Letter to OFCOM regarding Citizen Vigilante

Re: Distribution of the film “Citizen Vigilante” to UK users on X (formerly Twitter) and the adequacy of the platform’s illegal-content systems and risk assessment under the Online Safety Act 2023

Dear Sirs,

I write as Chief Executive of MEND (Muslim Engagement and Development), a national not-for-profit civil society organisation that works to tackle Islamophobia and to protect, promote and strengthen the civic participation of British Muslim communities. MEND is also a key convener of the Islamophobia Advisory Group, a coalition of civil society organisation’s dealing with all manner of Islamophobic anti-Muslim hatred, including its online dissemination.

The purpose of this letter is to refer to Ofcom a matter of serious concern regarding the platform X (formerly Twitter), a regulated user-to-user service, and to ask Ofcom to consider whether the platform’s systems, processes and illegal-content risk assessment are adequate to meet its duties under the Online Safety Act 2023 (“the Act”). We are conscious that Ofcom regulates the design and operation of platforms’ systems rather than adjudicating individual items of content, and our concerns are framed accordingly. We are not asking Ofcom to remove any single post, but to examine what this episode reveals about the platform’s compliance with its statutory duties.

The content at issue

“Citizen Vigilante” (2026) is a film directed by Uwe Boll in which the protagonist, played by Armie Hammer, hunts and kills immigrants depicted as criminals, together with officials portrayed as protecting them. The film’s framing is specifically anti-Muslim rather than generically concerned with crime. It includes a sequence in which the protagonist enters the home of a Muslim family and kills the family, including unarmed members, and dialogue in which the abuse of women is attributed to the teachings of the Qur’an and to Islamic values. Reviewers across the mainstream press have characterised the film in these terms; Variety, for example, described it as “morally bankrupt” exploitation.

The film was denied an age classification in Germany on the basis, according to the director, that it incites violence against migrants, and it has not been classified in the United Kingdom. On 25th June 2026 the entire film was posted on X by the platform’s owner, Elon Musk, and made available to view free for approximately 48 hours to an account following of more than 240 million users, accompanied by posts promoting it[1]. It has since continued to circulate on the platform through reposts, including by UK-based accounts. The effect was to deliver, to a mass UK audience and without any age or classification control, a dramatic work whose central narrative endorses, incites and valorises the killing of Muslim families.

Why this engages the Act

The illegal-content duties under the Act have been in force since 17th March 2025, and Ofcom is able to take enforcement action under them. Among the priority offences listed in Schedule 7 to the Act are the “stirring up” hatred offences under Part 3 of the Public Order Act 1986, including the stirring up of racial hatred and (as inserted by the Racial and Religious Hatred Act 2006) religious hatred. The Government’s Statement of Strategic Priorities for Online Safety expressly identifies stirring-up-hatred offences among the illegal content that platforms must proactively identify and act against.

We consider that the distribution described above raises a serious question as to whether content capable of amounting to the stirring up of racial and religious hatred against Muslims was disseminated at scale to UK users, and as to whether X’s systems and processes identified, assessed and responded to that content as the Act requires. The concern is sharpened by the identity of the disseminator: the content was not posted by an anonymous user evading moderation, but boosted by the platform’s own owner, which raises the question of whether the platform’s safety systems operate effectively, consistently and without preferential treatment – a matter going directly to the design and governance of the service.

The wider context

This material has been amplified during a period of heightened risk to Muslim and minority communities in the UK, including the disorder seen in Belfast and, more recently, the violence across parts of Scotland in June 2026. The Centre for Countering Digital Hate has separately found that posts by the platform’s owner concerning the Belfast disorder reached very large audiences and amplified narratives that risked inciting violence. Against that backdrop, the mass distribution of a film that dramatises, incites and celebrates the murder of Muslims is not an abstract or merely distasteful matter; it carries a foreseeable risk of normalising and encouraging real-world hostility and violence towards identifiable communities.

What we ask of Ofcom

In light of the above, we respectfully ask Ofcom to:

1. Consider whether the matters set out in this letter indicate that X has failed to comply with its illegal-content duties under the Act – in particular its duties to carry out a suitable and sufficient illegal-content risk assessment and to operate proportionate systems and processes to identify, assess and minimise the dissemination of priority illegal content, including content capable of stirring up racial and religious hatred;
2. Use Ofcom’s information-gathering powers to require X to explain how its systems and processes handled this content, including whether its risk assessment accounts for content targeting Muslims and other minorities, and whether content posted or boosted by the platform’s owner is subject to the same safety processes as other users’ content;
3. Take into account, in its supervision of X, the heightened community-safety context described above and the demonstrated capacity of the platform to deliver such material to a mass UK audience without classification or age controls; and
4. Meet with MEND and partners in the Islamophobia Advisory Group, who would welcome the opportunity to provide further evidence on the online dissemination of Islamophobic/anti-Muslim hatred and its offline consequences.

This case presents an early opportunity to demonstrate that the Online Safety Act applies equally where potentially harmful content is amplified by the platform itself, and not solely by ordinary users. Content disseminated by the platform owner raises distinct governance questions because it tests whether internal safety systems operate independently of commercial or executive influence.

We would be grateful for an acknowledgement of this letter and a substantive response within 28 days. We are content for this correspondence to be treated as on the record, and we are happy to provide any further evidence that would assist Ofcom’s consideration of these matters.

Yours faithfully,

Abdullah Saif

Chief Executive Officer

MEND

Copied to:

Dame Melanie Dawes, Chief Executive, OfcomOliver Griffiths, Group Director, Online Safety, OfcomDepartment for Science, Innovation and TechnologyHome Affairs CommitteeJoint Committee on Human Rights

[1] https://x.com/elonmusk/status/2070157480915538098