Systemic Manipulation, Child Vulnerability, and the Regulatory Deficit in Ofcom’s Framework

The most potent vectors of digital harm today are not merely located in what is seen , but in how interaction is engineered —through asymmetries of choice, misaligned incentives, and design architectures optimised for extraction rather than wellbeing.

In the absence of a regulatory duty to assess how a service elicits and sustains interaction , oversight is reduced to procedural formalism, concerned more with what is visible than how visibility itself is engineered .

To meet this challenge, the regime must evolve from content-centred regulation to systems-level accountability —from evaluating discrete outputs to interrogating the design logic of digital environments. This requires a shift in regulatory maturity: what might be called a second-order regime , one that targets architectural manipulation as a first-... See more

Second-order regulatory maturity entails more than extending existing duties—it requires reimagining platforms not as passive hosts of content, but as engineered environments whose very structure determines the distribution of risk, attention, and agency. Absent this evolution, the regulatory model risks collapsing into performative governance : ad... See more

By failing to name and frame manipulative design practices, the guidance forecloses regulatory attention to the intentional structuring of user behaviour through interface , leaving the architecture that governs exposure, prolongs engagement, and shapes digital habitus unexamined. It also limits the evidentiary expectations placed on service provid... See more

Regulating outputs without confronting the architecture that generates them is fighting symptoms while ignoring the cause. Protecting children online demands a shift from content oversight to interactional governance, a move that recognises interface design not as neutral scaffolding but as a potential vector of systemic harm

A child need not encounter violent, pornographic, or hateful content to suffer profound harm; it is enough to be entrapped by infinite scroll mechanisms, gamified feedback loops, or pseudo-choice interfaces that distort perception, erode self-control, and monetise vulnerability. These harms are not accidental—they are deliberate artefacts of behavi... See more

Techniques such as friction asymmetry (e.g., seamless opt-ins but complex opt-outs), visual priming , confirmation bias exploitation , time scarcity cues , and gamified compulsion loops are not ancillary features; they are the core infrastructure of monetised digital interaction

The regulatory architecture gestures toward individual functionalities but stops short of situating them within a broader understanding of systemic behavioural manipulation . No coherent framework compels providers to interrogate how their design logic —the orchestrated configuration of friction, salience, and reward—may itself constitute a source ... See more