Tackling online and influencer glamourisation of gun violence: a UK and European perspective

1. Abstract

Gun violence remains a significant public health challenge. The manifestation of gun violence in the United Kingdom and the European Union is significantly different from jurisdictions such as the United States due to stricter firearms regulations and lower rates of gun ownership. However, the increasing influence of digital platforms, online communities and influencers has created new pathways through which the use of firearms and related harmful ideologies are glamorised. This report prepared by the University of Essex Human Rights Centre clinic in support of Iain Overton, AOAV’s Executive Director, and his role as a co-Commissioner on the Lancet Commission on Gun Violence and Health, examines how online and influencer driven content contributed to the promotion of gun and gun adjacent violence within the UK and EU context. This report evaluates the extent to which the existing regulatory frameworks address the promotion of firearms, violence, misogyny, hypermasculinity and extremist ideologies particularly among vulnerable audiences.

This report finds that while current legislation provides significant oversight on formal advertising and illegal content, regulatory gaps remain where influencers promote harmful narratives through seemingly non-commercial content that falls outside traditional marketing definitions. This report further highlights the role of recommendation algorithms and online subcultures and micro influencers in amplifying violent norms which can shape attitudes towards weapons. Drawing on evidence from the UK, EU and comparative international examples, this report argues that the existing regulatory approaches inadequately address the wider influence by digital creators in causing societal harms. The report concludes by proposing reforms aimed at strengthening accountability, improving platform responsibility, redefining the term influencer and adopting a public health approach to reduce harmful online exposure and prevent the normalisation and glamorisation of violence in digital environments.

2. Introduction

Gun Violence is an escalating and yet preventable public health crisis.[1]  As an umbrella term, it encompasses various types of violence that involve a firearm, including mass shootings, smaller acts of violence and individual homicides and suicides.[2]  Current estimates indicate that approximately 600 people die per day due to civilian firearm-related incidents worldwide[3], with gun violence accounting for up to 71% of all homicides globally.[4] The rate of firearm homicides in the US remains the highest among high-income countries at 4.52 per 100,000 residents.[5]  In comparison, the rate in the United Kingdom (UK) is significantly lower at 0.01 per 100,000 residents.[6] Similarly, the average rate of gun-related homicides within the Europe is 0.03 per 100,000 residents.[7]  These statistical disparities may be attributed to cultural differences and considerably stricter gun ownership laws across the UK and EU.  

Culturally, gun ownership in these regions is viewed as a privilege rather than an inherent right,[8] and is governed by robust legislation, notably by (i) the Firearms Act (1968) (as amended) in the UK and (ii) Directive 2021/555 U.[9]  Indeed, the UK maintains some of the most restrictive gun laws in the world[10] and includes a near-total ban on handguns and semi-automatic rifles. While EU member states operate under a common framework that permits some limited national variation, largely to accommodate licensing for hunting or sport, applicants across both jurisdictions must undergo rigorous police background checks, medical screenings and strict storage inspections to obtain and retain a license. Consequently, rates of legal gun ownership in the UK and EU remain significantly lower than in the US,[11] which correlates with a lower frequency of gun-related crimes and shooting accidents, reinforcing the public health consensus that suppressing gun acquisition directly reduces overall rates of firearm-related injury and mortality.

While physical firearm violence is statistically lower in the UK and EU than in other global regions, the borderless nature of digital spaces allows transatlantic gun culture to subtly permeate local feeds, and in so doing, arguably presents an escalating public health risk. Whilst traditional drivers of gun violence such as poverty and gang violence remain highly relevant, the rapid expansion of digital platforms has introduced new mechanisms through which attitudes towards firearms are shaped and circulated.[12] Social media has altered how violence is represented and normalised particularly among younger audiences.[13] One key factor contributing to this is the growing role of online influencers and digital communities in constructing narratives around firearms.[14] Given its higher incidence of gun ownership and gun-related violence, it is perhaps not surprising that the majority of research into the glamorisation of gun violence by influencers through social media platforms has, to date, been focused on the US, finding that both gun manufacturers and individual influencers promoting guns, gun influencers, known as ’gunfluencers,’[15] often use platforms such as YouTube and Twitter to direct audiences to websites that facilitate firearm sales.[16]

Even without a deep gun tradition as demonstrated by the US, research, notably from the UK, highlights links between glamorisation of weapon carrying and violence.[17] While empirical evidence specifically mapping these dynamics within the UK and EU remains relatively limited, the impacts are still significant. As such, even where levels of gun violence are lower, the societal and psychological impacts remain intense and emerging risk factors, particularly those linked to digital environments, post new and not properly understood challenges[18].[19] 

Written by Essex University Law School Human Rights Centre Clinic, (“Clinic”) and designed to contribute to AOAV’s Executive Director’s role as a Co-Commissioner on the Lancet Global Commission on Gun Violence, this report evaluates firearm promotion within a broader, interconnected culture of violence. Because firearms are less prevalent in the UK and EU, this paper intentionally broadens the conventional conceptualisation of violence. This expansion is necessary to accurately reflect how these public health risks manifest in a localised context, capturing not only physical violence involving alternative weapons (such as knives), but also digital aggression, including online hate speech, misogyny, and targeted harassment (herein collectively defined as ‘gun-adjacent violence’.) Utilising a comparative and doctrinal socio-legal framework, this research analyses how gun and gun-adjacent violence is glamourised by influencers and online platforms, focusing specifically on addressing four key questions:

1. What is the current framework for regulating influencer marketing and firearm-related content in the UK and EU?
2. Where do current frameworks fall short in addressing influencer-led glamorisation of firearms and targeting of vulnerable populations?
3. What measures could strengthen oversight and reduce harmful exposure particularly among vulnerable populations via social media? Can good practice examples from other jurisdictions be found?
4. What kinds of accountability measures could be developed or reinforced to ensure that online platforms better manage firearm-related influencer content and its public health impacts?

3. Current Legal Frameworks in the UK and EU

In order to determine if current legal frameworks aimed at regulating influencer marketing and firearm-related content are actually effective, the Clinic first looked at what legal frameworks are currently in place and how they operate. In the UK and EU, the regulatory landscape for online content is split into two distinct tracks: the governance of the “tools” (i.e. the platforms) and the “enablers” (i.e. the influencers themselves and their messaging). This report will take each one in turn, starting with the platforms themselves to see how these controls play out in practice.

3.1 The Platforms (‘Tools”)

To evaluate how effectively the tools are being regulated, we must first examine the evolving statutory regimes designed to govern platform infrastructure. The UK Online Safety Act 2023 (OSA) and the EU Digital Services Act (DSA)[20] both represent a significant shift toward holding platforms accountable for their ‘digital architecture’ and the types of online content they allow to be uploaded.

For example, the OSA imposes a comprehensive set of legal duties on regulated service providers, including online social media platforms,[21] which include (amongst other things) a duty of care to implement systems capable of preventing, detecting and swiftly removing illegal content, such as the incitement of violence or the unauthorised sale of weapons.[22] 

Under the OSA, platforms ‘likely to be accessed by children’ have stricter duties.[23] They must use ‘highly effective’ age assurance (such as age verification or estimation) to prevent children from encountering Primary Priority Content harmful to children (e.g., pornography, and content promoting suicide, self-harm, or eating disorders).[24] They must also protect children from Priority Content (e.g., bullying, hateful content, or content which depicts or encourages serious violence or injury). by ensuring it is age-appropriate.[25] Notably, the OSA does not require platforms to proactively remove legal content that is harmful to adults. Instead, it mandates that the largest user-to-user platforms meeting certain thresholds conditions (’Category 1 Services,‘)[26] must a) be transparent about the specific legal content they choose to allow or prohibit in their terms of service[27], b) adhere strictly to those terms of service[28] and c) give adult users tools to filter out content they do not want to see or to prevent exposure to specific types of legal-but-harmful content[29], including enabling users to verify their identity to reduce interaction with non-verified users.[30] Enforcement is through the regulator, the UK Office of Communications  (Ofcom), which has significant powers, including the ability to issue fines of up to £18 million or 10% of a company’s annual global revenue, whichever is higher, for non-compliance.[31] In severe cases, Ofcom can apply to the courts to block access to non-compliant services in the UK.[32]

Similarly, the DSA applies to ‘intermediary services’[33] provided to service recipients (whether businesses or consumers) established or resident in an EU state, irrespective of where the service provider is located. By capturing hosting services, the DSA brings social media and online marketplace platforms under its scope.[34] Like the OSA, a higher level of regulation applies to some providers, in this case, those designated by the European Commission as ‘very large online platforms’ (VLOPs) and ‘very large online search engines’ (VLOSEs).[35] Legislating by way of a regulation (which applies directly rather than requiring implementing legislation) is intended to avoid different rules applying across EU Member States. Enforcement of the DSA is shared between national authorities and the European Commission through a tiered system. While independent ‘Digital Services Coordinators’ handle oversight at the Member State level, the European Commission retains exclusive, centralised authority to supervise and enforce compliance for designated VLOPs and VLOSEs.[36] Adopting a distributed approach reflects practical governance. Rather than relying on uniform, centralised EU oversight, this model utilises national authorities who are uniquely positioned to navigate the nuances of their specific domestic markets and regulatory cultures.

Under the DSA, platforms are primarily responsible for implementing ‘notice and action’ mechanisms, requiring them to act quickly to remove illegal content once notified[37]. For those designated as VLOPs or VLOSEs, the obligations extend to conducting systemic risk assessments to identify how their algorithms might amplify illegal material[38]. Crucially, the DSA mandates that all platforms accessible to minors must implement ‘appropriate and proportionate’ measures to ensure a high level of privacy, safety, and security for children[39]. This includes a strict prohibition on the presentation of advertisements to minors based on profiling using personal data – a measure designed to prevent the targeted marketing of harmful subcultures.[40] A key feature of this framework is the role of ‘trusted flaggers’[41], entities with proven expertise whose notices must be prioritised by platforms. This mechanism offers a significant opportunity for NGOs or industry bodies to ensure that expert-identified glamorisation or trafficking is addressed with urgency. Furthermore, VLOPs and VLOSEs must specifically assess and mitigate any systemic risks regarding the ‘protection of the rights of the child’, including the negative effects on their physical and mental health arising from platform design or algorithmic amplification[42].

3.2 The “Enablers”

Whilst influencers are not typically primary targets of online safety rules, they are nevertheless subject to consumer protection standards when promoting any products or services in a commercial context (incl. firearms or related lifestyle products). In the UK, content standards are primarily overseen by the Advertising Standards Agency (ASA), which enforces the ‘CAP Code.’[43] Consumer protection is enforced by the Competition & Markets Authority (CMA) through the Digital Markets, Competition and Consumers Act 2024. These frameworks ensure transparency by requiring clear disclosures around advertisements (such as #ad) to protect users from misleading practices. Within the EU, the Unfair Commercial Practices Directive (UCPD) provides a similar baseline[44].

