Artifact GuideUKDeadlines and Compliance Calendar

UK Online Safety Act Deadlines and Compliance Calendar

Keep the completed 2025 implementation dates separate from deadlines created by a launch, a significant service change, categorisation, a fee year, or an Ofcom notice.

The controlling date depends on the service, duty, and trigger. Record whether an entry is a statutory deadline, an Ofcom expectation, a consultation date, or an internal target.

Author
Sorena AI
Published
May 9, 2026
Updated
Oct 15, 2026
Overview

For Part 3 services already in scope during the first implementation wave, the main deadlines were 16 March 2025 for illegal-content risk assessments, 16 April 2025 for children's access assessments, and 24 July 2025 for children's risk assessments where the service was likely to be accessed by children. The illegal-content safety duties applied from 17 March 2025 and the children's safety duties from 25 July 2025. The began for regulated user-to-user services on 7 April 2026. A later service must calculate its dates from its own trigger rather than reuse the 2025 dates.

Section 1

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

For the first cohort of Part 3 user-to-user and search services, record 16 March 2025 as the illegal-content risk-assessment deadline and 17 March 2025 as the date the illegal-content safety duties took effect. These are separate milestones.

Record 16 April 2025 as the first children's access-assessment deadline. A service found likely to be accessed by children then had until 24 July 2025 to complete its first children's risk assessment, and the children's safety duties applied from 25 July 2025.

Part 5 services that publish or display regulated provider pornographic content followed a separate timetable. Their highly effective age-assurance duty took effect on 17 January 2025. Do not derive a Part 5 deadline from the Part 3 children's timetable.

From 7 April 2026, regulated user-to-user services must report detected and unreported child sexual exploitation and abuse content under the statutory reporting regime. UK providers report all such content; providers outside the UK report UK-linked content. The April 2026 regulations do not yet commence the duty for search services, and content already reported to a qualifying foreign agency is not reported again.

  • Label each entry as a statutory deadline, duty commencement, Ofcom expectation, consultation close, notice-specific deadline, or internal target.
  • Name the affected service and whether Part 3, Part 5, categorised-service, fee, or reporting duties create the entry.
  • Keep the assessment completion date separate from the date on which related safety measures must operate.
  • Attach the controlling source, accountable owner, evidence record, and escalation contact.
  • Treat the as an ongoing event-driven obligation, with portal registration, report timeframes, retention, and duplicate-report checks built into the operating process.
Section 2

Which current and upcoming 2026 dates belong in the calendar?

Use Ofcom's register to confirm the categorised service and registered part. Category 1 and Category 2A providers must now give Ofcom a copy of an illegal-content risk-assessment record, and any applicable children's risk-assessment record, as soon as reasonably practicable after making or revising it. Ofcom expects current records by October 2026 and published summaries by November 2026; those months are regulator expectations, not substitutes for the statutory 'as soon as reasonably practicable' test.

A 31 July 2026 deadline applies only to providers that received Ofcom's April 2026 formal information request for risk-assessment records. For the 2027/28 fee year, the notification window for new fee-liable providers closed on 30 September 2026. Existing fee-payers received a rolling information request for updated service details and 2025 qualifying worldwide revenue, also due on 30 September 2026; retain the request and response evidence.

Ofcom's 30 September 2026 update confirms that the 2026/27 tariff has been published and that it intends to issue invoices throughout October 2026. The 2027/28 notification window closed on 30 September 2026; Ofcom expects that year's tariff in March 2027 and invoices from April 2027. Use each invoice for the provider's actual payment deadline and check the applicable instalment terms. Treat dates for consultations and proposed additional safety measures as planning entries until the relevant final measure and legal process are complete.

  • For Category 1 and Category 2A services, calendar the statutory record-sharing duty and separately record Ofcom's October and November 2026 expectations.
  • For an April 2026 risk-assessment information request, use the deadline in the notice; Ofcom's programme identifies 31 July 2026 for that request round.
  • For fees, distinguish a notification, a request for revenue evidence, an invoice, and a payment date.
  • Treat consultation closing dates as optional participation dates, not provider compliance deadlines.
Section 3

How should a new service or product change calculate its dates?

