Artifact GuideUKDeadlines and Compliance Calendar

UK Online Safety Act Deadlines and Compliance Calendar

Separate the historic deadlines for the first cohort of regulated services from the event-based deadlines that apply when a service starts, becomes regulated, or materially changes.

Royal Assent and commencement dates do not by themselves tell a provider when its assessment is due. Match the service event to Schedule 3, the applicable Ofcom guidance, and any notice-specific deadline.

Author
Sorena AI
Published
May 9, 2026
Updated
Jul 16, 2026
Sections
4

Structured answer sets in this page tree.

Primary sources
4

Cited legal and guidance references.

Publication metadata
Sorena AI
Published May 9, 2026
Updated Jul 16, 2026
Overview

For existing Part 3 services, the initial sequence was 16 March 2025 for illegal-content risk assessments, 16 April 2025 for children’s access assessments, 24 July 2025 for children’s risk assessments where the service was likely accessed by children, and 25 July 2025 for the child-safety duties. Later services must calculate their own deadlines from the Act rather than reuse these dates.

Section 1

Which UK Online Safety Act deadlines should teams track in the compliance calendar?

Record 16 March 2025 as the initial illegal-content risk-assessment deadline and 17 March 2025 as the date the corresponding illegal-content duties became enforceable. These are different events and should not be collapsed into one milestone.

Record 16 April 2025 as the initial children’s access-assessment deadline. For services assessed as likely to be accessed by children, record 24 July 2025 for the first children’s risk assessment and 25 July 2025 for the child-safety duties taking effect.

Part 5 provider-pornography services followed a separate route: section 81 commenced on 17 January 2025 and Ofcom’s age-assurance guidance governs the practical standard. Categorised-service, transparency-report, fee, CSEA-reporting, and information-notice dates must be tracked separately rather than inferred from the Part 3 child-safety dates.

  • Label every entry as legislation, commencement, statutory guidance, code, assessment deadline, enforceable duty, consultation, or internal target.
  • For a new or newly in-scope service, calculate the deadline from Schedule 3 and the relevant guidance publication event.
  • Attach the affected service, owner, legal trigger, evidence record, review frequency, and escalation contact.
  • Do not present an Ofcom consultation or expected publication date as a binding provider deadline.
Section 2

How do ongoing and event-based deadlines differ from the 2025 implementation dates?

The 2025 dates describe the first implementation wave. A service that launches later, acquires UK links, adds user-to-user or search functionality, or becomes likely to be accessed by children must use the statutory timing rules for that event.

Risk assessments also require review before significant design changes and when the provider has reason to suspect a material change in risk. Ofcom information notices, confirmation decisions, and transparency-report notices carry their own response periods.

  • Maintain a service start/change log so legal can calculate event-based dates.
  • Create recurring review entries for illegal-content and children’s risk assessments, with a documented change trigger.
  • Track regulator notices separately because their due dates depend on the notice received.
  • Keep completed assessments and the control changes they produced, not only calendar reminders.
Section 3

Which status distinctions prevent misleading calendar entries?

The Act, commencement regulations, Ofcom codes, statutory guidance, non-statutory guidance, consultations, and government correspondence do different jobs. A code can provide a route to compliance, but the underlying duty comes from the Act; consultation text is not a final rule.

Categorisation is also not the gateway to the core illegal-content or child-safety duties. Those can apply to non-categorised Part 3 services; categories add further duties after Ofcom places a service on the register.

  • Mark parliamentary approval and a code taking effect separately from Ofcom’s earlier consultation or statement.
  • Do not label the Secretary of State’s strategic priorities as direct provider duties.
  • Do not treat voluntary age-assurance standards as substitutes for the Act and Ofcom’s effectiveness criteria.
  • Date-stamp any expected categorised-service measure and label it as pending until final instruments and Ofcom materials apply.
Section 4

What evidence should sit behind each calendar entry?

A defensible calendar entry identifies the affected service and statutory trigger, links to the controlling source, names the accountable owner, and points to the completed record. The calendar is an index to evidence, not the evidence itself.

For assessments, keep the methodology, risk findings, affected user groups, algorithms and functionalities considered, mitigations chosen, approval, completion date, and next review trigger. For notices and reports, keep the received instrument, response owner, data provenance, submission record, and follow-up correspondence.

  • Link each legal deadline to the exact service-scope decision that triggered it.
  • Store code-version and guidance-version information with the implemented measures.
  • Record why an alternative-to-code measure meets the underlying duty if the provider does not follow the recommended code measure.
  • Recalculate dates after acquisitions, product launches, UK expansion, material functionality changes, or a changed child-access conclusion.
Primary sources

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