In addition to basic transparency rules, both regimes in the UK and EU enforce strict boundaries and social responsibility guardrails regarding commercial digital spaces. Under the UK CAP Code, all marketing communications must be prepared with a strict sense of responsibility to consumers and society, and must contain nothing likely to condone or encourage violence or anti-social behaviour[45], which the ASA routinely uses to restrict content that links weapons to aggressive imagery, flippant language, or anti-social behaviour.

On a broader scale, Annex I of the Unfair Commercial Practices Directive (UCPD) explicitly forbids covert advertising to ensure influencers cannot legally disguise weapon-related sponsorships or corporate partnerships as organic, uncompensated lifestyle choices.[46] Crucially, these consumer guardrails also extend directly to gun-adjacent themes that cross over into wider societal harms, including general weapons, overt aggression, hate speech, racism, and misogyny.

Under rule 4 (Harm and Offence) of the CAP Code, influencer promotions and digital marketing communications are strictly prohibited from condoning or encouraging violence, or causing widespread offence, fear, or distress on the grounds of race, gender, religion, or sexual orientation.[47] An example of how this is successfully enforced can be seen in the ASA Ruling on ThruDark Ltd.[48] – an Instagram advertisement featuring a black-hooded individual aggressively advancing on and destroying a pink mannequin with a semi-automatic rifle, pistol, and concealed shotgun. ASA concluded that this advertisement irresponsibly glamorised guns, condoned gun violence and was in breach of rules 1.3 (Social responsibility) and 4.4 (Harm and offence) of the Code.

Similar to the UK regime, the EU’s consumer protection layout protects individuals from aggressive or coercive commercial practices under the UCPD,[49] while targeted discrimination and adjacent harms in commercial media feeds are met with strict structural prohibitions under Article 9 of the Audiovisual Media Services Directive (AVMSD).[50] This directive legally obliges Member States to ensure that all audiovisual commercial communications completely abstain from inciting violence or hatred against protected groups, while explicitly banning any commercial media content that undermines human dignity or encourages behaviour prejudicial to public health and safety.[51]

3.3 Online Terms & Conditions

While these statutory frameworks establish the baseline for formal commercial content, it would be remiss to ignore the secondary layer of oversight that directly governs influencers’ use of these digital spaces, i.e. the platforms’ own policies and terms and conditions. Both the UK and EU regulatory frameworks explicitly mandate that online platforms establish rules governing user behaviour and content via their terms and conditions. The DSA legally obliges intermediary services to outline clear restrictions regarding the information users can upload, requiring that these limitations be explicitly stated in their terms and conditions in a clear, plain, and unambiguous manner.[52] Similarly, OSA establishes statutory track duties that govern how platforms structure their terms of service. For services likely to be accessed by children, providers must explicitly set out in their terms of service how they intend to protect minors from encountering priority harms, including material that depicts or encourages serious violence.[53] For adult users on major platforms, Category 1 services must maintain absolute transparency and consistency within their terms of service, legally binding platforms to adhere to and enforce their own stated content policies regarding what legal-but-potentially-harmful material they choose to permit or prohibit.[54]  Nevertheless, while these terms and policies operate alongside hard law, the reality is that the actual enforcement and scope of these platform rules remain highly inconsistent in terms of coverage, format and marketing disclosure as discussed later in this report.[55]

4. Deconstructing the concept of ‘Influencer’

Before analysing why standard laws fail to restrict the online glamorisation of guns and gun-adjacent violence, we must first examine the ‘influencer’ as a specific target of regulation—and see how their methods systematically slip through statutory definitions.  There is currently no global consensus on what constitutes an ‘influencer’.[56]

Current regulatory frameworks in the UK and EU define ‘influencer’ primarily through a commercial lens, categorising them as active market participants only when their content satisfies specific advertising criteria. For example, the UK Advertising Standards Agency (ASA) adopts a broad definition as ’any human, animal or virtually produced persona that is active on any online social media platform, such as Facebook, Instagram, Snapchat, TikTok, Twitch, YouTube, and others’.[57] The EU Unfair Commercial Practices Directive (UCPD) defines the term in a similarly broad way as ’content creators who often advertise or sell products on a regular basis’ which would categorise them as ’traders’.[58] In each case, the influencer is historically deemed a commercial actor, triggering regulatory oversight only where an obvious commercial relationship exists between the brand and the creator. [59]

However, this narrow understanding of the sphere of influence of influencers has faced substantial academic critique for failing to capture the modern reality of social media influence. Scholars such as Goanta and Ranchordás argue that this definition is reductive, as it fails to account for the evolution of influencer business models that transcend simple paid endorsements.[60] Recent research emphasises that influencers have become “information gatekeepers” whose impact extends far beyond commercial activities, fundamentally shaping public opinion, democratic attitudes, and health-related behaviours.[61]

Further, as current regimes and understandings predominantly focus on ‘high-reach’ mega-influencers. This oversight approach systematically ignores the rising influence of micro- and nano-influencers who, despite their smaller follower counts, often maintain more devoted, intimate, and trusting audiences. Antoniou identifies this as a critical oversight, noting that these ‘trusted peers’ operate in the early phases of their professional journey and are often shielded from scrutiny because they fall below the professional or commercial thresholds of current regimes.[62]

As noted in the Council of the European Union’s 2024 conclusions, the impact of these influencers extends beyond their commercial activities[63] as their content impacts society, public opinion, and the personal views of their audience.[64] Thus, by focusing solely on commercial triggers, this fails to address the systemic public health risks including the harmfulness of online behaviour for individuals, negative impact of mis- and disinformation shared by some influencers, and the impact that influencers have on their audience that can affect democratic attitudes, values and political opinions, health, personal attitudes and career decisions.[65]

4. 1 The role of Gun influencers

Gun influencers also have a cultural influence on their audiences, affecting not only their purchasing behaviour but also their attitudes, values, and perceptions of firearms.  Experience from the US clearly highlights the connection between online influence (individuals and platforms) and the promotion or glamorisation of violence, including gun violence.  For example, Jordan et al. (2020) found that gun manufacturers use social media platforms such as YouTube and Twitter to direct audiences to websites that facilitate firearm sales in the US.[66] Furthermore, online enable social media influencers to glamorise and normalise guns by promulgating a consumption ideology, cultivating aspirational desires by associating gun ownership with affluence and American identity and culture, particularly relating to the Second Amendment, interpreted as fundamental to individual rights and freedoms and framing gun ownership as not just a consumer choice but as a constitutional entitlement.[67] 

Despite the strict laws governing firearm ownership and lower rates of gun violence in the UK and EU, there is still concern about the supply of illegalweapons across Europe and the UK (including reactivated weapons, counterfeit guns, imitation firearms and 3D guns), which research by the Royal United Service Institute and The Small Arms Survey states is an increasing threat.[68] Further investigation is required to establish if online influencers/gangs normalise firearms and/or sometimes facilitate access to illegal weapons, which may raise questions around platform enforcement and regulatory gaps.  Bridging the gap between physical trafficking and digital promotion requires a deep dive into the rules that currently govern these digital spaces.

Currently, there is limited literature indicating that the activities of gun influencers in the EU/UK directly contribute to the normalization of firearms, interest in acquiring them, or the promotion of violence. However, it is suggested that repeated exposure to violence and weapons leads to the normalization and status-seeking of violence and weapons, the creation of a culture that justifies them, and the promotion of weapon acquisition.[69] As such, a key consideration will be to look at the wider context of violence in this respect which may include online communities that promote toxic masculinity and normalize aggressive behaviour, misogyny and domestic violence (the manosphere), as well as the increase in far-right ideology.

5. Targeting of Vulnerable Populations by Online Subcultures Promoting Violence

Even without a deep gun tradition as demonstrated in the US, research, notably from the UK, negative socio-economic factors, particularly for youth, such as poverty and gang culture, can contribute to the glamorisation of violence in media.[70] Online subcultures can manufacture a ‘gun-adjacent’ masculinity/status script that normalises aggression. The Youth Endowment Fund (YEF) survey of 10,000 young people in England and Wales found that 70% of teenagers encountered real-life violent content online in the past year.[71] Significantly, 25% reported that social media platforms algorithmically suggested this content, highlighting the role of platform mechanisms in content dissemination.[72] Among children who encountered weapons-related content, 74% viewed content featuring knives,[73] and 39% stated that exposure made them more likely to carry a weapon themselves.[74] These findings demonstrate that online violent content has a measurable impact on young people’s attitudes and potential behaviours. Similarly, Catch22 (2017) documents that groups commonly recognized as ‘gangs’ upload content displaying young people holding weapons, engaging in violence, trespassing into rival territories, and stealing property associated with opposing groups.[75] These videos serve multiple functions within gang culture: Enhancing perceived status, humiliating and provoking rival groups and seeking revenge through public displays.[76] Given the large audiences these posts attract, individuals who upload such content feel pressure to maintain their reputations, which can lead to escalation of face-to-face violence.[77] The nature of online gang content creates a cycle wherein online posting drives offline violent behaviour.

5.1 Misogynist and Far-Right Online Subcultures

An example from the US in the link between subcultures promoting toxic masculinity and far-right political views and gun violence is the 2022 mass shooting in Buffalo by an individual radicalised by content on specific online platforms.  Research following this attack highlighted how gun-related content available on YouTube makes its way to other online platforms favoured by extremist groups, where it is mixed with extremist content.[78]

Despite much stricter firearm laws in the UK and EU and significantly far less gun violence, there are still some notable examples of the influence of these online communities and platforms resulting in mass shootings. One example from the UK is the 2021 shooting in Plymouth, UK, by an individual who had a fascination of guns and connection with online incel (involuntary celibate) communities.[79]  The influence of online incel communities was also a strong factor in a 2020 shooting in Hanau, Germany.[80]  Far-right political motivations were also a factor in the Hanau attack and such motivations were also a factor in a 2019 mass shooting in Halle, Germany.[81] What is particularly notable in the Halle attack is how it was inspired by a similar attack in New Zealand, demonstrating the transnational reach and influence of extremist online communities.[82]

As demonstrated above, although gun violence is low in the UK and EU, certain cultural and political online subcultures, can be important catalysts for violence offline in general, which can lead to gun violence and as such it is necessary to examine these when looking at whether and how legal and policy frameworks on online safety fall short in addressing influencer-led glamourisation of violence and firearms and targeting of vulnerable populations.  

It is necessary to examine more closely how online subcultures and influencers within these subcultures promote and normalise violence, including the use of guns and other weapons. Gender plays a key role in this through the disproportionate representation of male influencers and notions of masculinity in the online promotion of violence.[83] Of particular current concern are the influence of the Manosphere and certain elements within it, as well as political extremists.

