Observed 9 September 2026. Bounded acquisition following the latest forest assessment; no canonical case edits. This packet follows the Online Safety Act Network (OSAN, predecessor name of the current Online Safety Network) from submissions into regulator responses. It does not reassess the whole current Online Safety Act regime.
The strongest new pattern is selective, attributable uptake with explicit resistance. These records establish that the network's arguments entered the decision process and received substantive answers. They do not establish control of Ofcom, preferential treatment of the network, or a donor-to-regulatory-decision instruction chain. The prior UK operator and articles packets supply organizational context only.
1. Illegal-content inference: proposed interpretation not accepted
Submission. OSAN's Full response to Ofcom's consultation on protecting people from illegal harms online is internally dated February 2024, with Maeve Walsh as contact (PDF/printed p2). Its pp25–26 argue that the regulatory threshold should be understood against a civil balance of probabilities, allowing consideration of wider contextual evidence. The cyberflashing example refers to widespread harm and limited countervailing interests, expressly contrasting difficulties around suicide offences. It is therefore inaccurate to recast the original as a universal test that any speech without apparent benefit should be illegal. [Ofcom-hosted original response, pp25–26](http[local research file]
Disposition, 16 December 2024. Ofcom identifies OSAN and cites those pages in Volume 3: Transparency, trust and other guidance, 2.19 and footnote11, PDF/printed p10. At 2.20–2.21, pp10–11, it declines the proposed departure: the Act requires reasonable grounds to infer all necessary offence elements; the appropriate inference depends on the offence and context. Ofcom also invokes the expression costs of erroneously treating large quantities of lawful activity as illegal. It agrees that this is not the criminal beyond-reasonable-doubt threshold, while denying that its consultation applied that threshold. This is an explicit adverse disposition of the proposed interpretation, not a court determination that OSAN's legal argument was invalid. [Ofcom decision, 2.18–2.21](http[local research file]
Personal contribution boundary. A separate network article by Lorna Woods, dated 15 February 2024, makes this contextual civil-threshold argument under “Burden of Proof in a Civil Regime.” It supports a named public intellectual contribution. The full February response's contact field alone does not prove Walsh wrote every passage. [Woods article](http[local research file]
2. Search results: accepted register clarification, without expanding statutory scope
Submission. The February response's PDF/printed p97 identifies a mismatch between the risk discussion, thumbnails/click-through pathways and the presentation of search obligations, including direct and indirect routes to harmful material. It provides a concrete concern about how the risk assessment and proposed measures fit together. [OSAN response, p97](http[local research file]
Disposition, 16 December 2024. Annex 1: Further stakeholder responses, A1.9.9–A1.9.10, PDF/printed p94, attributes the concern to OSAN (footnote486, p97). Ofcom says it amended Register of Risks paragraph24.13, agreed with the wider risks highlighted and reiterated them in 24.10–24.14. It simultaneously confines “search content” to the Act's definition: content in results or reached through interaction with them, excluding subsequent interactions; footnote487 cites s57(2) and (5). This supports an OSAN concern → acknowledged amendment of the risk register edge. It does not establish expansion of statutory liability, a new content-removal mandate or adoption of an unrestricted downstream-link duty. The final register was not independently acquired and compared in this pass; the amendment is expressly reported by its issuing regulator. [Ofcom Annex1, A1.9.9–10](http[local research file]
3. Children's minimum ages: regulator credits feedback including OSAN; exact clause authorship remains open
Dated network contribution. The full Protection of Children Consultation: Response from Online Safety Act Network names Professor Lorna Woods and Maeve Walsh on PDF p1 and is dated July 2024 on p2. Its Issue8, pp66–69, criticises reliance on age gates without changing underlying service design, discusses under-13 detection and different-age experiences, and seeks clearer effectiveness metrics plus use of information-gathering powers to establish companies' capabilities. It also supports Ofcom not selecting a particular tool. These are differentiated proposals, not an uncomplicated demand for universal identification. [OSAN response2, pp1–2 and66–69](http[local research file]
Actual decision, 24 April 2025. Ofcom's children's statement Volume3: Assessing the risks of harms to children online, 8.170–8.171, PDF/printed pp36–37, clarifies that declared minimum ages in terms of service and self-declared ages are insufficient evidence for risk assessment. Without highly effective age assurance enforcing a minimum age, providers should conservatively assess the likely presence and ages of younger children. Ofcom calls these minor drafting changes in this statement. This particular decision is guidance on evidential assumptions for risk assessments: it does not, by itself, require every service to set a minimum age or every user to present identity documents. [Ofcom April decision, 8.169–8.171](http[local research file]
Explicit attribution, published 15 May 2025. In the Secondary Legislation Scrutiny Committee's 25th Report, paragraph23, Ofcom's answer credits changes reflecting civil-society feedback including OSAN, giving the minimum-age clarification as its example. It also denies assigning greater weight to any stakeholder group. The Committee describes OSAN's formal submission and publishes Ofcom/DSIT responses; it records OSAN's continuing dissatisfaction at 24 and says at 26 it does not adjudicate the competing arguments. This is stronger evidence of recognized contribution than similar wording or a meeting. It is weaker than an exact accepted-edit record or proof OSAN originated the measure. [SLSC report, paragraphs11,23–26](http[local research file] [Report publication date](http[local research file]
The July response's inspected age-assurance section does not contain the exact minimum-age formulation; text searches of both published OSAN response files also returned no exact “minimum age” match. That negative is limited by PDF extraction and terminology. The April statement's nearby stakeholder footnotes do not uniquely identify an OSAN sentence behind this edit. Consequently, retain the edge as Ofcom publicly credited OSAN among contributing civil-society respondents, not Ofcom adopted Woods/Walsh's specified minimum-age clause.
