The child safety regime had a staged rollout through 2025 and now needs to be live in operations.
Services likely to be accessed by children need more than age gates. They need a documented child access decision, a children risk assessment, and controls that actually change the product experience.
Structured answer sets in this page tree.
Cited legal and guidance references.
The government implementation materials make the sequence clear. Ofcom published age assurance guidance for online pornography in January 2025, section 81 came into force on 17 January 2025, child access assessments were due by 16 April 2025, and services likely to be accessed by children then had until 24 July 2025 to complete their children's risk assessment.
Before you apply child safety controls, determine whether the service is likely to be accessed by children. This assessment should consider the actual service experience, not only the intended audience in marketing copy.
The output should be a documented yes or no decision with evidence and review triggers.
Services likely to be accessed by children then need a children risk assessment. Government materials highlight duties to stop children encountering harmful and age inappropriate content, including pornography and legal content that encourages, promotes, or instructs on suicide, self-harm, or eating disorders.
This is a systems design exercise, not a disclosure exercise.
The ICO Children's Code applies to information society services likely to be accessed by children and sets out 15 standards of age-appropriate design. In practice, age assurance, privacy defaults, geolocation, profiling, and nudge techniques should be reviewed in the same product forum as UK OSA child safety controls.
Doing this together reduces the risk of building a child safety control that creates a child privacy problem.
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