While it is a different type of armed violence, the capacity of social media to turn masculinity toxic and lead to violence can be seen in research into youth violence and knife crime, which is more common in the UK, in Greater Manchester. This highlighted the important role that the perpetual, 24/7 nature of social media has on knife crime, through creating pressure to maintain a public image of masculinity that is associated with violence and aggression.[84] 

Although there are no agreed definitions, the term “toxic masculinity” has primarily been used to refer to men’s aggressive temperament, as well as homophobic or misogynistic behaviour and violence perpetrated by men.[85] This toxic masculinity has been influenced by notions that men must be strong and dominant to be masculine[86] and must assert themselves over others, notably women. This notion is a corollary of another key aspect of toxic masculinity that pushes the concept that men are socially and individually disadvantaged[87] and thus must act aggressively and potentially violently to address this. This reasoning forms the basis of “the manosphere”.

Emerging in the early 2000s, the manosphere is “an international collection of online communities including websites, forums, blogs, and social media accounts that discuss the issues relating to men, masculinity and men’s role in society.[88] The ideological core of the manosphere seeks a reversal of established knowledge, centred on the victimisation of men and an anti-feminist view that sees feminism as a tool to maintain female privilege.[89] Central to this worldview is the concept of hegemonic masculinity, defined by Connell as “the configuration of gender practice which embodies the currently accepted answer to the problem of the legitimacy of patriarchy, which guarantees (or is taken to guarantee) the dominant position of men and the subordination of women.” [90] Incels are an identity group within the manosphere,[91] driven by loneliness and frustration over their inability to find romantic or sexual partners.[92] They blame women for this, fuelling strong resentment.[93] To address their grievances and restore patriarchal order, some have even resorted to mass shootings.[94]

The initial premise of encouraging and supporting self-improvement is attractive, particularly to young men (and boys) who may feel lonely and isolated  Engagement with online groups or certain influencers can make individuals feel they are connecting with likeminded people which may initially feel very positive but can quite quickly turn negative.[95] Some influencers will reiterate messages of men being weak and disadvantaged to encourage more extreme views, in a manner that could be akin to grooming individuals and isolating them from the real world. As such the only relationships that vulnerable men and boys may have are those online with individuals encouraging them to reject anyone men to reject anyone who does not have the same views as them. 

Misogyny has also been found to be a dominant element in the online spread of extreme political views which have encouraged gun violence.[96] As demonstrated in the attack in Hanau, Germany, far right extremists are often radicalised in online spaces where hatred of women is promoted,[97] and further research has also linked incels with far-right violence.[98]  Another link between parts of the manosphere and political extremism, such as the far right, is the distrust or hatred of established statutory authority. Current research shows that access to guns makes it easier for radicalised men to commit such violence.[99]

Social media and online platforms have greatly contributed to firearm ownership as a marker of masculinity, going further than original connections with sport and hunting.  This in turn reinforces the view that gun possession is an essential element of male identity and authority.[100]  This has been demonstrated by social media posts by some extremist groups such as Islamic State.[101]  It has also been demonstrated through online gaming as highlighted by Action on Armed Violence. They have noted that within an increasingly unregulated world of video games, violence is a major component of masculinity with 63.6% of male characters enacting violence, with this violence being targeted against others 84.4% of the time. The study also showed 48.9% of male video game characters carrying or using a gun.[102] The influence of online gaming on children’s exposure to violence is also highlighted by UNICEF in a report on protecting children and mitigating risks from online gaming and influences towards organised violence.[103] Nearly nine in ten children in middle and upper-income countries (such as the UK and EU countries) play online games.  Such games can expose children to armed violence and also be used to exploit and groom children into participating in acts of violence and promote targeted hate speech.[104]   

Whilst establishing causation between exposure to violence and committing violence remains complex, the correlation between exposure and behavioural and attitudinal shifts is sufficiently strong and warrants serious policy attention. Ultimately, it can be inferred that, as with exposure to knife-related and gang violence content, repeated exposure to glamorised gun imagery may be associated with reduced empathy, risk normalisation, and an increased behavioural intention to possess or use weapons.[105] Over time, this can alter perceptions of what is acceptable or typical behaviour particularly in environments where offline experiences may already involve insecurity and a lack of institutional trust. This suggests that the digital architecture of social media platforms can act as a catalyst for physical violence.  From a public health perspective, these findings point to the existence of a digital-to-physical pathway whereby online environments act not merely as reflections of societal attitudes but as active contributors to behavioural risk factors. For policymakers in the UK and EU, this raises important questions about platform responsibility and the adequacy of existing regulatory tools. Whilst some progress has been made in addressing harmful online content such as extremism and misinformation, weapon related content has received limited attention in comparison.[106]

In addition to the role that individual influencers have in promoting or encouraging violence, including that involving guns and other weapons, algorithmic systems built by online platforms and social media companies also play an essential role in increasing the reach and spread of such content.[107]  The gaps in online regulations identified in this report include regulations for social media companies that allow violent content to spread as well as the conduct of online influencers.

When using social media, users are psychologically engaged by certain types of content, particularly if it is sensitive and of a nature that is very likely to incite violence or cause harm to others.  Posts may energise individuals but in a manner that spikes their anger.  People pay more attention to negative stimuli and outrage (whether it is related to perceived individual, gender-based or political hardship or discrimination).  As algorithms are built to prioritise content that gets the most engagement, it could be said that platforms and algorithms are therefore built and used through recommendation systems that result in violence.[108]  Furthermore, if left unchecked, algorithms will prioritise the worst content. 

Social media companies’ response to addressing harmful and dangerous content and safeguarding vulnerable users has been mixed.[109] As highlighted in a recent BBC documentary, safeguarding blocks have tended to be developed and incorporated into platforms after they have been launched.  Social media companies have not always acted proactively, despite the initial aim of such media to promote social benefit.  Actions, often taken after a serious act of violence encouraged by social media, to change the ranking and recommendations of content to put family and friends first or political and news content, have not necessarily been successful as content meant to promote division and harm has still been promoted.  Internal policies and systems (Trust and Safety Units) to address the posting and spreading of harmful and violent content and protect vulnerable and impressionable users have also been limited.[110]  Adolescents reported that they feel seeing violence on social media makes people feel it is acceptable and if offensive and dangerous material is reported it is often put back into feeds even if it is initially taken down.[111]

Concern has also been raised of the increase in ‘content that does not fit within formal legal frameworks – misogynist, antisemitic and racist abuse, that can easily contribute or result in violence, including gun violence.  The Police Counter-Terrorism Internet Referral Unit report thousands of pieces of such content in recent years, stating that there is an exceptionally high level.[112]

It is particularly concerning, therefore, that safeguarding mechanisms and capacity within social media platforms and companies has been greatly reduced in recent years. For example, in early 2025, Meta cut much of its content moderation and fact-checking processes on its platforms, getting rid of restrictions on content about gender and immigration.[113]  Facebook has been reported to state that social media platforms are not responsible for people’s actions.  However, violence or incitement to violence, including gun violence, is a social media problem.

6. Regulatory blind spots: Where the law falls short.

6.1 The Tools

Having evaluated both the statutory frameworks in place and real-world examples showing how online gun and gun-adjacent violence can nevertheless be glorified and promoted within the EU and UK (using the US as a comparison), it is clear that certain cases continue to slip through the regulatory net. To understand why these narratives, remain active despite current laws, it is necessary to identify where and why the system breaks down.

The first point of failure lies in the primary compliance framework for influencers: the contractual obligations set out in platform Terms & Conditions (T&Cs). As Pflücke observed, when these platform-specific rules are weak or inconsistent, they effectively undermine statutory consumer protections. Historically, this created a “hotchpotch” of private regulation: while platforms like YouTube and Meta developed sophisticated disclosure tools, others like Snapchat and Pinterest remained historically silent on hidden marketing.[114]

Although platforms have since evolved,[115] these guardrails still place the burden of transparency entirely on the influencer. This creates a significant loophole for the digital transition of gun and gun-adjacent violence where influencers are able to operate outside formal advertising channels to portray weapons and/or aggressive ideologies as symbols of status or empowerment. The lack of proactive platform enforcement forces influencers to navigate complex national laws independently, often leading to a default state of non-disclosure[116]. In the context of gun and gun-adjacent glamorisation, these regulatory gaps allow lifestyle-branded content to circulate as authentic personal opinion. Because this content blends seamlessly into the platform’s visual aesthetic rather than appearing as a formal ‘ad’, it evades scrutiny and regulatory oversight. Ultimately, as Pflücke notes, even robust UK or EU regulations can be rendered ineffective if a narrative falls outside a platform’s narrow technical definition of ‘sponsored content’.[117]

A potential regulatory gap arises in how these platforms handle content that is ‘lawful but awful’ – specifically influencer-led glamorisation that shapes harmful social norms without meeting the strict legal threshold for ‘illegal content’. While the UK’s OSA attempts to mitigate this for children through a proactive duty of care and age-assurance mandates for ‘priority content’[118], both the OSA and DSA struggle to hold platforms accountable for legal but harmful content shown to adults.  An attempt to address this has been made via section 15 of OSA which legally requires platforms to provide accessible user-empowerment tools, such as content filters and account verification options, to mitigate exposure to harmful content and anonymous harassment.[119] However, this framework suffers from significant structural limitations: it applies exclusively to Category 1 services—leaving users on smaller platforms unprotected—and arguably shifts the burden of safety onto vulnerable individuals rather than forcing platforms to fix systemic algorithmic amplification.[120] Furthermore, because effective content filtering often requires users to verify their identities, this mechanism creates secondary human rights challenges. It raises severe privacy risks through mass data collection, restricts free expression by marginalising anonymous whistleblowers, and introduces socio-economic inequalities if platforms place these vital safety and verification tools behind paid subscriptions.[121]

In a similar vein to the UK framework, the DSA attempts to give users more control over what they see via an additional requirement set out in Article 38, which obliges VLOPs and VLOSEs to offer a feed entirely free from profiling. However, this mechanism has been criticised for failing to provide users with a meaningful choice, as it forces them to sacrifice the platform’s core functionality just to escape the informal online gun culture driving these feeds; because platforms retain the power to design these interfaces as they see fit, this frequently results in safety tools being buried, shifting the burden of protection onto vulnerable individuals rather than forcing platforms to fix the algorithms that actively promote harmful content.[122]

Furthermore, because both frameworks focus on the ‘digital architecture’ of the platform, the individual influencers often remain shielded from direct accountability[123]. This lack of personal liability under safety rules necessitates a further look at the laws that govern the actual content that is uploaded to these platforms and how effective they are in shielding users – including vulnerable populations – from harmful ideologies and violence-adjacent narratives.

