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The regulator asks for your moderation figures: could you answer within 15 days?

Published 2 November 2026Updated 3 November 20268 min readBy Pleenk Approve

The regulator asks for your moderation figures: could you answer within 15 days?

Picture a Tuesday morning. An official email arrives. The regulator wants to know how many reports your platform received last year. It also asks how many pieces of content you removed, and how quickly. Finally, it wants the number of banned accounts and the number of appeals handled. You have fifteen days. Your team moderates every day, seriously. But nobody has ever counted.

For the founder of an adult or creator platform, this situation is very real. It has just become even more so. On 30 October 2026, London's High Court rejected a challenge by Meta, TikTok and X. The three groups were contesting information requests from Ofcom, the UK's communications and online safety regulator. So the largest platforms in the world cannot refuse to hand over their moderation figures. Neither will a mid-sized platform.

The short answer: a regulator will not only judge your moderation. It will also judge your ability to prove it, with figures and on time. Not answering, or answering badly, is an offence in itself. The good news: these figures cost almost nothing if you build them into daily work from today.

What happened in London on 30 October?

In February 2026, Ofcom sent formal information requests to Meta, WhatsApp, TikTok and X. Ofcom relied on the Online Safety Act, the UK law on online safety. It wanted detailed moderation indicators: content removed or made less visible, restricted accounts, user complaints. It also asked for appeals against moderation decisions and for users' exposure to harmful content. The data goes back to January 2024. It is due in three waves, until March 2027.

The platforms challenged these requests in court. In their view, Ofcom was bypassing the rules set for transparency reports. They also argued that the data was not necessary and that the effort required was disproportionate. X spoke of a cost of several million pounds. The High Court rejected all these arguments. For the judges, it is enough that Ofcom rationally considers it needs this information. As for the cost, the platforms failed to show how much of it really came from these requests.

Ofcom said it was open to discussing other data or extra time. But the principle is set: asking for moderation figures is part of a regulator's job.

Why is this your issue, even if you are not Meta?

Because this power does not only target the giants. Ofcom's very first fine under the Online Safety Act dates from October 2025. It targeted 4chan, an online forum that had not answered an information request. The amount: £20,000, plus £100 per day until the answer arrived. What was Ofcom asking for? A copy of the illegal content risk assessment, and worldwide revenue. Nothing exotic.

The UK goes further on a point founders often overlook. When a platform answers an information request, it may have to name a responsible senior manager. Imagine the company fails to comply with the request, gives false information or destroys data. That manager can then be held criminally liable if they did not take all reasonable steps to prevent it. This is section 110 of the Online Safety Act. Answering the regulator is not a formality to hand to an intern.

In the European Union, the logic is the same. The Digital Services Act (DSA) is the EU regulation on digital services. It allows the regulator appointed in each country to demand information. In France, that regulator is Arcom. In October 2026, Arcom gave Mym, a French creator platform, fifteen days to explain itself. Its concerns included Mym's terms of service and its recommender systems. These systems decide which content each user sees. Inaccurate, incomplete or misleading information can cost up to 1% of annual worldwide income or turnover (Article 52 DSA).

Finally, even without an investigation, the DSA already requires a transparency report. Every year, before the end of February, online services must publish their moderation figures. They follow a template common to the whole EU, in force since 1 July 2025. Micro and small enterprises are exempt, but not the others. When a platform covered by the rules takes a moderation decision, it explains it to the user. It must also send that explanation to a public database run by the European Commission. In other words, many of the figures you will be asked for in an investigation are ones you should already be producing.

Which figures will you be asked for, in practice?

They boil down to a few simple questions. Your bank and your PSP often ask them too, in another form. The PSP is the provider that lets you accept card payments.

What is reported to you, and how fast do you react? The number of reports received, by reason: illegal content, non-consensual content, suspected minor, fraud. And the time between the report and the decision.

What do you remove, and why? The number of pieces of content removed or restricted, and the reason for each decision. That reason must point to a specific rule in your terms of service or to a law. A decision without a clear reason can neither be counted nor defended.

What do you do before publication? The share of content checked before going live, by artificial intelligence (AI), by a human or by both. For an adult platform, this is also what card networks such as Visa and Mastercard expect.

Who uploads, and who appears? The number of verified creators and co-performers, with the date of their verification. These figures prove that each piece of content is linked to real people.

What happens when someone appeals? The number of appeals, how long they take to handle and the share of decisions reversed. A high reversal rate is not necessarily a bad sign. It shows that the appeal process works.

Whom have you removed? The number of suspended or banned accounts, the reason, and how many tried to come back. If a banned user can return with a new email address, this figure does not mean much.

Regulators also ask for figures on visitor age verification. But the essentials happen inside your platform.

What we would do in your place, starting this week

Make every decision a data point. For each removal, restriction or ban, record four pieces of information. They are the date, the author (a person or a tool), the reason, and a link to the content and account concerned. Pick the reason from a closed list that mirrors your terms of service. Everything else relies on this data. It also lets you explain the decision to the user.

Name a person and write the procedure. Who receives the regulator's request? Who extracts the figures? Who approves before sending? Within what time? One page is enough. In the UK, this person may become the senior manager named in the answer. So they need to know what that role involves.

Run a dry run every quarter. Take the list of questions above and try to answer it in two hours. The points that get stuck show you what is missing. It is far less stressful to discover them on an ordinary Tuesday than with a fifteen-day deadline.

Link decisions to a person, not to an account. A ban, a payout freeze or a removal should be attached to a verified person. Your figures then become credible. And the same individual can no longer reappear under three usernames.

Write the method next to the figure. How do you count a report received twice? Or content removed and then put back online? Write your rules down. A regulator forgives an imperfect but clear method more easily than a figure nobody can reproduce. If you cannot meet the deadline, ask early for an extension and explain why. Do not send a vague answer.

Reuse the same file everywhere. The figures that answer the regulator also reassure your bank. Your PSP will ask for them at its annual review. And they are the ones in your February transparency report. One effort, four uses. You spent months getting your bank account and your PSP. This file also helps you keep them.

How Pleenk Approve can help

The core of Pleenk Approve is a single digital identity. Every creator and every co-performer is verified with a liveness check. Their identity is encrypted by Pleenk and stored in a single wallet: your platform receives proof, never the ID document. Everything is linked to that wallet: their accounts, their consents, the bank account that receives their earnings and any bans. Every step is dated. Pleenk also measures your response times, for example how long it takes to remove content after consent is withdrawn. Your moderation remains yours: Pleenk connects to your AI moderation tool and keeps proof that the checks were done. Your evidence is ready when a regulator, a bank or your PSP asks. Want to know whether you could answer an information request today? Write to us at contact@pleenk.com.

This article is for information only and does not constitute legal advice. Have your procedures validated by your legal counsel, especially for country-specific obligations.

Sources

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