To me, that judgment reads like a fairly strong warning to Ofcom. The outcome section makes it clear that although the request for judicial review has been refused at present, that refusal is predicated on the fact that Ofcom has currently not ruled that Wikipedia is a Category 1 service. If Ofcom
were to rule that Wikipedia is a C1 service, the Wikimedia foundation would have grounds to request a review again -- and, between the lines, that request might well succeed.
So, is Wikipedia really a Category 1 service? From https://www.legislation.gov.uk/ukdsi/2025/9780348267174, it seems to come down to whether Wikipedia is a site which uses a "content recommender system", where that term is defined as:
> a system, used by the provider of a regulated user-to-user service in respect of the user-to-user part of that service, that uses algorithms which by means of machine learning or other techniques determines, or otherwise affects, the way in which regulated user-generated content of a user, whether alone or with other content, may be encountered by other users of the service
There's plenty of flexibility in that definition for Ofcom to interpret "content recommender system" in a way that catches Facebook without catching Wikipedia. For instance, Ofcom could simply take the viewpoint that any content recommendation that Wikipedia engages in is not "in respect of the user-to-user part of that service."
After today's judgement, and perhaps even before, my own bet is that this is exactly the route Ofcom will take.