TikTok privacy appeals: an old UK fine becomes final

September’s development concerns an earlier penalty

On 24 September 2026, the ICO said TikTok had agreed to pay a £12.7m fine imposed in 2023 after withdrawing its appeal. Information Commissioner’s Office The distinction between the date of the penalty and the date of the withdrawal matters. A headline about a fresh fine would misidentify the development and obscure what changed procedurally.

The ICO estimated that up to 1.75 million UK children under 13 used TikTok in 2020. Information Commissioner’s Office This is a historical estimate attributed to the regulator. It should retain both the “up to” qualification and its reference year, rather than being presented as a current count of children using the service.

According to Recording Law, the penalty concerned infringements during the period 25 May 2018 to 28 July 2020. Recording Law That period helps keep the account of the earlier enforcement action separate from the later investigation. The subject may be children’s information in both instances, but the procedural status of each matter needs its own explanation.

A final notice and an unfinished investigation

Withdrawal of the penalty appeal means the monetary penalty notice is now final, Recording Law reports. Recording Law Finality concerns that penalty notice. It should not be stretched into a conclusion about every aspect of the platform’s handling of children’s information or about an investigation addressing a different question.

TikTok also withdrew its appeal against an information notice concerning how its recommender systems process the personal information of 13-17-year-olds, the ICO said. Information Commissioner’s Office This is the other withdrawal in the announcement. An information request about recommender systems belongs in the account of an ongoing investigation, not in a description of findings already established.

The separate recommender-systems investigation has produced no findings, according to Recording Law. Recording Law That limit is essential to a fair account. The withdrawal permits the investigation to continue, but it does not establish the outcome. A reader should not have to infer that limitation from a footnote after encountering language suggesting a new violation.

What the earlier tribunal ruling actually decided

The Upper Tribunal held that the special-purposes preconditions did not apply to the processing covered by the penalty notice. Upper Tribunal (via The National Archives) This was a legal ruling on a preliminary issue. Its significance should be described at that level rather than turned into a claim that the tribunal had resolved the whole substantive appeal.

After dismissing the preliminary appeal, the Upper Tribunal remitted the case for determination of the substantive appeal. Upper Tribunal (via The National Archives) Reading these steps together explains why the later withdrawal remains a distinct development. The earlier ruling addressed the preliminary issue; it did not itself dispose of the substantive appeal that was subsequently withdrawn.

This sequence is useful for anyone writing an internal regulatory update. Record what the tribunal decided, what remained to be determined and what the company later withdrew. Combining those stages into a single statement that TikTok “lost the case” would discard the procedural distinctions that make the announcement intelligible.

A practical lesson for Algerian platform teams

For Algerian teams assessing services for overseas users, the relevant lesson is to separate age-related data questions, transparency about recommender processing and the response to regulatory information requests. These are suggested review categories. The UK development alone does not establish which requirements apply to a particular Algerian service.

A team could prepare a record of its intended users, the information it proposes to process and the explanations it would need to substantiate. It could also designate responsibility for gathering records if an information request arrives. Those are recommendations for preparation, not claims about new local duties created by this announcement.

The editorial boundary is also a management boundary: a final penalty, a preliminary legal ruling and an unfinished investigation should not share one undifferentiated risk label. A better briefing identifies the status of each, avoids reusing a historical user estimate as current evidence and leaves the outcome of the recommender investigation open.

Frequently Asked Questions

Sources & Further Reading

• Information Commissioner’s Office
• Recording Law
• Upper Tribunal (via The National Archives)
• Tiktok to pay £12.7m UK child privacy fine despite disputing watchdog findings — City AM