UK Online Safety Act.
The Online Safety Act 2023 creates safety duties for user-to-user services accessible by people in the United Kingdom. This page explains how those duties apply to Circus and what we do to meet them.
What is the Online Safety Act?
The Online Safety Act 2023 (the Act) received Royal Assent on 26 October 2023 and is enforced by Ofcom, the UK's communications regulator. It creates binding safety duties for companies that operate user-to-user services — platforms where people can publish or interact with content created by other users — that are accessible by people in the United Kingdom.
The Act categorises services by size and potential risk. Circus is a user-to-user platform. As a new service, we expect to fall into the smaller provider category initially, with corresponding baseline safety duties. We have designed our platform from the ground up with those obligations in mind.
Our safety duties
The Act imposes several categories of duty. Our approach to each is set out below.
Priority illegal content
We are required to identify and swiftly remove priority illegal content — including child sexual abuse material (CSAM), terrorism, hate crime, and fraud. Our three-layer moderation system (content filters, AI detection, and human review) is designed to detect and remove such content before it reaches community feeds.
Protection of under-18s
The minimum age to use Circus is 16 globally. We apply age gates at registration and use automated checks to prevent underage access. Content that is harmful to children — including self-harm, eating disorder promotion, and bullying — is addressed by our moderation stack and community rules.
Illegal content risk assessment
We conduct and maintain a risk assessment identifying how illegal content could appear on Circus, the likelihood of it occurring, and the steps we take to mitigate it. This assessment is reviewed when we make material changes to the service and at least annually.
Reporting and complaints
Every post, comment, and profile on Circus has a Report button. Reports go directly to our Trust & Safety team. We also provide an in-app complaints mechanism for users who disagree with a moderation decision. Complaints are reviewed by a human and responded to.
Transparency reporting
We publish transparency reports covering content removal, account actions, and enforcement data. Our intention is to publish reports that are accurate, timely, and useful — without committing to a fixed cadence that we cannot guarantee at this stage of the company.
Clear and enforceable rules
Our Terms of Service and Community Guidelines set out what content and behavior is permitted on Circus, and the consequences of violations. These documents are written in plain language and are available without requiring an account.
Content moderation
Circus operates a three-layer moderation system designed to intercept violating content before it reaches community feeds.
Automated content filters
Hash-matching against databases of known illegal content (including CSAM) and profanity filtering run on every submission before any content is published. This layer operates with zero tolerance — matching content is blocked instantly.
AI detection
AWS Comprehend and AWS Rekognition analyze text, images, and video for policy violations including hate speech, graphic violence, sexual content, and self-harm imagery. Flagged content is held for human review before publication.
Human review
Our Trust & Safety team reviews flagged content and makes all final decisions. Human reviewers assess context, apply community-specific rules, and determine appropriate enforcement action. All decisions create an audit trail.
Designated safety contact
The Act requires designated safety officers for some categories of service. Circus Corporation's safety contact is Rowan Ware, Founder. All safety-related correspondence, Ofcom communications, and regulatory enquiries should be directed to the addresses below.
For content reports, safety concerns, and Ofcom-related enquiries about user safety.
Legal & RegulatoryFor regulatory correspondence, formal notices, and Ofcom enforcement communications.
Age assurance
Circus requires all users to confirm they are aged 16 or over at registration. We apply automated checks and use behavioral signals to identify potential underage users. Where we have reasonable grounds to believe a user is under 16, we suspend the account pending verification and contact the user for confirmation.
We do not permit monetization features (Creator Fund earnings and paid content) for users under 18, in line with our global minimum age for financial features.
User empowerment
Circus gives users meaningful controls over their experience. These include the ability to control who can reply to or react to their posts, who can send them direct messages, and whether their community is publicly searchable or invite-only. Creators can restrict membership and apply custom community rules beyond our platform-wide policies.
These controls are not locked behind settings menus — they are surfaced during community creation and post composition, where the decisions are most useful.
Ofcom and enforcement
Ofcom has the power to require information, audit our systems, issue improvement notices, and impose financial penalties for non-compliance. Circus Corporation takes these obligations seriously and will co-operate fully with any Ofcom information requests or investigations.
If Ofcom wishes to contact Circus in connection with the Online Safety Act, please use legal@circus.app. We will acknowledge within 48 hours and designate a point of contact for the relevant matter.