6.2 The Enablers

As noted earlier in the report, the ASA, together with the CAP Code and UCPD are effective tools for traditional advertising where the commercial intent is obvious. A clear example of this is the ASA ThruDark Ruling[124] where the explicit commercial content allowed the regulator to step in and swiftly restrict the content. However, where these regulatory regimes fall short is when they struggle to handle the more organic lifestyle promotion seen in gun-adjacent, hyper-masculine subcultures. In these spaces, influencers intentionally blur the line between personal opinion and commercial messaging, making it difficult to trigger standard marketing regulations in the absence of brand partnership.[125]

The most significant challenge for current UK regulation is the ‘payment plus control’ test,[126] which serves as the primary trigger for ASA to take action. Under current guidelines, a social media post is generally only classified as an advertisement – and subject to the CAP Code –  if there is both a transfer of value and editorial control exercised by the brand.[127] This results in a clear regulatory gap for ‘organic’ content that isn’t explicitly illegal but falls outside the traditional scope of commercial regulation. For instance, if a brand gives an influencer a free product but relinquishes all control over what they say about it, the content fails the second part of the test.[128] Similarly,  a manosphere influencer posing with a firearm to signal ‘dominance’ or ‘hustle’ often stays beyond the reach of consumer law because there is no payment or direct commercial transaction. However, the public health impact of normalising this kind of aggression can be far-reaching.

The EU landscape faces a similar struggle under the UCPD[129] While the UCPD traditionally focuses on ‘commercial intent,’ regulators are nevertheless increasingly apply a functional assessment of the influencer’s ‘gainful activity’ and ‘professional diligence’[130]to determine if their content, such as affiliate links or product, requires mandatory disclosure as a professional trader.[131] Recent shifts, such as the AVMSD, attempt to widen the scope of media oversight by categorising professional influencers with editorial responsibility as ‘on-demand media service providers’. This classification imposes stricter duties regarding the protection of minors and prohibits the incitement of violence, potentially capturing content such as ‘lifestyle’ glamorisation that escapes consumer law (however this only applies to videos but may not capture other content such as text, pictures or GIFs).[132]

Recognising the limitations of these broader directives, France has recently moved to establish a dedicated national framework, passing Law no. 2023-451 in June 2023 to specifically regulate ’commercial influence‘.[133] This legislation is significant because it codifies a clear definition of the influencer as a natural or legal person who, for remuneration or benefits in kind, promotes goods, services, or causes via electronic means.[134] Additionally, it imposes strict transparency requirements, such as the mandatory use of “advertising” or “commercial partnership” labels and introduces a new requirement for retouched or AI-generated images to be clearly identified. In addition, the French law prohibits influencers from promoting specific ’sensitive’ sectors – including aesthetic surgery, nicotine products, and gambling – sectors that are seen as particularly harmful to public health, often exploiting the same user vulnerabilities (appearance-based anxiety, financial desperation) often associated with hyper-masculine, gun-adjacent subcultures.  France has also pioneered a model of professionalisation through the “Responsible Influence Certificate” (’Le Certificat de l’Influence Responsable’), created by the self-regulatory body ARPP.[135] This certification attempts to move the regulatory focus from passive disclosure to active training, requiring content creators to demonstrate an understanding of ethical marketing and the protection of vulnerable audiences[136]. While the UCPD and AVMSD provide a baseline, France’s combination of direct legislative requirements and encouragement to adopt a formal ethical certification represents a best-practice model to professionalise the influencer’s social authority and address the lack of oversight inherent in unregulated digital spaces.

Nevertheless, even the pioneering French model remain restricted by the psychological reality of influencer consumption and its reliance on a commercial trigger. Both the AVMSD and the proposed Digital Fairness Act, like the French Law, only apply if a creator is officially classified as a professional ‘media service’ or if a clear commercial transaction is present, leaving a significant grey zone for the spread of non-commercial ideologies. In the manosphere and gun-adjacent subcultures, influencers exploit what Ducato describes as ‘media blurring’ – where ideological or ‘hustle’ narratives are diluted within a stream of everyday posts[137]. This lack of transparency prevents consumers from recognising the commercial nature of the content, thereby bypassing the natural critical filters they would normally apply to standard advertising. Because these influencers operate as ‘trusted peers’ rather than obvious commercial actors, they bypass the traditional ‘payment plus control’ scrutiny by framing misogyny or status-based violence as “organic” lifestyle content rather than a regulated service. This includes ‘hustling’ for brands – tagging products or displaying weapons to curate a specific aesthetic—without the formal paid sponsorship that would trigger disclosure rules set out in the French law or EU Directives. Their messages are perceived as sincere personal opinions.[138]

This is further exacerbated by the ‘Audience Size Bias’ in oversight. Regulatory focus including the ASA’s AI-driven monitoring in the UK[139] and similar initiatives under the EU’s Influencer Legal Hub,[140] tends to prioritise ‘high-reach’ mega-influencers.  This oversight systematically ignores the micro- (or nano-) influencers who, despite smaller followings, often maintain a more devoted audience and higher levels of intimacy and trust. In vulnerable communities, these ‘trusted peers’ are often the most effective at transmitting violent norms, yet they remain largely shielded because their activity falls below the professional thresholds of the current and upcoming EU and UK regimes.[141]

As such, the glamorisation of gun-adjacent culture is particularly dangerous when performed by micro-influencers at the ‘hustling’ stage. Because these influencers are often unmonitored due to a lack of formal payment or control, they can normalise gun-adjacent culture under the guise of ‘authentic’ personal experience, effectively bypassing traditional advertising scrutiny. Consequently, while both jurisdictions are robust in tackling traditional advertising, the decentralised and informal nature of micro-influencer narratives creates a significant pathway for the transmission of violent norms that remains virtually invisible to current regulatory frameworks.[142]

7. Recommendations on Strengthening Oversight and Accountability

The findings of this report indicate that, while high-level legislative frameworks such as the UK’s Online Safety Act and the EU’s Digital Services Act address digital architecture, they frequently fail to capture the informal, lifestyle narratives of online subcultures that promote extremist social (e.g. misogynist) and political views that can lead to violence, including gun violence. Current consumer protection laws are often toothless against these narratives because they rely on traditional markers of ‘commercial intent’ or ‘payment plus control’. Consequently, ideological and lifestyle-based influencer content – which effectively glamorises gun-adjacent violence – falls through the regulatory net, allowing harmful norms to spread as ‘authentic’ personal opinion. To disrupt this cycle of normalisation, we propose the following recommendations:

7.1 Redefining ‘Influencer’

To effectively address the normalisation of gun-adjacent violence in digital spaces, there must be a transformative shift in the regulatory understanding of what constitutes an “influencer”.[143] Current frameworks frequently fail because they rely on a purely economic model, viewing influencers only through the lens of transactional marketing. Instead, a robust human rights-based approach requires a perspective that recognises an influencer’s ability to materially shape social attitudes and behaviours throughout their entire career journey—from their initial experimental stages to professional bonding with brands.[144]

The prevailing regulatory reliance on ‘payment plus control’ parameters – where oversight is only triggered if an influencer receives a transfer of value and the brand exercises editorial control – is increasingly inadequate and creates a significant regulatory gap. Many influencers impact their audiences in profound ways that transcend selling products, such as through ‘hustling’ for brand attention or organic content that lacks a formal commercial contract but effectively glamorises violence or aggressive lifestyles. By pigeonholing practices into these limited parameters, regulators fail to acknowledge influencers who exert substantial influence without immediate monetisation, leaving vulnerable populations exposed to unmonitored harm.[145]

Following this recalibrated approach, we align with Antoniou’s endorsement of a more comprehensive and functional definition that moves beyond a purely economic model. Specifically, we reiterate the preference for the definition proposed by the House of Commons Culture, Media and Sport Committee,[146] which describes an influencer as ”an individual content creator who builds trusting relationships with audiences and creates both commercial and non-commercial social media content across topics and genres“. This broader concept is preferable as it accounts for the flexible nature of influencer agency across their entire career lifecycle.[147] It is also critical to acknowledge the 2024 EU position, which defines influencers as online creators who impact society, public opinion, and personal views through authenticity-based relationships.[148] The EU emphasises that their impact extends far beyond commercial activities, affecting democratic values and public health.

To close this gap, and based on the above, we recommend that this broader definition be codified within key legislative instruments to ensure that ‘organic’ influence no longer falls within a regulatory grey zone. Specifically:

• Expansion in the UK Online Safety Act (OSA): The definition of “Category 1” services and high-reach users[149] should be expanded to include creators who have significant influence, regardless of commercial ties. Ofcom should be granted the power to designate influencers as ’Socially Significant Creators’ based on their impact on public health and safety norms.[150]
• Harmonisation with the EU Digital Services Act (DSA): The European Commission should adopt a “Functional Impact” test within the DSA’s transparency requirements.[151] This would require platforms to hold influencers at the ‘hustle’ stage to the same content-moderation and transparency standards as commercial actors if their content reaches a designated threshold of engagement. [152]
• Modernising Consumer Law:  The Unfair Commercial Practices Directive (UCPD) should be updated to include “status-based promotion.” If a creator promotes a certain lifestyle (such as gun ownership) to build a personal brand for future gain, this should be treated as a commercial practice subject to regulatory oversight.[153]

Furthermore, effective oversight must recalibrate its thresholds to move beyond a focus on high-reach mega-influencers. Regulators (such as Ofcom, the European Commission and the respective EU national regulatory authorities) must also include nano-influencers who, despite having a smaller reach, often maintain deeper levels of trust and intimacy with their audiences[154]. This intimacy makes their ability to normalise aggressive behaviour and firearm glamorisation particularly persuasive and dangerous for vulnerable populations.

To provide clarity for enforcement while addressing these non-commercial gaps, we propose a tiered regulatory model that distinguishes between different spheres of influence. This model would categorise (i) commercial influencers who have a clear and primary advertising focus, (ii) professional lifestyle influencers whose curated content monetises the shaping of social norms; and (iii) ideological or movement-based influencers. The latter category includes non-commercial actors, such as those within the ‘manosphere’, who normalise aggression and gun-adjacent violence as a lifestyle or identity script. This recalibration ensures that influencers are held accountable for the social norms they cultivate and the public health risks they facilitate, rather than solely the products they endorse.[155]

7.2 Trusted Influencer Status

To bridge the gap between commercial regulation and public health protection, we recommend the implementation of a mandatory ‘Responsible Influencer Certificate,’, modelled on the pioneering French framework established by the self-regulatory body ARPP.[156] Such certification must move beyond a purely transactional scope to adopt the ‘Functional Impact’ definition discussed above. It should serve as a license to influence that ensures creators understand their social responsibility before they enter formal commercial partnerships. This model should be copied and adapted as follows:

• Mandatory Training Modules: Implementation should require influencers to complete specific modules on the public health impacts of gun and gun-adjacent glamorisation and the psychological mechanics of ‘media blurring’.[157]
• Expansion of ‘Sensitive Sectors’: Just as the French law prohibits the promotion of gambling and aesthetic surgery due to their potential for harm[158], this certificate should categorise firearms and gun-adjacent violence as ‘sensitive’ content requiring heightened ethical scrutiny.
• Oversight and Verification: Oversight should be managed through a co-regulatory partnership between national media regulators (such as Ofcom) and industry self-regulatory bodies (such as the ASA). The regulator (Ofcom) should set the mandatory standards for training, while the self-regulatory body (ASA) manages daily verification. Verification of the certificate should be integrated directly into platform architectures, allowing users to see a ‘Trust Label’ on the profiles of certified creators[159].