Authority and chronology boundaries for integration
The network is a submitter and advocate in these records. Woods and Walsh are named authors of the July response, not thereby statutory committee members or holders of regulatory approval rights. Targeted Ofcom searches did not establish a formal appointment for either; an unrelated result names Siobhan Walsh, not Maeve Walsh. This pass makes no claim that no formal role exists anywhere.
The November2023 consultation title describes the consultation's opening period, not the response date. The illegal-harms response itself says February2024. Ofcom's current consultation page displays 20 November 2024 alongside the main response download; that is not treated as its submission date. [Ofcom consultation chronology and response listing](http[local research file]
The reported decisions are historical December2024 / April–May2025 decisions. They are not presented as a complete current-law statement on 9 September2026. A later review must distinguish a subsequent change from reversal of these attributed decisions.
Suggested precise relations for root, without creating canonical entries here:
| Relation | Record-supported verb and limit |
|---|---|
| OSAN → February2024 illegal-harms response | Submitted an identified consultation response; exact day not established |
| Ofcom → OSAN inference proposal | Declined proposed interpretation in published December2024 response |
| Ofcom → OSAN search-scope concern | Acknowledged and reported amending risk-register wording; statutory scope retained |
| Woods + Walsh → July2024 response | Named co-authors |
| Ofcom → OSAN / minimum-age clarification | Publicly credited OSAN among contributors in May2025; no exclusive or verbatim authorship proof |
| OSAN → SLSC | Formal submission considered during scrutiny; this confers no committee membership or adjudicatory power |
Source custody and actual reading scope
Retained reader capture: uk-disposition-reader-extracts.json, SHA256 c15aa176a8a012bfe25cb819787c8c6661d30a1e10ce697234cd06d35d1c22cc. It contains the three scoped public web-reader result groups. It is a derivative text capture, not the original PDFs and not their hashes. Context returned by the reader extends beyond the selected paragraphs; no complete-volume audit is claimed. The operative passages inspected are listed above.
Retained original: uk-disposition-woods-icjg-2024.pdf, ordinary public GET200, 2,062,645 bytes, SHA256 4097e729563bd10b42046cc8d5392c2d5a688aef8a11d5ea219a7df18bec530f, nine pages. Source: [network-hosted article PDF](http[local research file] Text extraction did not expose the relevant heading; this PDF has not been visually audited and is not the evidential basis of the article summary. The corresponding public HTML was successfully read through ordinary GET, including the named author/date and civil-threshold section.
Ofcom's full February response was read through the public PDF reader at pp1–2,25–27 and97 plus date searches. July response2 was read at pp1–6 and66–69, with surrounding reader context; response1's cover/initial sections were read and an exact-term search performed. Ofcom's December Volume3 was read at cover and2.18–2.21; Annex1 at cover andA1.9.9–10 with surrounding search-moderation context. April Volume3 was read at cover and8.169–8.179. SLSC report was read at paragraphs11 and17–26 plus publication metadata.
Access gaps: the separate Ofcom “Our approach to developing Codes measures” PDF gave a reader error and ordinary GET403; that acquisition branch is closed and no unseen safe-harbour disposition from it is claimed. Network HTML initially failed through the web reader but ordinary GET succeeded. A direct Parliament HTML capture returned403; its public reader text was accessible and retained. No access controls were bypassed. No original Ofcom PDF hash is supplied. No visual proof of fine layout, handwritten annotation or hidden/redacted text is asserted.
Coherent stopping point and next separating record
The three decisions satisfy this run's contribution-to-disposition test: an adverse interpretation decision, an expressly reported amendment, and regulator-attributed contribution to a concrete guidance clarification. No further acquisition is needed before the parent's whole-case reassessment.
The most useful next record is Ofcom's consultation-response coding/decision log or drafting version comparison for April2025 paragraph8.171, with the cited OSAN input and approval trail. Custodian: Ofcom's online-safety policy team / consultation records function. It would separate collective feedback attribution from the exact authorship and decisive influence of a particular proposal. For the search issue, the already published final Register24.10–24.14 and its consultation predecessor would resolve the small remaining text-diff question. Neither missing record warrants claiming that influence was absent; neither is needed to invent donor instruction or a veto. No request or outreach was made.