1 August 2025, Geneva

Situation Overview

The UK Online Safety Act, intended to protect citizens from harmful and illegal online content, may unintentionally be increasing national vulnerability. By incentivizing the use of low-cost or free VPNs, the law is pushing users out of the jurisdictional reach of UK safeguards and into the hands of foreign intelligence services that operate or compromise widely used VPN providers. This shift represents a classic case of regulatory backfire, where well-intentioned safety mechanisms lead to expanded threat surfaces and reduced sovereign oversight.

Strategic Context

• The Online Safety Act (OSA) mandates new content monitoring, takedown obligations, and identity verification across online platforms.

• In response, privacy-conscious users, such as journalists, whistleblowers, and dissidents, are increasingly using VPNs to mask their location, activity, and metadata.

• Most users turn to low-cost or free VPNs, which are often operated without transparency and with servers located in high-risk jurisdictions.

As concerns mount over the unintended consequences of the UK Online Safety Act, cybersecurity professionals are urging a more pragmatic and expert-driven approach to oversight. Daniel Card, a respected voice in the field, emphasizes the importance of involving those with frontline experience in shaping the Act’s future trajectory:

“It’s still early days, but policymakers should seriously consider forming a challenge advisory board composed of experienced practitioners in cybersecurity, intelligence, and privacy to review and oversee the Act’s implementation. Without grounded, expert scrutiny, we risk unintended consequences that could compromise the very values we’re trying to protect.”

— Daniel Card, Cybersecurity Consultant (@UK_Daniel_Card)

Key Risks

1. Foreign Exploitation of VPN Infrastructure

• Free and low-cost VPNs are attractive targets for foreign intelligence operations.

  • Historical cases include:

    1. Hola VPN routing user traffic through unsecured peers.

    2. VPNs based in China, Russia, or under ambiguous shell corporations are being used to funnel user traffic through hostile infrastructure.

    3. Metadata harvesting at exit nodes by third parties or state actors.
       
       

2. Loss of Sovereign Oversight

• Users routed through VPNs to appear to be in other jurisdictions, limiting UK law enforcement’s visibility and regulatory control.

• VPN providers are not held to UK standards, and many are not subject to any effective privacy audit mechanisms.

• Intelligence-grade metadata, once handled by UK ISPs, may now be accessed or manipulated by foreign adversaries.
  
  

3. Cognitive & Narrative Risk

• The OSA’s public framing as a “safety” measure may backfire if citizens perceive it as surveillance, furthering:

  • Distrust in institutions,

  • Increased reliance on unsanctioned tools,

  • Amplification of state-backed disinformation campaigns that exploit this distrust.
    
    

Cognitive Risk 

• Behavioral Displacement: Users adopt VPNs to avoid surveillance, unintentionally degrading safety

• Narrative Warping: OSA becomes framed as authoritarianism, fueling radicalization

• Strategic Fog: UK loses attribution clarity over citizen activity and threat surfaces

• Adversarial Leverage: Foreign actors gain improved surveillance access at scale

ISRS Recommendations

For UK Policymakers

• Avoid enforcement mechanisms that push users underground or toward “privacy theater” tools.

• Establish a certification program for privacy tools (VPNs, secure messengers) to guide users toward safe choices.

• Incentivize use of audited, jurisdiction-bound VPNs (e.g., through digital literacy programs).

For Civil Society and Tech Sector

• Launch public awareness campaigns on VPN risk differentiation.

• Partner with reputable VPN providers to promote transparency and accountability (e.g., open audits, no-log guarantees, jurisdictional disclosures).
  
  

For Allies and Partners

• Share intelligence on compromised VPN infrastructure and potential intelligence fronts.

• Support international norms for regulating privacy tools and implementing countermeasures against surveillance.
  
  

Conclusion

The UK’s Online Safety Act, while aiming to improve digital safety, may be creating the opposite effect: accelerating the public’s retreat into foreign-controlled infrastructure. Without a course correction, this dynamic risks exposing more UK citizens to foreign surveillance than ever before, while simultaneously undermining institutional trust at home.