By making this certification a prerequisite for professional brand partnerships and a marker of “trusted creator” status for organic content, regulators can force a move from passive disclosure to a model where influencers must actively demonstrate an understanding of their social authority and the risks their content poses to vulnerable audiences.

7.3 Commitment to Improving Accountability of Online Platforms

Both the OSA and DSA contain codes of conduct for user-to-user services, including online platforms.  The OSA covers codes of conduct for both user-to-user services and search services and confirms the role and responsibility of Ofcom to monitor and raise complaints.  Complementing the DSA, the EU has additional regulations including a Code of Conduct countering illegal hate speech online – aimed at strengthening how online platforms deal with online content that the EU and national laws deem as illegal hate speech.[160] Relevant resources examined for this paper have highlighted that Trust and Safety Units of online platforms are challenged in their mandates to monitor and address harmful content due to how algorithms are developed and managed.[161] It is essential that there is a requirement for engineering departments and trust and safety Units within online platforms and social media companies to work together to ensure that online safety is prioritised and that permanent as well as prompt action is taken to remove harmful and illegal content within the timeframes stipulated within statutory codes of conduct.  In addition to types of online content, collaboration between engineering and trust and safety departments within social media platforms, attention must also be made monitoring and addressing the addictive nature of social media and the role that algorithms have in promoting additive habits.  This need is highlighted in a US court case in March 2026 in which Meta and YouTube were successfully sued by a young woman for the harmful effect on her mental health due to the intentionally addictive nature of their platforms.[162]          

7.4 Additional Public Health Interventions

Regulatory fixes must be paired with public health interventions aimed at building societal resilience. This includes the implementation of digital literacy training specifically for vulnerable groups, helping children and young men activate self-defence mechanisms against deceptive ‘media blurring’ techniques that disguise ideological messaging as personal opinion.[163] In the UK, many education authorities support training within schools on digital safety and AI as well as training for teachers on how to address misogyny with children.  There are also examples of collaboration between communications companies and specialist NGOs in the development of online curricula for school children.  An example of good practice in this can be seen in the Skills Upload online curriculum developed by Vodafone and Save the Children which is available within a number of EU countries.  The curriculum targets children aged nine years+ and includes modules on critical thinking and digital boundaries, understanding algorithms and what to do if exposed to harmful or inappropriate content.[164]  Other areas for partnership between online platforms and specialist agencies, including expert NGOs is in “trusted flaggers” – to prioritise the removal of content that contributes to the social normalisation of firearm aggression, treating it as a critical public health risk factor. It is notable these examples focus on children.  By bridging the gap between public health, digital regulation, and consumer protection, these recommendations seek to inform targeted interventions that contribute to meaningful change in the life outcomes of communities affected by gun and gun-adjacent violence.

7.5 Addressing gaps in evidence 

As has been highlighted in this report, there is limited evidence examining the links between gun violence and online influencers and glamorisation of violence within the UK and EU (in comparison to the US). Whilst emerging evidence has suggested how online influencers, algorithmic recommendations systems and online subcultures such as the manosphere can contribute to the normalisation of violence and weapon carrying, there remains little empirical research which assesses how these dynamics operate within UK and European digital environments. To address this gap further interdisciplinary research should be conducted to examine the link between exposure to firearms and violence related content and the real-world behavioural outcomes specifically in the UK and EU. Particular attention should be given to vulnerable groups to strengthen understandings or emerging risks.

8. Bibliography

8.1 Primary Sources 

8.1.1 UK Legislation 

• Online Safety Act 2023 
• Online Safety Act 2023 (Category 1, Category 2A and Category 2B Threshold Conditions) Regulations 2025, SI 2025/226 
• Firearms Act 1968 

8.1.2 EU Legislation 

• Council Directive 2005/29/EC of 11 May 2005 concerning unfair business-to-consumer commercial practices in the internal market and amending Council Directive 84/450/EEC, Directives 97/7/EC, 98/27/EC and 2002/65/EC of the European Parliament and of the Council and Regulation (EC) No 2006/2004 (Unfair Commercial Practices Directive) [2005] OJ L149/22 
• Directive (EU) 2018/1808 of the European Parliament and of the Council of 14 November 2018 amending Directive 2010/13/EU on the coordination of certain provisions laid down by law, regulation or administrative action in Member States concerning the provision of audiovisual media services (Audiovisual Media Services Directive) [2018] OJ L 303/69 
• Regulation (EU) 2022/2065 of the European Parliament and of the Council of 19 October 2022 on a Single Market For Digital Services and amending Directive 2005/29/EC (Digital Services Act) [2022] OJ L 277/1 
• Directive (EU) 2021/555 of the European Parliament and of the Council of 24 March 2021 on control of the acquisition and possession of weapons [2021] OJ L115/1 

8.1.3 French Legislation 

• Loi n° 2023-451 du 9 juin 2023 visant à encadrer l’influence commerciale et à lutter contre les dérives des influenceurs sur les réseaux sociaux (France) 

8.2 Secondary Sources 

• Adnan A Hyder and Lorena Barberia, ‘Addressing Global Gun Violence: A Lancet Commission on Global Gun Violence and Health’ (2024) 404 The Lancet 1794 
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• Advertising Standards Authority, ‘Influencer Ad Disclosure on Social Media: Instagram and TikTok’ (May 2025) <www.asa.org.uk/resource/influencer-ad-disclosure-on-social-media-instagram-and-tiktok-2024.html> accessed 27 April 2026 
• Advertising Standards Authority, ‘ASA Ruling on ThruDark Ltd’ (18 October 2023) <www.asa.org.uk/rulings/thrudark-ltd-g23-1206049-thrudark-ltd.html> accessed 30 May 2026 
• Advertising Standards Authority, ‘Remit: Advertisement Features’ (4 February 2026) <https://www.asa.org.uk/advice-online/remit-advertisement-features.html> accessed 31 May 2026 
• Amnesty International, ‘GUN VIOLENCE’ <www.amnesty.org/en/what-we-do/arms-control/gun-violence/> accessed 31 May 2026 
• Antoniou A, ‘Navigating freezones in the Influencerdom: a shadowlands guide’ (2024) 29 Communications Law 8
• Antoniou A, ‘When Likes Go Rogue: Advertising Standards and the Malpractice of Unruly Social Media Influencers’ (2024) 16(1) Journal of Media Law 74 
• Autorité de Régulation Professionnelle de la Publicité, ‘Influence Responsable’ <www.arpp.org/influence-responsable/> accessed 8 May 2026 
• Baker J, ‘Online Safety Needs Structural Change Not More Layers Of Control’ (Open Rights Group, 18 February 2026) <www.openrightsgroup.org/blog/online-safety-needs-structural-change-not-more-layers-of-control/> accessed 31 May 2026 
• BBC ‘Inside the Rage Machine’ (16 March 2026) <www.bbc.co.uk/programmes/m002sw4z> accessed 20 March 26 
• BBC ‘Men of the Manosphere’ (12 November 2025) <www.bbc.co.uk/iplayer/episodes/m002m7j5/men-of-the-manosphere> accessed 24 March 2026 
• Committee of Advertising Practice, The UK Code of Non-broadcast Advertising and Direct & Promotional Marketing (CAP Code) <www.asa.org.uk/codes-and-rulings/advertising-codes/non-broadcast-code.html> accessed 31 May 2026 
• Committee of Advertising Practice, The UK Code of Non-broadcast Advertising and Direct & Promotional Marketing (CAP Code) <www.asa.org.uk/codes-and-rulings/advertising-codes/non-broadcast-code.html> accessed 31 May 2026 
• Council of the European Union, Council Conclusions on Support for Influencers as Online Content Creators [2024] OJ C 2024/3807 
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• Directive (EU) 2018/1808 of the European Parliament and of the Council of 14 November 2018 amending Directive 2010/13/EU on the coordination of certain provisions laid down by law, regulation or administrative action in Member States concerning the provision of audiovisual media services (Audiovisual Media Services Directive) in view of changing market realities [2018] OJ L 303/69 
• Directive (EU) 2021/555 on Control of the Acquisition and Possession of Weapons [2021] OJ L115/1  
• Drenten J, Gurrieri L, Huff AD and Barnhart M, ‘Curating a consumption ideology: Platformization and gun influencers on Instagram’ (2024) 24(1) Marketing Theory 91  
• Ducato R, ‘One Hashtag to Rule Them All? Mandated Disclosures and Design Duties in Influencer Marketing Practices’ in Goanta C and Ranchordás S (eds), The Regulation of Social Media Influencers (Edward Elgar Publishing 2020) 
• Educate Against Hate, ‘The Manosphere An Educate Against Hate Explainer’ (HM Government 2025)
• European Audiovisual Observatory, National Rules Applicable to Influencers (2024). 
• European Commission, ‘Influencer Legal Hub’ <https://commission.europa.eu/topics/consumers/consumer-rights-and-complaints/influencer-legal-hub_en> accessed 2 February 2026 
• European Commission, ‘Investigation of the Commission and Consumer Authorities Finds That Online Influencers Rarely Disclose Commercial Content’ (Press Release, 14 February 2024) <https://ec.europa.eu/commission/presscorner/detail/en/ip_24_708> accessed 31 May 2026  
• European Commission, ‘The Cooperation Framework under the Digital Services Act’ <https://digital-strategy.ec.europa.eu/en/policies/dsa-cooperation> accessed 30 May 2026 
• European Commission, ‘Code of Conduct Countering Illegal Hate Speech Online’, January 2025 <https://digital-strategy.ec.europa.eu/en/library/code-conduct-countering-illegal-hate-speech-online> accessed 29 May 26 
• European Commission, ‘Guidance on the interpretation and application of Directive 2005/29/EC of the European Parliament and of the Council on unfair business-to-consumer commercial practices in the internal market’ [2021] OJ C526/1 
• European Parliamentary Research Service, The regulation of influencers: Addressing the legal and regulatory challenges (PE 779.254, 2025) 
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• Jesser G, Kelly M, Rothermel AN, ‘Male Supremacism and the Hanau Terrorist Attack: Between Online Misogyny and Far Right Violence’ (International Centre for Counter Terrorism, 20 May 2020) <https://icct.nl/publication/male-supremacism-and-hanau-terrorist-attack-between-online-misogyny-and-far-right> accessed 28 May 2026 
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• Koehler D, ‘The Halle, Germany, Synagogue Attack and the Evolution of the Far-Right Terror Threat’ (2019) 12(11) Combating Terrorism Center at West Point 
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• Lamphere-Englund G, ‘Protecting Children in Online Gaming: Mitigating Risks from Organised Violence’ (UNICEF Innocenti Centre 2025) 
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• Morris S, ‘Plymouth shooter fascinated by serial killers and ‘incel’ culture, inquest hears’ (The Guardian, 18 January 2023) <www.theguardian.com/uk-news/2023/jan/18/plymouth-shooter-jake-davison-fascinated-by-mass-shootings-and-incel-culture-inquest-hears> accessed 20 April 2026 
• Mueller E B, ‘The Misogynist Incel in the News: Analysing Representations of Gender-based Violence in the UK’ (2024) 26(4) British Journal of Politics and International Relations 1121 
• Naudts L, Helberger N, Veale M and Sax M, ‘A Right to Constructive Optimization: A Public Interest Approach to Recommender Systems in the Digital Services Act’ (2025) 48(3) Journal of Consumer Policy 269 
• Niestadt M, ‘Regulating influencer marketing in the European Union’ (European Parliament, Dec 2025) PE 779.254 <www.europarl.europa.eu/thinktank/en/document/EPRS_BRI(2025)779254> accessed 27 April 2026 
• Ofcom, ‘Online Safety Enforcement Guidance’ (2026) <www.ofcom.org.uk/siteassets/resources/documents/online-safety/information-for-industry/illegal-harms/online-safety-enforcement-guidance.pdf> accessed 30 May 2026 
• Oxley G and Downs W, ‘Short guide to firearms licensing’ licensing’ (UK Parliament House of Commons Library, 20 February 2026) <https://commonslibrary.parliament.uk/research-briefings/cbp-10291/> accessed 31 May 2026 
• Pflücke F, ‘Chapter 12: Making influencers honest: the role of social media platforms in regulating disclosures’ in Catalina Goanta and Sofia Ranchordás (eds), The Regulation of Social Media Influencers (Edward Elgar Publishing, 2020) 
• Pinterest, ‘Paid partnerships for creators’ <https://help.pinterest.com/en-gb/business/article/paid-partnerships-for-creators> accessed 31 May 2026 
• Preston K, Halpin M and Lockyer D, ‘Incels and gender inequality’ (2025) spaf052 Social Problems 
• Rollano C, Pérez-González JC and Román-González M, ‘A Framework for Understanding the Manosphere’ (2026) Social and Personality Psychology Compass e70123 
• Rottweiler B, Clemmow C and Gill P, ‘A Common Psychology of Male Violence? Assessing the Effects of Misogyny on Intentions to Engage in Violent Extremism, Interpersonal Violence and Support for Violence against Women’(2025) 37 (3) Terrorism and Political Violence 287 
• Sandu G and Cseby RB, ‘Women‘s Rights and Democracy: Combating Stereotypes, Disinformation, Violence in the Digital Age’ (European Parliament, PE 785.000, 2026)   
• Spring M and Radford M, ‘Meta and TikTok let harmful content rise after evidence outrage drove engagement, says whistleblowers’ BBC News (16 March 2025) <www.bbc.co.uk/news/articles/cqj9kgxqjwjo> accessed 20 May 2026 
• Tesire Y and Schroeder S, ‘The Political Economy of the Gun: Militarised Masculinity, Commerce and the Global Health Burden of Firearms Examined.’ (Action on Armed Violence, 6 Feb 2026) <https://aoav.org.uk/2026/the-political-economy-of-the-gun-militarised-masculinity-commerce-and-the-global-health-burden-of-firearms-examined/> accessed 24March 2026 
• UN Office on Drugs and Crime, ‘Intentional Homicide rates by mechanisms’ (2022) <https://dataunodc.un.org/data/homicide/Homicide%20rate%20by%20mechanisms> accessed 31 May 2026 
• Vodafone Foundation and Save the Children and Skills Upload, ‘Every half second, a child goes online for the first time’<https://skillsuploadjr.eu/saveTheChildren> accessed 1 Jun 2026 
• Wamser-Nanney R, ‘Understanding gun violence: Factors associated with beliefs regarding guns, gun policies and gun violence’ (2021) 11(4) Psychology of Violence 349 
• Watkins LWJ and Gearon A, ‘Mapping Driving Factors of UK Serious Youth Violence across Policy and the Community: A Multi-Level Discoursal Analysis’ (2024) 14(7) Societies 125 
• Youth Endowment Fund, ‘Children, violence and vulnerability 2024 Report 2 What role does social media play in violence affecting young people?’ (2024) 