A Part 3 service that becomes available to UK users after the relevant guidance has been published generally has three months from the day it comes into scope to complete its first illegal-content risk assessment and children's access assessment.

Ofcom's quick guide describes a three-month children's risk-assessment period after launch. Its detailed Children's Risk Assessment Guidance, paragraph 2.21, measures that period from the positive children's access-assessment conclusion, including for a new service.

Record both dates, plan to the earlier deadline where they differ, and seek Ofcom clarification before relying on the later one. For other trigger events, calculate the deadline under Schedule 3 using the actual event.

Complete the relevant risk assessment before making a significant change to the service. If a children's access assessment concludes that the service is not likely to be accessed by children, repeat it no more than 12 months later and sooner if a specified trigger occurs, including a relevant significant change, reduced age-assurance effectiveness, or evidence of a significant increase in child users.

  • For the first illegal-content risk assessment and children's access assessment, start the clock from the actual UK availability or other applicable scope-trigger date, not the company's incorporation date. Use the separate children's risk-assessment timing comparison above.
  • Run a pre-launch deadline check when adding user-to-user, search, or provider-pornography functionality.
  • Put a product-change gate before recommender, moderation, messaging, search, age-assurance, or audience changes that may alter risk.
  • If the scope or trigger date is uncertain, record the assumption and obtain case-specific legal review before relying on the calculated date.
Section 4

What evidence should sit behind each calendar entry?

Each calendar entry should identify the legal or regulatory trigger, affected service, date-calculation method, owner, and completed evidence. A reminder alone does not show compliance.

For assessments, retain the methodology, findings, relevant user groups and service features, chosen measures, approval, completion date, and next review trigger. For an Ofcom notice, retain the notice itself, receipt date, response deadline, preservation steps, data provenance, representations, submission evidence, and follow-up correspondence.

  • Link each date to the service-scope decision and source provision that created it.
  • Record the time zone and receipt method for notice-specific deadlines.
  • Keep the version of each code or guidance document used, but do not present guidance publication as the source of an underlying statutory duty.
  • Recalculate dates after launch, UK expansion, acquisition, significant functionality change, altered age assurance, or a changed conclusion about child access.
Primary sources

References and citations

ofcom.org.uk3 citations
Referenced sections
  • Current Ofcom calendar for completed implementation dates, live duties, consultations, and expected future milestones.
  • Lists the 2025 assessment deadlines and the dates on which the illegal-content, children's safety, and Part 5 age-assurance duties took effect.
  • Provides Ofcom's current calendar of duties, actions, consultations, and expected implementation dates.
ofcom.org.uk2 citations
Referenced sections
  • Confirms the 16 April 2025 first-cohort deadline and the three-month deadline for a service that came into scope after 16 January 2025.
  • Explains the three-month first assessment, annual reassessment, and earlier reassessment triggers.
ofcom.org.uk2 citations
Referenced sections
  • States the risk-record duties for Category 1 and Category 2A providers and Ofcom's October and November 2026 expectations.
  • Confirms the three-month deadline after launch and the requirement to complete an illegal-content risk assessment before a significant change.
ofcom.org.uk2 citations
Referenced sections
  • Current notification, invoice, and payment timetable for the online safety fees regime.
  • Confirms the 30 September 2026 notification deadline for new fee-liable providers and the current invoice and payment timetable.
ofcom.org.uk2 citations
Referenced sections
  • Confirms the first register published on 30 June 2026, its 28 September 2026 update, and formal service-specific categorisation decisions.
  • Confirms publication of the register and that final categorisation decisions have been issued to providers.
legislation.gov.uk2 citations
Referenced sections
  • Binding source for assessment timing, recurring and event-based duties, categorised-service duties, information notices, fees, and enforcement.
  • Binding source for assessment timing, record-keeping, information powers, categorised-service duties, and enforcement notices.
ofcom.org.uk
Referenced sections
  • Gives the launch-based summary of children's risk-assessment timing; compare detailed guidance paragraph 2.21, which uses the positive access-assessment conclusion. Also confirms the pre-change assessment requirement.
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