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
Oct 15, 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: record each service part's two-stage result and evidence. A conclusion that children cannot normally access it needs plus access controls. If they can access it, separately test whether significant numbers use it or it is likely to attract significant numbers of children.
  • 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, required compliance gaps are resolved, every exception has a valid reason, and required pre-launch or pre-change assessments are approved. Keep other follow-up actions with owners and due dates. 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 most recently updated it on 28 September 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.uk2 citations
Referenced sections
  • Current issued codes and guidance used to verify assessment, control, and record evidence.
  • Current codes and guidance used to verify measures, content judgements, assessments, and records.
legislation.gov.uk2 citations
Referenced sections
  • Primary source for every legal trigger and duty checked on this page.
  • Primary legislation for service scope, assessment triggers, duties, exemptions, categories, records, and Ofcom powers.
ofcom.org.uk
Referenced sections
  • Confirms that Ofcom published the first Category 1, 2A, and 2B register on 30 June 2026, most recently updated it on 28 September 2026, and identifies the formally categorised service parts and providers.
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