That's an incorrect understanding. It creates a range of requirements for essentially any service with users in the UK if there is UGC or messaging.
Then there are additional requirements applied to 3 classes of services: Category 1, 2A, 2B. The latter have the thresholds as discussed above.
But, as usual, poorly written. eg a "Content Recommendation System" -- if you choose, via any method, to show content to users, you have built a recommendation system. See eg wikimedia's concern that showing a picture of the day on a homepage is a bonafide content recommendation system.
The definition
> (2)In paragraph (1), a “content recommender system” means a system, used by the provider of a regulated user-to-user service in respect of the user-to-user part of that service, that uses algorithms which by means of machine learning or other techniques determines, or otherwise affects, the way in which regulated user-generated content of a user, whether alone or with other content, may be encountered by other users of the service.
Then there are additional requirements applied to 3 classes of services: Category 1, 2A, 2B. The latter have the thresholds as discussed above.
But, as usual, poorly written. eg a "Content Recommendation System" -- if you choose, via any method, to show content to users, you have built a recommendation system. See eg wikimedia's concern that showing a picture of the day on a homepage is a bonafide content recommendation system.
The definition
> (2)In paragraph (1), a “content recommender system” means a system, used by the provider of a regulated user-to-user service in respect of the user-to-user part of that service, that uses algorithms which by means of machine learning or other techniques determines, or otherwise affects, the way in which regulated user-generated content of a user, whether alone or with other content, may be encountered by other users of the service.
https://www.legislation.gov.uk/uksi/2025/226/regulation/3/ma...
If you in any way display UGC, it's essentially impossible not to do that. Because you pick which UGC to display somehow.