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Comment Moderation Policy for UK Publishers

Moderation labour models, toxic commenter management, when to open or close comments, and the IPSO and Online Safety Act 2023 liability implications of hosting reader comments.

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Why comment sections need a written policy

Reader comments were once treated as a low-stakes add-on to an article — a way to build engagement with minimal editorial oversight. That view no longer holds. Comment sections carry real legal exposure, real reputational risk, and real welfare costs for both moderation staff and for readers and subjects who are targeted within them. A written comment moderation policy sets out who is responsible for what, what content is removed and why, and how the publisher responds when a comment section becomes a source of harm rather than engagement.

This guide addresses the operational and regulatory dimensions of comment moderation specific to UK publishers, distinct from social media moderation, which is covered in our social media use guide.

Moderation labour: in-house versus outsourced

The choice of moderation labour model shapes almost everything else in a comment policy — response time, cost, and how quickly borderline cases reach an editor with the context to make a judgment call.

In-house moderation

  • 1Closer editorial context — moderators understand the story, the subjects involved, and any ongoing legal sensitivities.
  • 2Faster escalation to a section editor for content that requires an editorial judgment call, not just a rules check.
  • 3Higher cost per comment reviewed; difficult to scale to 24-hour coverage without a large team.
  • 4Better suited to publishers with a smaller volume of comments on sensitive or investigative content.

Outsourced moderation

  • 1Cheaper at high volume; specialist providers can offer around-the-clock coverage.
  • 2Requires detailed written guidelines up front, since outsourced moderators lack newsroom context.
  • 3Needs a defined escalation path back to an in-house editor for anything touching defamation, harassment, or a possible criminal offence.
  • 4Well suited to high-traffic general news sites where most comments are routine and rules-based moderation is sufficient.

Many mid-sized UK publishers run a hybrid model: outsourced first-pass moderation against a written rules document, with automatic escalation triggers (certain keywords, a report from a subject of the story, or any comment naming a private individual) routed to an in-house editor.

Managing toxic and repeat-offending commenters

A small proportion of commenters typically generate a disproportionate share of moderation workload and harm. A tiered response, applied consistently, protects both other readers and moderation staff:

  • First infringementComment removed, no account action. Automated or templated notice to the commenter explaining which house rule was breached.
  • Repeat infringementTemporary posting suspension (commonly 7 to 30 days) with a written warning that further breaches will result in a permanent ban.
  • Persistent or severe infringementPermanent ban from commenting, applied at account and, where feasible, device or IP level to reduce straightforward evasion.
  • Criminal-threshold contentContent that may constitute a criminal offence (credible threats, harassment, content relating to a protected characteristic that meets a hate-crime threshold) should be preserved as evidence, reported through the publisher's legal team, and referred to police where appropriate — not merely deleted.

When to open, restrict, or close comments

There is no obligation to allow comments on every article. Editorial judgment about which stories carry comments is itself part of a responsible comment moderation policy.

Comments typically closed by default:

  • Stories involving suicide or self-harm, consistent with responsible reporting guidance.
  • Stories about grief, bereavement, or recently deceased individuals.
  • Sexual offence reporting, particularly where a victim could be identified or targeted.
  • Ongoing criminal proceedings, where comments could create a contempt of court risk.
  • Stories about children or young people identifiable from the article.

For stories where comments remain open, publishers should retain the ability to close comments retrospectively if a thread deteriorates — for example, if a story attracts a coordinated pile-on against a named individual — rather than treating the initial decision to open comments as irreversible.

IPSO implications: publisher liability for reader comments

IPSO's regulatory framework treats reader comments as user-generated content, but publishers are not entirely insulated from Editors' Code obligations once they become aware of a problematic comment. Once a publisher has actual knowledge — through a complaint, a report function, or its own moderation review — of a comment that breaches the Code (for example, harassment of a named individual, or a comment revealing information that would identify a protected person), the obligation to act arises.

A documented notice-and-response process — logging when a complaint about a comment was received, when it was reviewed, and what action was taken — is the practical equivalent for comments of the corrections log for articles, and is the evidence a publisher would need to demonstrate compliance if a complaint about reader comments reached IPSO.

Online Safety Act 2023: what applies to comment sections

The Online Safety Act 2023 introduces duties for services that host user-generated content to assess and mitigate risks of illegal content and, for services likely to be accessed by children, content harmful to children. Recognised news publisher content itself benefits from a specific exemption in the Act, reflecting Parliament's intent not to duplicate press-specific regulation (IPSO/IMPRESS) with platform regulation (Ofcom).