[1] Adnan A Hyder and Lorena Barberia, ‘Addressing Global Gun Violence: A Lancet Commission on Global Gun Violence and Health’ (2024) 404 The Lancet 1794.

[2] Wamser-Nanney, Rachel, ‘Understanding gun violence: Factors associated with beliefs regarding guns, gun policies and gun violence’ (2021) 11 (4) Psychology of Violence 349.

[3] Hyder and Barberia (n 1) 1794.

[4] Amnesty International, ‘GUN VIOLENCE’ <https://www.amnesty.org/en/what-we-do/arms-control/gun-violence/> accessed 31 May 2026.

[5] Katherine Leach-Kemon, Rebecca Sirull and Scott Glenn, ‘On gun violence, the United States is an outlier’ (Institute for Health Metrics and Evaluation, 31 October 2023) <https://www.healthdata.org/news-events/insights-blog/acting-data/gun-violence-united-states-outlier> accessed 31 May 2026.

[6] ibid.

[7] United Nations Office on Drugs and Crime ‘Intentional Homicide rates by Mechanisms. Dataset’ (2022) <https://dataunodc.un.org/data/homicide/Homicide%20rate%20by%20mechanisms> accessed 31 May 2026; Katharina Krüsselmann, Pauline Aarten, Sven Granath, Janne Kivivuori, Nora Markwalder, Karoliina Suonpää, Asser Hedegaard Thomsen, Simone Walser & Marieke Liem ‘Firearm Homicides in Europe: A Comparison with Non-Firearm Homicides in Five European Countries’ (2023) 24 Global Crime 145. Examples of individual county rates include Sweden (0.34), France (0.24) and (0.24) do show much higher levels at a national level. (Leach-Kemon et al (n 5))

[8] Home Office, ‘Firearms licensing guidance strengthened to protect the public’ (5 August 2025) <https://www.gov.uk/government/news/firearms-licensing-guidance-strengthened-to-protect-the-public> accessed 31 May 2026; Also, European Commission, ‘EU legislation on civilian firearms’ (2026) <https://home-affairs.ec.europa.eu/policies/internal-security/organised-crime/trafficking-firearms/eu-legislation-civilian-firearms_en>accessed 31 May 2026.

[9] Directive (EU) 2021/555 on Control of the Acquisition and Possession of Weapons [2021] OJ L115/1.

[10] Greg Oxley and William Downs, ‘Short guide to firearms licensing’ (UK Parliament House of Commons Library, 20 February 2026) < https://commonslibrary.parliament.uk/research-briefings/cbp-10291/ > accessed 31 May 2026.

[11]Aaron Karp, ‘Estimating Global Civilian-Held Firearms Numbers’ (Small Arms Survey, 2018) www.smallarmssurvey.org/resources/estimating-global-civilian-held-firearms-numbers accessed 31 May 2026.

[12] Brian Taehyuk Keum, Lianne Wong and Jung Yun Na, ‘Trauma, Depression, and Anxiety from Gun Violence Exposure on Social Media: Development of the Gun Violence on Social Media Scale’ (2025) 34 (9) Journal of Aggression Maltreatment & Trauma 1340.

[13] Keir Irwin-Rogers and Craig Pinkney, ‘Social media as a catalyst and trigger for youth violence’ (Catch22 2017) <https://www.catch-22.org.uk/resources/social-media-as-a-catalyst-and-trigger-for-youth-violence/> accessed 31 May 2026.

[14] Lisa Jordan, James Kalin and Colleen Dabrowski, ‘Characteristics of Gun Advertisements on Social Media: A Systematic Search and Content Analysis of Twitter and YouTube Posts’ (2019) 22 (3) Journal of Medical Internet Research e15736, 7.

[15] Mark Bellis and others, ‘Weapons of Influence: Tactics of a Growing Global Arms Industry and Needed Health Actions’ (2025) 390 BMJ e086167 < https://doi.org/10.1136/bmj-2025-086167 > accessed 2 February 2026.

[16] ibid.

[17] Luke Willian John Watkins and Alinka Gearon, ‘Mapping Driving Factors of UK Serious Youth Violence across Policy and the Community: A Multi-Level Discoursal Analysis’ (2024) 14(7) Societies 125.

[18] ‘The Rising Threat of Gun Crime in the UK: A Growing Concern for Communities – Noble Solicitors’ (Nobel Solicitors 5 March 2025) <https://noblesolicitors.co.uk/the-rising-threat-of-gun-crime-in-the-uk-a-growing-concern-for-communities/> accessed 31 May 2026.

[19] ibid.

[20] Regulation (EU) 2022/2065 of the European Parliament and of the Council of 19 October 2022 on a Single Market For Digital Services and amending Directive 2000/31/EC (Digital Services Act) [2022] OJ L277/1.

[21] For full definitions see ‘regulated service’ in Online Safety Act 2023, s 2(3)-(4).

[22] Online Safety Act 2023, s 10.

[23] ibid, s 11.

[24] Online Safety Act 2023, ss 12(3)(a) and 12(6).

[25] ibid, s 12(3)(b).

[26] The Online Safety Act 2023 (Category 1, Category 2A and Category 2B Threshold Conditions) Regulations 2025, SI 2025/226, reg 3.

[27] Online Safety Act, 2023 s 14(2)

[28] ibid s 14(3).

[29] ibid s 15.

[30] ibid s 64.

[31] Ofcom, ‘Online Safety Enforcement Guidance’ (2026) <https://www.ofcom.org.uk/siteassets/resources/documents/online-safety/information-for-industry/illegal-harms/online-safety-enforcement-guidance.pdf> accessed 30 May 2026, para 3.12.

[32] ibid para 9.

[33] Digital Services Act, art 3(g).

[34] Digital Services Act, art 3(g)(iii).

[35] ibid arts 33-43.

[36] European Commission, ‘The cooperation framework under the Digital Services Act’ <https://digital-strategy.ec.europa.eu/en/policies/dsa-cooperation> accessed 30 May 2026.

[37] Digital Services Act, art 16.

[38] ibid art 34.

[39] ibid art 28(1).

[40] Digital Services Act, art 28(2).

[41] ibid art 22.

