---
title: "UK Online Safety Act Children Safety Duties"
canonical_url: "https://www.sorena.io/artifacts/uk/online-safety-act/children-safety-duties"
source_url: "https://www.sorena.io/artifacts/uk/online-safety-act/children-safety-duties"
author: "Sorena AI"
description: "Grounded guide to UK Online Safety Act children safety duties covering section 81 timing, children access assessments, children risk assessments."
published_at: "2026-02-21"
updated_at: "2026-02-21"
keywords:
  - "UK Online Safety Act children safety duties"
  - "children access assessment"
  - "children risk assessment"
  - "section 81 online safety act"
  - "age assurance children"
  - "children safety duties"
  - "age assurance"
---
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# UK Online Safety Act Children Safety Duties

Grounded guide to UK Online Safety Act children safety duties covering section 81 timing, children access assessments, children risk assessments.

*Duty Guide* *Children Safety*

## Children Safety Duties

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.

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.

## Start with the children access 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.

- Record the age exposure evidence used for the decision
- Note any features that materially increase the chance children will access the service
- Set triggers for reassessment after major product or market changes

## Use the children risk assessment to drive design controls

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.

- Map harm scenarios by age band and service feature
- Set age restrictions and age assurance measures where the service relies on them
- Link each child risk to a prevention, detection, response, and review control

## Bring ICO child-data controls into the same design review

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.

- Default to high privacy and avoid harmful profiling patterns
- Switch off geolocation by default unless there is a compelling reason not to
- Use age assurance and age estimation in a way that is proportionate, privacy aware, and testable

*Recommended next step*

*Placement: near the end of the main content before related guides*

## Use Children Safety Duties as a cited research workflow

Research Copilot can take Children Safety Duties from getting cited answers and faster research on this topic to a reusable workflow inside Sorena. Teams working on Children Safety can keep owners, evidence, and next steps aligned without copying this guide into separate documents.

- [Open Research Copilot for Children Safety Duties](/solutions/research-copilot.md): Start from Children Safety Duties and answer scope, timing, and interpretation questions with cited outputs.
- [Talk through Children Safety](/contact.md): Review your current process, evidence gaps, and next steps for Children Safety Duties.

## Primary sources

- [Online Safety Act explainer](https://www.gov.uk/government/publications/online-safety-act-explainer/online-safety-act-explainer?ref=sorena.io) - Current government implementation status, deadlines, and plain language explanation of the regime.
- [ICO introduction to the Children's Code](https://ico.org.uk/for-organisations/uk-gdpr-guidance-and-resources/childrens-information/childrens-code-guidance-and-resources/introduction-to-the-childrens-code/?ref=sorena.io) - ICO explanation of scope for information society services likely to be accessed by children and the 15 standards.
- [ICO audit guide for the Age Appropriate Design Code](https://ico.org.uk/for-organisations/advice-and-services/audits/data-protection-audit-framework/toolkits/age-appropriate-design/?ref=sorena.io) - Audit scope and control themes for children's data, including age assurance, privacy settings, geolocation, profiling, and nudge techniques.

## Related Topic Guides

- [UK Online Safety Act Age Assurance Options | Age Estimation, Verification, and Child Access Controls](/artifacts/uk/online-safety-act/age-assurance-options.md): Grounded age assurance guide for the UK Online Safety Act covering January 2025 pornography guidance, highly effective age assurance.
- [UK Online Safety Act Applicability Test | Regulated Service, Exemptions, and UK Scope](/artifacts/uk/online-safety-act/applicability-test.md): Grounded UK Online Safety Act applicability test covering regulated user-to-user and search services, Schedule 1 exemptions, provider pornography scope.
- [UK Online Safety Act Checklist | Scope, Risk, Child Safety, Moderation, and Evidence](/artifacts/uk/online-safety-act/checklist.md): Audit-ready UK Online Safety Act checklist covering service scope, illegal risk assessment, child access and child risk assessment, moderation, complaints.
- [UK Online Safety Act Compliance Program | Governance, Controls, and Ofcom Readiness](/artifacts/uk/online-safety-act/compliance.md): Program design guide for UK Online Safety Act compliance covering governance, scope, assessments, moderation, age assurance, complaints, metrics.
- [UK Online Safety Act Content Moderation and Appeals | Complaints, Terms Enforcement, and Redress](/artifacts/uk/online-safety-act/content-moderation-and-appeals.md): Grounded guide to UK Online Safety Act moderation and appeals requirements covering sections 21, 32, 71, and 72, complaints design, terms enforcement.
- [UK Online Safety Act Deadlines and Compliance Calendar | 2023 to 2026 Milestones](/artifacts/uk/online-safety-act/deadlines-and-compliance-calendar.md): Grounded UK Online Safety Act calendar covering 26 October 2023 enactment, 31 January 2024 offences, 16 December 2024 illegal harms codes.
- [UK Online Safety Act Enforcement and Penalties | Ofcom Notices, Penalties, and Escalation](/artifacts/uk/online-safety-act/enforcement-and-penalties.md): Grounded UK Online Safety Act enforcement guide covering Ofcom information notices, senior manager naming, confirmation decisions.
- [UK Online Safety Act FAQ | Scope, Child Duties, Categories, and Ofcom Enforcement](/artifacts/uk/online-safety-act/faq.md): Practical FAQ on the UK Online Safety Act covering who is in scope, what changed in 2025, child access and risk assessments, age assurance, category duties.
- [UK Online Safety Act Illegal Content Duties | Illegal Harms, Priority Offences, and Risk Assessments](/artifacts/uk/online-safety-act/illegal-content-duties-explained.md): Grounded guide to UK Online Safety Act illegal content duties covering user-to-user and search services, illegal content risk assessments.
- [UK Online Safety Act Penalties and Fines | GBP 18 Million, 10 Percent Revenue, and Liability](/artifacts/uk/online-safety-act/penalties-and-fines.md): Grounded penalty guide for the UK Online Safety Act covering the GBP 18 million or 10 percent worldwide revenue cap.
- [UK Online Safety Act Requirements | Sections, Deadlines, Controls, and Evidence](/artifacts/uk/online-safety-act/requirements.md): Detailed UK Online Safety Act requirements guide mapping scope, illegal content duties, child safety duties, terms enforcement, complaints, categorisation.
- [UK Online Safety Act Risk Assessment Template | Illegal Content and Child Safety Template](/artifacts/uk/online-safety-act/online-safety-risk-assessment-template.md): Practical UK Online Safety Act risk assessment template covering service profile, harms inventory, controls, residual risk, child access, child safety.
- [UK Online Safety Act Risk Assessments Playbook | How to Run Illegal and Children Risk Reviews](/artifacts/uk/online-safety-act/risk-assessments-playbook.md): Operational playbook for UK Online Safety Act risk assessments covering sequencing, ownership, evidence collection, control design.
- [UK Online Safety Act Service Scope and Categorization | Category 1, 2A, 2B, and Part 3 Logic](/artifacts/uk/online-safety-act/service-scope-and-categorization.md): Grounded service scope and categorisation guide for the UK Online Safety Act covering Part 3 logic, likely to be accessed by children, Category 1, 2A.
- [UK Online Safety Act vs EU Digital Services Act | Scope, Child Safety, and Enforcement Differences](/artifacts/uk/online-safety-act/online-safety-act-vs-dsa.md): Practical comparison of the UK Online Safety Act and the EU Digital Services Act covering regulated service models, illegal content frameworks.


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