However, the exemption is generally understood to focus on the publisher's own editorial content rather than automatically extending to every feature of a publisher's website, including comment sections, which are user-generated content in their own right. Publishers operating comment sections at scale should:

  • Assess whether their comment functionality brings any part of the service into scope of Online Safety Act duties, ideally with specific legal advice.
  • Maintain illegal content risk assessments proportionate to the scale and risk profile of the comment section.
  • Ensure a functioning reporting mechanism exists for users to flag illegal or harmful comments.
  • Keep records of moderation decisions in case of an Ofcom information request.

Protecting moderation staff and targeted journalists

Moderation work carries a genuine psychological cost, particularly for staff reviewing abusive, graphic, or threatening content repeatedly. A responsible comment moderation policy addresses staff welfare directly:

  • Rotate moderation duties rather than assigning one person to review the most toxic threads indefinitely.
  • Provide access to wellbeing support and a clear route to flag when moderation content is causing distress.
  • Give journalists who are personally targeted by commenters (rather than simply moderating them) a clear internal escalation path, separate from routine comment moderation.
  • Signpost affected staff to specialist support such as Glitch UK and the NUJ Online Safety Hub, both of which address online abuse specifically.

Quick-reference checklist

  • Written comment house rules published and linked from the comment box itself.
  • Moderation labour model chosen (in-house, outsourced, or hybrid) with a defined escalation path.
  • Tiered response for repeat offenders documented and applied consistently.
  • Default comment-closed categories defined for sensitive story types.
  • Notice-and-response log maintained for comment complaints, mirroring the article corrections log.
  • Online Safety Act exposure assessed for the comment feature specifically, not assumed to be covered by the news publisher exemption.
  • Staff wellbeing and rotation policy in place for moderation teams.
  • Escalation path defined for journalists personally targeted by commenters.

Frequently asked questions

Can a UK publisher be held legally responsible for defamatory reader comments?
Yes, in principle. A publisher that hosts reader comments can be treated as a publisher of that content once it has actual knowledge of an unlawful comment and fails to remove it promptly. The defence under the Defamation Act 2013 and the Electronic Commerce (EC Directive) Regulations 2002 for hosting third-party content generally depends on acting expeditiously once notified. This is why a functioning notice-and-takedown process, not just pre-moderation, is a legal necessity, not only good practice.
Does the Online Safety Act 2023 apply to a newspaper's own comment section?
The Online Safety Act 2023 primarily targets user-to-user services and search services, and recognised news publisher content itself is generally exempt from the Act's core duties. However, comment sections attached to news articles are user-generated content and can fall within scope depending on the service's categorisation and scale, which is why larger publishers with substantial comment communities should assess their Online Safety Act obligations separately from their IPSO or IMPRESS obligations, ideally with legal advice specific to their platform's size and design.
Is it acceptable to close comments on a story entirely?
Yes. There is no obligation under IPSO, IMPRESS, or general UK media law to offer comments on every story, and many UK publishers close comments by default on stories involving grief, suicide, sexual offences, or ongoing legal proceedings, where the moderation risk and potential for harm to named individuals is highest. Selectively closing comments on sensitive categories of story, while keeping them open elsewhere, is standard and defensible editorial practice.
Should comment moderation be handled in-house or outsourced?
Both models are common in UK publishing. In-house moderation gives closer editorial control and faster escalation to the newsroom for context-dependent judgment calls, but is costly at scale. Outsourced moderation (via specialist third-party moderation services) can handle high volume more cheaply and around the clock, but requires clear written guidelines and an escalation path back to an in-house editor for borderline or high-risk cases, particularly anything that could constitute defamation, harassment, or a criminal offence.
What support exists for journalists targeted by abusive commenters?
Glitch UK provides guidance and support specifically for people experiencing online abuse, including journalists, and campaigns on platform accountability. The NUJ Online Safety Hub provides sector-specific guidance for journalists dealing with abuse and threats connected to their published work, including advice on documenting abuse, escalating to platforms, and involving police where threats cross into criminal conduct.

Related guides

EthicsSocial Media Use — EthicsRead →EthicsCorrections Policy — Ethics OverviewRead →BlogOnline Safety Act — UK JournalistsRead →LawRight of ReplyRead →

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