Artifact GuideUKChecklist

UK Online Safety Act Checklist

This checklist helps verify required notices, controls, workflows, records, and escalation points under the UK Online Safety Act before launch or review.

Use it for one defined service and provider entity. Mark an item not applicable only with a recorded statutory or factual reason.

Author
Sorena AI
Published
May 9, 2026
Updated
Jul 25, 2026
Sections
3

Structured answer sets in this page tree.

Primary sources
8

Cited legal and guidance references.

Publication metadata
Sorena AI
Published May 9, 2026
Updated Jul 25, 2026
Overview

Complete this checklist in order for each part. Approve scope first, then complete the illegal-content and children's assessments that determine which measures apply. Existing Part 3 services should already have completed their first illegal-content assessment by 16 March 2025 and children's-access assessment by 16 April 2025; services likely to be accessed by children should have completed their first by 24 July 2025. These are continuing duties, so keep evidence for every yes, no, and not-applicable result.

Section 1

What must be checked before assigning Online Safety Act controls?

Identify the provider entity and map user-generated content, public search, messaging, comments, sharing, and provider-published pornography. Apply the UK-link test, every relevant Schedule 1 exemption, and the Schedule 2 exclusion to each service part.

Once Part 3 scope is approved, complete the and . If children are likely to access any part, complete the separate before finalizing child-safety controls. A new or newly in-scope service generally has three months for its first applicable assessment, but a significant design or operational change requires the relevant risk assessment before the change.

  • Scope approved: the record names the provider, regulated user-to-user and search parts, UK link, Schedule 1 and Schedule 2 conclusions, provider-pornography status, reviewer, date, and change triggers.
  • Illegal-content assessment complete: every relevant harm, risk factor, likelihood, impact, user group, feature, evidence source, finding, and significant-change trigger is recorded.
  • complete: each service part has a recorded two-stage result and evidence; any adult-only conclusion relies on plus access control or a supported child-user-condition analysis.
  • complete where triggered: each relevant kind of harmful content is assessed separately for children's ages, likelihood, impact, and service features.
  • Current duties identified: the checklist distinguishes Part 3, Part 5, child-safety, and formal Category 1, 2A, or 2B requirements.
Section 2

Which controls and evidence should the checklist verify?

For each applicable duty, verify the measure exists, operates on the assessed service version, has a named owner, and produces evidence. A policy statement or implementation ticket alone does not show that a control works.

  • Safety measures: moderation, de-indexing, recommender or ranking changes, user controls, age assurance, access restrictions, reporting, complaints, and terms match the risk and service type.
  • Code mapping: each relevant issued Ofcom code measure is implemented, or the record explains and supports an effective alternative route to the underlying statutory duty. Codes describe a route to compliance; the Act sets the binding duty.
  • User process: reporting and complaints paths are easy to use, transparent, tested, and connected to timely action and recorded outcomes.
  • Records: scope, assessments, control decisions, alternative measures, tests, incidents, complaints, reviews, and approvals are complete and understandable.
  • Privacy and expression: safety processing has data-protection controls and the provider has considered freedom of expression and privacy as required.
  • Ofcom readiness: owners can preserve and supply accurate records, respond to information notices, and track formal category, transparency, fee, and reporting obligations.
Section 3

When is the checklist complete, and when must it be reopened?

Close the checklist only when every applicable item has evidence, every exception has a reason, every gap has an owner and due date, and required pre-launch or pre-change assessments are approved. A completed historic deadline does not close an ongoing duty.

Reopen the checklist before a significant service change and after changes in users, risk evidence, recommender or search design, moderation, age assurance, incidents, complaints, control performance, Ofcom category status, or official regulatory documents.

  • New or changed service: use the applicable event-based assessment period instead of copying the 2025 deadlines for existing services.
  • Child access assessed as unlikely: repeat within 12 months or sooner when Ofcom's specified triggers apply.
  • Before a , complete the relevant illegal-content or .
  • Category 1 or 2A service: after Ofcom published the first register on 30 June 2026 and updated it on 10 July 2026, update the registered service boundary and prepare the current illegal-content risk-assessment record for Ofcom's October 2026 expectation; the record must also reflect the June 2026 risk-profile changes.
  • Source update: record whether the document is binding legislation, an in-force code, non-binding guidance, a formal notice, or a consultation. A consultation proposal is not a current control requirement.
Primary sources

References and citations

ofcom.org.uk
Referenced sections
  • Confirms that Ofcom published the first Category 1, 2A, and 2B register on 30 June 2026, updated it on 10 July 2026, and identifies the formally categorised service parts and providers.
legislation.gov.uk
Referenced sections
  • Primary legislation for service scope, assessment triggers, duties, exemptions, categories, records, and Ofcom powers.
Related guides

