Addressing Illegal Harms on Small and Emerging Platforms: Regulatory Challenges and Gaps

The document argues that current online safety regulations, such as the EU's Digital Services Act and the UK's Online Safety Act, often prioritise larger platforms based on user numbers, leaving a gap where illegal harms are concentrated on smaller, high-risk services. It highlights the adaptive nature of terrorist networks that migrate between platforms to evade detection and notes that regulators often lack the real-time primary data needed for effective enforcement. The brief recommends a shift toward ecosystem-level interventions, improved data-sharing with non-governmental organisations, and the creation of risk-based prioritisation frameworks that do not rely solely on user thresholds.

• Illegal harms are frequently concentrated on a broad ecosystem of smaller or emerging platforms, some of which are ideologically opposed to regulation or lack the capacity to respond to threats, despite regulations like the EU DSA and UK OSA prioritising larger platforms.
• Terrorist and extremist networks are highly adaptive, using multiple platforms simultaneously and migrating between them to circumvent regulatory actions and account removals.
• Current regulatory frameworks in the EU, UK, and Australia often rely on user-number thresholds to assign obligations, which may fail to capture small but high-risk platforms that provide safe havens for malicious actors.
• Regulators face significant challenges in enforcing rules on emerging technologies like the Fediverse due to decentralised architectures that make it unclear who is accountable for removing content.
• Strict enforcement of the UK Online Safety Act has led some platforms, including Bitchute, Gab, and Kiwi Farms, to withdraw from the UK market via geoblocking.
• The 'whack-a-mole' problem persists, where improvements on one platform lead to a deterioration elsewhere as criminal actors migrate; for example, some white supremacist extremists migrated from Telegram to SimpleX in late 2024.
• A mapping of the top 20 platforms used by IS and Al-Qaeda between April 2024 and April 2025 shows a diverse jurisdictional spread, including the US, UAE, Switzerland, and France, with some services being self-hosted by the groups themselves.

APA

Bradley, A. (2025). Addressing Illegal Harms on Small and Emerging Platforms: Regulatory Challenges and Gaps. Institute for Strategic Dialogue. https://www.isdglobal.org/wp-content/uploads/2025/11/Addressing-Illegal-Harms-on-Small-and-Emerging-Platforms_Regulatory-Challenges-and-Gaps.pdf

Chicago

Bradley, Arthur. Addressing Illegal Harms on Small and Emerging Platforms: Regulatory Challenges and Gaps. Institute for Strategic Dialogue, 2025. https://www.isdglobal.org/wp-content/uploads/2025/11/Addressing-Illegal-Harms-on-Small-and-Emerging-Platforms_Regulatory-Challenges-and-Gaps.pdf.

Wikipedia

{{cite report |last1=Bradley |first1=Arthur |title=Addressing Illegal Harms on Small and Emerging Platforms: Regulatory Challenges and Gaps |publisher=Institute for Strategic Dialogue |date=2025 |url=https://www.isdglobal.org/wp-content/uploads/2025/11/Addressing-Illegal-Harms-on-Small-and-Emerging-Platforms_Regulatory-Challenges-and-Gaps.pdf |access-date=23 October 2026 |via=Climate Insights Directory}}

BibTeX

@techreport{bradley2025addressing, author = {Bradley, Arthur}, title = {{Addressing Illegal Harms on Small and Emerging Platforms: Regulatory Challenges and Gaps}}, institution = {Institute for Strategic Dialogue}, year = {2025}, url = {https://www.isdglobal.org/wp-content/uploads/2025/11/Addressing-Illegal-Harms-on-Small-and-Emerging-Platforms_Regulatory-Challenges-and-Gaps.pdf}, urldate = {2026-10-23}, note = {Indexed by Climate Insights Directory} }