[42] ibid art 34(1)(d); see also art 35.

[43] Committee of Advertising Practice, The UK Code of Non-broadcast Advertising and Direct & Promotional Marketing (CAP Code) <https://www.asa.org.uk/codes-and-rulings/advertising-codes/non-broadcast-code.html> accessed 31 May 2026.

[44] Directive 2005/29/EC of the European Parliament and of the Council of 11 May 2005 concerning unfair business-to-consumer commercial practices in the internal market (Unfair Commercial Practices Directive) [2005] OJ L149/22.

[45] CAP Code, rules 1.3 and 4.4.

[46] Unfair Commercial Practices Directive, Annex I, para 11.

[47] CAP Code, rules 1.2, 1.3, 4.4 and Section 4.

[48] Advertising Standards Authority, ‘ASA Ruling on ThruDark Ltd’ (18 October 2023) <https://www.asa.org.uk/rulings/thrudark-ltd-g23-1206049-thrudark-ltd.html> accessed 30 May 2026.

[49]Unfair Commercial Practices Directive, arts 8 and 9.

[50] Directive (EU) 2018/1808 of the European Parliament and of the Council of 14 November 2018 amending Directive 2010/13/EU on the coordination of certain provisions laid down by law, regulation or administrative action in Member States concerning the provision of audiovisual media services (Audiovisual Media Services Directive) [2018] OJ L303/69.

[51] Audio Visual Media Services Directive, art 6.

[52] Digital Services Act, art 14(1).

[53] OSA 2023, s 10(2) and s 10(3).

[54] ibid s 70(1).

[55] Felix Pflücke, ‘Making influencers honest: the role of social media platforms in regulating disclosures’ in Catalina Goanta and Sofia Ranchordás (eds), The Regulation of Social Media Influencers (Edward Elgar 2020) 299, 318-321.

[56] Alexandros Antoniou, ‘Navigating Freezones in the Influencerdom: A Shadowlands Guide’ (2024) 29(1) Communications Law 8, 12.

[57] ibid 12; ASA, Recognising Ads: Social Media and Influencer Marketing (23 March 2022) <https://www.asa.org.uk/advice-online/recognising-ads-social-media.html> accessed 8 May 2026.

[58] European Commission, ‘Influencer Legal Hub’ <https://commission.europa.eu/topics/consumers/consumer-rights-and-complaints/influencer-legal-hub_en> accessed 2 February 2026.

[59] Alexandros Antoniou, ‘Navigating Freezones in the Influencerdom: A Shadowlands Guide’ (2024) 29(1) Communications Law 8.

[60] Catalina Goanta and Sofia Ranchordás, ‘The regulation of social media influencers: an introduction’ in Catalina Goanta and Sofia Ranchordás (eds), The Regulation of Social Media Influencers (Edward Elgar Publishing 2020), 4-9.

[61] Cristina González-Díaz, Mari Carmen Quiles-Soler and Natalia Quintas-Froufe, ‘The Figure of the Influencer under Scrutiny: Highly Exposed, Poorly Regulated’ (2024) 9 Frontiers in Communication 7, 10.

[62] Alexandros Antoniou, ‘Navigating freezones in the influencerdom: a shadowlands guide’ (2024) 29 Communications Law 8, 18.

[63] Council of the European Union, ‘Council Conclusions on Support for Influencers as Online Content Creators’ [2024] OJ C/2024/3807, para 4.

[64] ibid Annex Definitions.

[65] ibid para 3.

[66] Jordan et al., (n 14).

[67] Jenna Drenten, Lauren Gurrieri, Aimee Dinnín Huff and Michelle Barnhart ‘Curating a consumption ideology: Platformization and gun influencers on Instagram.’ (2024) 24 (1) Marketing Theory 91.

[68] Elijah Glantz, ‘Firearms in the UK: A Stable Threat?’ (RUSI, 21 March 2024) < https://www.rusi.org/explore-our-research/publications/commentary/firearms-uk-stable-threat> accessed 13 February 2026.

[69] Youth Endowment Fund, ‘Children, violence and vulnerability 2024 Report 2 What role does social media play in violence affecting young people?’ (2024).

[70] Luke William John Watkins and Alinka Gearon, ‘Mapping Driving Factors of UK Serious Youth Violence across Policy and the Community: A Multi-Level Discoursal Analysis’ (2024) 14(7) Societies 125.

[71] Youth Endowment Fund (n 69) 15.

[72] ibid 19.

[73] ibid 18.

[74] ibid 21-22.

[75] Irwin-Rogers (n 13) 8.

[76] Irwin-Rogers (n 13) 23.

[77] Irwin-Rogers (n 13) 21.

[78] Everytown Research & Policy, ‘Armed Extremism in Buffalo Online Gun Communities Provide a Path of Radicalisation and Training to a Racist Shoter’ (12 August 2022)  <https://everytownresearch.org/report/armed-extremism-buffalo-shooting/> accessed 28 May 2026. 

[79] Steven Morris, ‘Plymouth shooter fascinated by serial killers and ‘incel’ culture, inquest hears’ (The Guardian, 18 January 2023) <https://www.theguardian.com/uk-news/2023/jan/18/plymouth-shooter-jake-davison-fascinated-by-mass-shootings-and-incel-culture-inquest-hears> accessed 20 April 2026  ; Elsa Bengtsson Mueller, ‘The Misogynist Incel in the News: Analysising Representations of Gender-based Violence in the UK’ (2024) 26(4) British Journal of Politics and International Relations 1121.

[80] Greta Jesser, Megan Kelly, Ann-Kathrin Rothermel, ‘Male Supremacism and the Hanau Terrorist Attack: Between Online Misogyny and Far Right Violence’ (International Centre for Counter Terrorism, 20 May 2020) <https://icct.nl/publication/male-supremacism-and-hanau-terrorist-attack-between-online-misogyny-and-far-right> accessed 28 May 2026.

[81] Daniel Koehler, ‘The Halle, Germany, Synagogue Attack and the Evolution of the Far-Right Terror Threat’ (2019) 12(11) Combating Terrorism Center at West Point.

[82] Daniel Koehler, ‘The Halle, Germany, Synagogue Attack and the Evolution of the Far-Right Terror Threat’ (2019) 12(11) Combating Terrorism Center at West Point.

[83] Georgiana Sandu, Roza Bella Cseby, ‘Women‘s Rights and Democracy: Combating Stereotypes, Disinformation, Violence in the Digital Age’ (European Parliament, PE 785.000, 2026).

[84] Innovation Unit, ‘“Be a man”: Toxic masculinity, social media and violence’ < https://www.innovationunit.org/latest-updates/be-man-toxic-masculinity-social-media-and-violence> accessed 25 March 2026.

[85] Carol Harrington, ‘What is “Toxic Masculinity” and Why Does it Matter? Men and Masculinities’ (2021) 24(2), 345.

[86] Innovation Unit, ‘“Be a man”: Toxic masculinity, social media and violence’ <https://www.innovationunit.org/latest-updates/be-man-toxic-masculinity-social-media-and-violence> accessed 25 March 2026.

[87] Everytown Research & Policy (n 78).

[88] Educate Against Hate, ‘The Manosphere An Educate Against Hate Explainer’ (2025) HM Government.

[89] Cecilia Rollano, Juan-CarlosPérez-González, and MarcosRomán-González, ‘A Framework for Understanding the Manosphere’ (2026) Social and Personality Psychology Compass: e70123, 4; BBC, ‘Men of the Manosphere’ (12 November 2025) <https://www.bbc.co.uk/iplayer/episodes/m002m7j5/men-of-the-manosphere> accessed 24 March 26.

[90] Raewyn W. Connell, Masculinities (2th edn, Polity Press 1995) 77.

[91] Rollano et al. (n 89) 1.

[92] Xiaoting Han and Chenjun Yin ‘Mapping the manosphere. Categorization of reactionary masculinity discourses in digital environment’ (2023) 23(5) Feminist Media Studies 1923.

[93] ibid 1933.

[94] Debbie Ging, ‘Alphas, Betas, and Incels: Theorizing the Masculinities of the Manosphere’ (2017) 22(4) Men and Masculinities 638.

[95] Rollano et al. (n 89) 4; BBC, ‘Men of the Manosphere’ (12 November 2025) <https://www.bbc.co.uk/iplayer/episodes/m002m7j5/men-of-the-manosphere> accessed 24 March 26.

[96] Bettina Rottweiler, Caitlin Clemmow, and Paul Gill, ‘A Common Psychology of Male Violence? Assessing the Effects of Misogyny on Intentions to Engage in Violent Extremism, Interpersonal Violence and Support for Violence against Women’ (2025) 37 (3) Terrorism and Political Violence 287.

[97] Everytown Research and Policy (n 78).

[98] Kayla Preston, Michael Halpin, Demeter Lockyer, ‘Incels and gender inequality: changing tides in defining the far right’ (2025) 00 Social Problems 1.

[99] Everytown Research & Policy (n 78).

[100] Yvonne Tesire and Samantha Schroeder, ‘The Political Economy of the Gun: Militarised Masculinity, Commerce and the Global Health Burden of Firearms Examined.’ (Action on Armed Violence, 6 Feb 2026) <https://aoav.org.uk/2026/the-political-economy-of-the-gun-militarised-masculinity-commerce-and-the-global-health-burden-of-firearms-examined/> accessed 24 March 2026.

[101] ibid.

[102] Geena Davis Institute, ‘The Double-Edged Sword of Online Gaming: An Analysis of Masculinity in Video Games and the Gaming Community’ (2021) 4 < https://geenadavisinstitute.org/research/the-double-edged-sword-of-online-gaming-an-analysis-of-masculinity-in-video-games-and-the-gaming-community/> accessed 31 May 2026.

[103] Galen Lamphere-Englund, ‘Protecting Children in Online Gaming: Mitigating Risks from Organised Violence’, (UNICEF Innocenti Centre, 2025).

[104] ibid 6-7.

[105] Summer Rita Josephine Herbert,  Maria Ioannou, Calli Tzani, ‘Impact of social media on knife crime in the UK’ (2025) 17(2) Assessment and Development Matters 48.

[106] HM Government, ‘Independent End-to-End Review of Online Knife Sales’ (2025) <https://www.gov.uk/government/publications/independent-end-to-end-review-of-online-knife-sales/independent-end-to-end-review-of-online-knife-sales-accessible> accessed 31 May 2026.

[107] Youth Endowment Fund (n 69); Rollano et al. (n 89); Drenten et al. (n 67).

[108] BBC ‘Inside the Rage Machine’ (16 March 2026) 23mins 12 secs <https://www.bbc.co.uk/programmes/m002sw4z> accessed 20 March 26.

