Start with the statutory service test before you build a controls program.
Most wasted compliance work comes from treating a product family as one service when the Act is applied service by service and feature by feature.
Structured answer sets in this page tree.
Cited legal and guidance references.
The right order is simple. First test whether you have a regulated user-to-user service, a regulated search service, or provider pornography duties. Then check the exemptions and mixed-service boundaries. Then run the child-access test and only after that move into risk assessment, age assurance, or categorisation work.
The Act applies to search services and services that allow users to generate, upload, or share content or interact with one another. That analysis must be done at the actual service or relevant part of a service, not only at brand level.
Where a product contains several surfaces, document which parts are user-to-user, which parts are search, and which parts are outside scope.
Schedule 1 excludes certain services, including internal business services. The legislation also treats some provider pornography scenarios separately, so the right question is not only whether a service is social or searchable, but which chapter and schedule apply.
This is where many teams over-scope the program or miss a narrow but important duty set.
If the service is likely to be accessed by children, the child access and child safety regime comes into play. The Act points to section 37 for the meaning of likely to be accessed by children, and the implementation sequence required services to complete children's access assessments before children's risk assessments.
Separately, some services will later be categorised as Category 1, 2A, or 2B. The threshold regulations were laid on 16 December 2024, the register was expected in summer 2025, and further category specific codes were expected from early 2026.
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