around that framework, and recommends Ofcom seek insight and align definitions to improve public/private coordination. The government-practice claims are Full Fact's account; the underlying sources were not acquired here.
At paragraph79, PDF18, it recognizes that Ofcom's judgment about whether an incident occurred may differ from a provider's judgment. It proposes shared indicators to make those judgments more understandable. It does not confer authority on Full Fact to declare a binding crisis.
| Request within the same submission | Precise location |
|---|---|
| Legislative review to address systemic and collective misinformation harms, including legal-but-harmful adult content, with expression safeguards. Full Fact acknowledges wider legal reform lies beyond this consultation. | Paragraphs12–15, PDF4 |
| A centralized Ofcom information-incident framework; advance communication channels with police, government, other providers and civil society; provider notifications to Ofcom and users when protocols start/end. | Paragraphs29–34, PDF7–8 |
| Stronger Ofcom supervision of effectiveness and proportionality; remedial steps where necessary, including protection of expression. Provider discretion should sit within clearer command structures and accountability. | Paragraphs38–44, PDF9–10 |
| Written decision logs, evidence preservation where appropriate, indicators/risk assessments for de-escalation and ending a crisis, and clear responsibility for starting/stopping it. The stated purpose includes avoiding indefinite crises and misuse. | Paragraphs62–67, PDF14–15 |
| Routine submission of post-crisis analyses to Ofcom, ongoing regulatory review, and publicly available summaries of Ofcom's assessment/recommendations. | Paragraphs71–72, PDF16 |
These are proposed process safeguards, not evidence that an affected user's post or account would be restored or that a particular appeal succeeded. Full Fact's proportionality argument also criticizes a focus on minimizing provider costs and asks that the severity of harms be weighed (paragraphs86–90, PDF20). Its argument combines stronger intervention with accountability; either half alone would misrepresent the response.
A related institutional boundary appears in paragraph52, PDF12: Full Fact acknowledges that Ofcom cannot currently mandate changes to platforms' partnership policies to require working with fact checkers. Paragraphs53–54, PDF12 separately seek guaranteed, meaningful data access for accredited fact checkers and enforceable consequences for non-cooperation. This is advocacy for a future entitlement, not an existing award, partnership mandate or acquired data-access right. No donor or organizational genealogy was pursued.
The accepted root operational note records Ofcom's statement 3.46–47/footnote29, PDF17, identifying Full Fact's response p17 and an Ofcom/DSIT meeting on 4 August 2025 as inputs to questions about the interaction. Ofcom's resulting amendment says providers should consider an Ofcom public statement notice alongside their other indicators.
Reading the actual response narrows that attribution: Full Fact supplied a definition/coordination argument involving section 175, while the regulator's eventual notice-consideration wording is not found as an explicit Full Fact instruction in the inspected text. The response's 17 October date is later than the 4 August meeting. It cannot by itself prove Full Fact initiated that meeting's question, attended it, co-drafted the amendment or controlled the wording. No such inference is made.
The strongest rival to a direct ministerial-trigger lobbying account is that Ofcom resolved an interaction surfaced by differently framed stakeholder inputs. The remaining discriminating record is the 4 August2025 Ofcom/DSIT meeting note or drafting record showing what was asked, by whom, and how the final wording was chosen. Root owns that separate public search.
The ordinary GET returned 403 and was closed. No original PDF was acquired. fullfact-reader.txt retains 825 of 829 official-reader lines, covering substantive paragraphs 1–90 across 20 PDF pages; omitted lines 577–580 are explicitly marked. Decisive paragraphs76–79 and surrounding authority/safeguard passages were read in full. The extracted PDF has irregular internal spacing, preserved rather than silently normalized. No images or linked case evidence, DSA text, Full Fact framework, government framework or external report were independently inspected in this lane.
fullfact-captures.json records source/date/scope, reader custody and the retained 403 error. The reader derivative is not original-byte custody. Acquisition is complete; no broader branch was opened.