[109] Marianna Spring and Mike Radford, ‘Meta and TikTok let harmful content rise after evidence outrage drove engagement, says whistleblowers’, BBC News (16 March 2025) <https://www.bbc.co.uk/news/articles/cqj9kgxqjwjo> accessed 20 May 2026.

[110] BBC (n 108).

[111] BBC (n 108).

[112] ibid 38 mins.

[113] Liv McMahon, Zoe Kleinman and Courtney Subramanian, ‘Facebook and Instagram get rid of fact checkers’ (7 January 2025) <https://www.bbc.co.uk/news/articles/cly74mpy8klo> accessed 31 May 2026.

[114] Felix Pflücke, ‘Making influencers honest: the role of social media platforms in regulating disclosures’ in Catalina Goanta and Sofia Ranchordás (eds), The Regulation of Social Media Influencers (Edward Elgar 2020) 299, 312-321.

[115] Pinterest, ‘Paid partnerships for Creators’ <https://help.pinterest.com/en-gb/business/article/paid-partnerships-for-creators> accessed 4 April 2026.

[116] For example, only one in 5 influencers disclose advertising content: European Commission, ‘Investigation of the Commission and Consumer Authorities Finds That Online Influencers Rarely Disclose Commercial Content’ (Press Release, 14 February 2024) <https://ec.europa.eu/commission/presscorner/detail/en/ip_24_708> accessed 31 May 2026.

[117] Felix Pflücke, ‘Making influencers honest: the role of social media platforms in regulating disclosures’ in Catalina Goanta and Sofia Ranchordás (eds), The Regulation of Social Media Influencers (Edward Elgar 2020) 299, 319.

[118] Online Safety Act 2023, ss 11-13.

[119] ibid s15.

[120] Martin Husovec, ‘The Missing Link: How New Institutions Could Improve What We Read Online’ [2026] OJLS 1.

[121] James Baker, ‘Online Safety Needs Structural Change Not More Layers Of Control’ (Open Rights Group, 18 February 2026) <https://www.openrightsgroup.org/blog/online-safety-needs-structural-change-not-more-layers-of-control/> accessed 31 May 2026.

[122] Laurens Naudts and others, ‘A Right to Constructive Optimization: A Public Interest Approach to Recommender Systems in the Digital Services Act’ (2025) 48 Journal of Consumer Policy 269, 282.

[123] although they are not immune to separate criminal liability

[124] Advertising Standards Authority, ‘ASA Ruling on ThruDark Ltd’ (18 October 2023) <https://www.asa.org.uk/rulings/thrudark-ltd-g23-1206049-thrudark-ltd.html> accessed 30 May 2026.

[125]Alexandros Antoniou, ‘Navigating freezones in the Influencerdom: a shadowlands guide’ (2024) 29 Communications Law 8, 13-15, 18-19.

[126] Advertising Standards Authority, ‘Remit: Advertisement Features’ (AdviceOnline, 4 February 2026) <https://www.asa.org.uk/advice-online/remit-advertisement-features.html> accessed 31 May 2026.

[127]Advertising Standards Authority, ‘Influencers’ guide to making clear that ads are ads’ (ASA  23 March 2023) <https://www.asa.org.uk/static/790d2e01-e3f8-4fea-b3c99ef91a9f04dc/Influencerguidance2023v4-FINAL.pdf> accessed 31 May 2026.

[128] Although the Consumer Protection from Unfair Trading Regulations 2008 may still apply

[129] Directive 2005/29/EC of the European Parliament and of the Council of 11 May 2005 concerning unfair business-to-consumer commercial practices in the internal market (Unfair Commercial Practices Directive) [2005] OJ L149/22.

[130] European Commission, ‘Guidance on the interpretation and application of Directive 2005/29/EC of the European Parliament and of the Council on unfair business-to-consumer commercial practices in the internal market’ [2021] OJ C526/1, s 2.2; Felix Pflücke, ‘Making influencers honest: the role of social media platforms in regulating disclosures’ in Catalina Goanta and Sofia Ranchordás (eds), The Regulation of Social Media Influencers (Edward Elgar 2020) 299, 304, 309-311.

[131] Directive (EU) 2018/1808 amending Directive 2010/13/EU on the provision of audiovisual media services (Audiovisual Media Services Directive) [2018] OJ L303/69, art 1(1).

[132] Rossana Ducato, ‘One hashtag to rule them all? Mandated disclosures and design duties in influencer marketing practices’ in Catalina Goanta and Sofia Ranchordás (eds), The Regulation of Social Media Influencers (Edward Elgar Publishing 2020) 232, 266.

[133] Loi n° 2023-451 du 9 juin 2023 visant à encadrer l’influence commerciale et à lutter contre les dérives des influenceurs sur les réseaux sociaux (France) (‘French Law’).

[134] French Law, art 1.

[135] Autorité de Régulation Professionnelle de la Publicité, ’Influence Responsable’ <https://www.arpp.org/influence-responsable/> accessed 8 May 2026.

[136] Cristina González-Díaz, Mari Carmen Quiles-Soler and Natalia Quintas-Froufe, ‘The Figure of the Influencer under Scrutiny: Highly Exposed, Poorly Regulated’ (2024) 9 Frontiers in Communication 7, 9–11.

[137] Rossana Ducato, ‘One hashtag to rule them all? Mandated disclosures and design duties in influencer marketing practices’ in Catalina Goanta and Sofia Ranchordás (eds), The Regulation of Social Media Influencers (Edward Elgar Publishing 2020) 232, 233.

[138] Rossana Ducato, ‘One hashtag to rule them all? Mandated disclosures and design duties in influencer marketing practices’ in Catalina Goanta and Sofia Ranchordás (eds), The Regulation of Social Media Influencers (Edward Elgar Publishing 2020) 232, 246.

[139] Advertising Standards Authority, ‘Influencer Ad Disclosure on Social Media: Instagram and TikTok’ (May 2025) 12 <https://www.asa.org.uk/resource/influencer-ad-disclosure-on-social-media-instagram-and-tiktok-2024.html> accessed 27 April 2026.

[140] European Commission, ’Influencer Legal Hub’

<https://commission.europa.eu/topics/consumers/consumer-rights-and-complaints/influencer-legal-hub_en> accessed 27 April 2026; see also ‘82 influencers had over 1 million followers, 301 over 100,000 and 73 between 5,000 and 100,000’: European Commission, ‘Investigation of the Commission and Consumer Authorities Finds That Online Influencers Rarely Disclose Commercial Content’ (Press Release, 14 February 2024) <https://ec.europa.eu/commission/presscorner/detail/en/ip_24_708> accessed 31 May 2026.

[141] Alexandros Antoniou, ‘Navigating freezones in the Influencerdom: a shadowlands guide’ (2024) 29 Communications Law 8, 1, 12, 18.

[142] Alexandros Antoniou, ‘Navigating freezones in the Influencerdom: a shadowlands guide’ (2024) 29 Communications Law 8, 18-19.

[143] ibid 13-16.

[144] Alexandros Antoniou, ‘Navigating freezones in the Influencerdom: a shadowlands guide’ (2024) 29 Communications Law 8, 7-8, 13.

[145] ibid 15-16.

[146] House of Commons, Digital, Culture, Media and Sport Committee, ‘Influencer Culture: Lights, Camera, Inaction?’ (Twelfth Report of Session 2021–22, HC 258, 2022) para 3; Alexandros Antoniou, ‘When Likes Go Rogue: Advertising Standards and the Malpractice of Unruly Social Media Influencers’ (2024) 16 Journal of Media Law 74.

[147] Alexandros Antoniou, ‘Navigating freezones in the Influencerdom: a shadowlands guide’ (2024) 29 Communications Law 8, 13.

[148] European Parliamentary Research Service, The regulation of influencers: Addressing the legal and regulatory challenges (PE 779.254, 2025), 2; Council of the European Union, Council Conclusions on Support for Influencers as Online Content Creators [2024] OJ C 2024/3807, Annex 1.

[149] Online Safety Act 2023, s 95(10)(a).

[150] Alexandros Antoniou, ‘Navigating freezones in the Influencerdom: a shadowlands guide’ (2024) 29(1) Communications Law 8, 18-19.

[151] Digital Services Act, art 42.

[152] Cristina González-Díaz, Mari Carmen Quiles-Soler and Natalia Quintas-Froufe, ‘The Figure of the Influencer under Scrutiny: Highly Exposed, Poorly Regulated’ (2024) 9 Frontiers in Communication 7, 10-11.

[153] Felix Pflücke, ‘Making influencers honest: the role of social media platforms in regulating disclosures’ in Catalina Goanta and Sofia Ranchordás (eds), The Regulation of Social Media Influencers (Edward Elgar 2020) 299, 312.

[154] Alexandros Antoniou, ‘Navigating Freezones in the Influencerdom: A Shadowlands Guide’ (2024) 29(1) Communications Law 8, 7, 17-18.

[155] ibid 3-8.

[156] Autorité de Régulation Professionnelle de la Publicité, ’Influence Responsable’ <https://www.arpp.org/influence-responsable/> accessed 8 May 2026.

[157] Rossana Ducato, ‘One hashtag to rule them all? Mandated disclosures and design duties in influencer marketing practices’ in Catalina Goanta and Sofia Ranchordás (eds), The Regulation of Social Media Influencers (Edward Elgar Publishing 2020) 246.

[158] Loi n° 2023-451 du 9 juin 2023 (French law), art 4.

[159] See, for example certified content creators: Autorité de Régulation Professionnelle de la Publicité, ‘Créateurs de contenus certifiés’ <www.arpp.org/influence-responsable/createurs-de-contenus-certifies/> accessed 30 May 2026.

[160] European Commission, ’Code of Conduct Countering Illegal Hate Speech Online’(2025) <https://digital-strategy.ec.europa.eu/en/library/code-conduct-countering-illegal-hate-speech-online> accessed 29 May 2026.

[161] ibid; BBC ‘Inside the Rage Machine’(16 March 2026).

[162] Hays K, Saad N and Morris R, ‘Campaigners welcome Meta and YouTube’s defeat in landmark social media addiction trial’ BBC News (Los Angeles, 25 March 2025) <https://www.bbc.co.uk/news/articles/c747x7gz249o> accessed 29 May 26.

[163] Rossana Ducato, ‘One hashtag to rule them all? Mandated disclosures and design duties in influencer marketing practices’ in Catalina Goanta and Sofia Ranchordás (eds), The Regulation of Social Media Influencers (Edward Elgar Publishing 2020), 246; Cristina González-Díaz, Carmen Quiles-Soler and Natalia Quintas-Froufe, ‘The figure of the influencer under scrutiny: highly exposed, poorly regulated’ (2024) 9 Frontiers in Communication 1454543, 11.

[164] Vodafone Foundation and Save the Children and Skills Upload ‘Every half second, a child goes online for the first time’ <https://skillsuploadjr.eu/saveTheChildren>  (accessed 27 May 2026).

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