Explore more topics

Does the UK Online Safety Act apply to this service?
A practical scope test for user-to-user, search, and provider-pornography services under the UK Online Safety Act, including UK links and exemptions.
How Ofcom and ICO duties overlap for online services
How the UK Online Safety Act, UK GDPR, Data Protection Act 2018, and Children's Code apply together to safety technologies and children's data.
How Ofcom enforces the UK Online Safety Act
Ofcom information notices, investigations, representations, confirmation decisions, penalties, remediation, and court-based service restrictions.
How to complete a children's access assessment
The two-stage UK Online Safety Act children's access assessment, evidence, timing, reassessment triggers, and next duties.
How to complete an illegal content risk assessment
UK Online Safety Act illegal content risk assessment scope, required elements, deadlines, review triggers, records, and resulting safety measures.
Is This a User-to-user or Search Service Under the UK Online Safety Act?
Classify user-to-user, search, and combined services under the UK Online Safety Act, apply the UK-links and exemption tests, and identify the next duties.
Ofcom Transparency Reporting FAQ
Who receives Ofcom transparency notices, what Schedule 8 can require, the 2026 notice process, first-report timing, and evidence controls.
Online Safety Act Children's Access Assessment
Decide whether children are likely to access a regulated service or part of it, document the evidence, and identify when a children's risk assessment follows.
Online Safety Act Complaints Handling Workflow
Route and decide Online Safety Act complaints, record the required response, and distinguish an internal review from an Ofcom complaint or super-complaint.
Online Safety Act Illegal Content Risk Assessment
Assess illegal-content risks by offence kind, likelihood, severity, affected users, service design, controls, evidence, and review triggers.
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Online Safety Act: User-to-user and Search Service Scope
Decide whether an online service is a regulated user-to-user service, search service, combined service, or exempt service under the UK Online Safety Act.
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Compare age verification and age estimation methods by assurance, privacy, accessibility, bias, evasion risk, and operational evidence.
UK Online Safety Act Age Assurance Requirements
When Online Safety Act services need age assurance, what highly effective age assurance means, and how safety duties interact with data protection.
UK Online Safety Act Age Assurance Selection Workflow
Choose an age-assurance method for an Online Safety Act duty by testing effectiveness, privacy, accessibility, evasion risk, and the consequence of error.
UK Online Safety Act Applicability Test Guide
Test whether a service is covered by the UK Online Safety Act by checking service functionality, UK links, exemptions, and the duties that follow.
UK Online Safety Act categories: thresholds and duties
How Category 1, 2A, and 2B thresholds work, how Ofcom categorises services, and what the July 2026 register means.
UK Online Safety Act Categorisation Guide
Apply the UK Online Safety Act Category 1, 2A, and 2B thresholds, calculate active UK users, and use Ofcom's register published in June 2026 and updated in July.
UK Online Safety Act Children's Safety Duties Guide
Apply the UK Online Safety Act children's access, risk-assessment, safety, age-assurance, reporting, complaints, and record-keeping duties.
UK Online Safety Act Compliance Guide
Build a UK Online Safety Act compliance program from service scope through assessments, controls, evidence, review, and Ofcom response.
UK Online Safety Act Content Moderation and Appeals Guide
Design UK Online Safety Act moderation, content-reporting, complaints, and review processes for illegal content and content harmful to children.
UK Online Safety Act Deadlines and Compliance Calendar Guide
UK Online Safety Act compliance dates for risk assessments, child safety, categorised services, fees, and event-based deadlines.
UK Online Safety Act Enforcement and Penalties Guide
How Ofcom investigates Online Safety Act breaches, issues decisions, requires remedies, imposes penalties, and seeks court orders.
UK Online Safety Act FAQ: scope, duties, and deadlines
Standalone answers and decision paths for UK Online Safety Act scope, risk assessments, child protection, age assurance, categories, reporting, and enforcement.
UK Online Safety Act ICO Overlap Guide
Apply the Online Safety Act and UK data protection law together for age assurance, moderation, profiling, recommender systems, and safety-data sharing.
UK Online Safety Act Illegal Content Duties Explained
Understand the illegal-content risk assessment, safety, reporting, complaints, record-keeping, and review duties for regulated user-to-user and search services.
UK Online Safety Act Moderation, Complaints and Appeals
Build moderation, content-reporting, and complaints procedures for regulated services, and understand where the Online Safety Act does and does not require an appeal.
UK Online Safety Act Ofcom Enforcement Guide
How Ofcom assesses Online Safety Act concerns, gathers information, investigates suspected breaches, and reaches enforcement decisions.
UK Online Safety Act Penalties and Fines Guide
The Online Safety Act penalty ceiling, qualifying worldwide revenue, daily penalties, penalty factors, and payment consequences.
UK Online Safety Act Regulated Service Scope Guide
Understand which user-to-user, search, combined, and provider-pornography services the UK Online Safety Act regulates and which exemptions narrow scope.
UK Online Safety Act Requirements Guide
See which UK Online Safety Act requirements apply to Part 3 services, child-accessible services, provider pornography, and categorised services.
UK Online Safety Act Risk Assessment Template
A field-by-field template for recording service facts, statutory risks, evidence, controls, residual risk, approval, and reassessment triggers.
UK Online Safety Act Risk Assessment Workflow
Run illegal-content and children's risk assessments in the right order, with evidence for risks, controls, governance, and reassessment triggers.
UK Online Safety Act Risk Assessments Playbook
Organise recurring Online Safety Act risk assessments across product, safety, data, engineering, legal, and governance teams.
UK Online Safety Act Senior Manager Liability Explained
Understand when a named senior manager or corporate officer can face personal liability for Online Safety Act information offences and how to control the risk.
UK Online Safety Act Service Classification Workflow
Decide whether a service is regulated, whether it is user-to-user or search, which exemptions apply, and whether Ofcom categorisation adds duties.
UK Online Safety Act Service Scope and Categorization Guide
Move from UK Online Safety Act service scope to Category 1, 2A, or 2B threshold analysis without confusing categorisation with basic coverage.
UK Online Safety Act Transparency Reporting
Understand who must publish an Online Safety Act transparency report, what an Ofcom notice controls, and how to prepare traceable reporting data.
UK Online Safety Act vs DSA: scope and duties
Compare UK Online Safety Act and EU DSA scope, service classes, child-safety and platform duties, dates, evidence, exemptions, and enforcement.
When Are Senior Managers Liable Under the UK Online Safety Act?
When section 110 can make a named senior manager liable for an Online Safety Act information offence, the available defences, and the controls to keep.
When is age assurance required under the UK Online Safety Act?
When UK Online Safety Act services need highly effective age assurance, what Ofcom expects, and how UK data protection law applies.