Ofcom has launched a consultation on draft guidance on so-called ‘super-complaints’ under the Online Safety Act 2023.

As the draft guidance explains, super complaints are complaints made to Ofcom by expert organisations representing users or the public which relate to matters that (a) risk causing serious harm, (b) significantly affect people’s right to free expression, or (c) otherwise have a significant adverse impact on UK users or members of the public. Generally, they should concern more than one regulated service or service provider, and relate to features of the regulated services that give rise to such risks, or to the conduct of the organisations that run the services, or both.

Not everyone can make a super-complaint: the draft guidance sets out and explains the eligibility criteria, namely that the relevant entity must (1) represent the interests of users or members of the public; (2) act independently from regulated services; (3) contribute significantly, as an expert, to public discussions about online safety matters; and (4) have due regard to Ofcom’s super-complaints guidance.

For those that meet the qualifying criteria, the guidance describes how super-complaints should be made, including the form they should take, what details they should include, and what evidence should be provided. Ofcom also sets out its own processes for handling super-complaints. For example, the draft guidance details how it will assess the admissibility and substance of a super-complaint, as well as what information will be published once Ofcom has performed its role.

The draft guidance is also accompanied by a super-complaints submission template, a checklist for whether an organisation is eligible to make a super-complaint, and a more digestible ‘simple guide’ to online super-complaints.

The consultation closes on 3 November 2025, and the draft guidance can be read in full here.