Artifact GuideUKFAQ

UK Online Safety Act FAQ

Use this FAQ to identify the service, apply the right gateway tests, and move from legal scope to owned evidence and controls.

The answers distinguish baseline Part 3 and Part 5 duties from child-access, categorisation, transparency, privacy, and enforcement questions.

Author
Sorena AI
Published
May 9, 2026
Updated
Jul 24, 2026
FAQ modules
11

Structured answer sets in this page tree.

Primary sources
9

Cited legal and guidance references.

Publication metadata
Sorena AI
Published May 9, 2026
Updated Jul 24, 2026
Overview

Start with the service, not the desired control. Decide whether it contains a regulated user-to-user part, search engine, combined-service part, or provider-pornography service and whether it has . Then apply the illegal-content, children's access, age-assurance, complaints, categorisation, reporting, and enforcement rules that fit that result.

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These focused FAQ modules break this artifact into narrower answer sets so teams can move straight to the right source-backed guidance.

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Focused FAQ modules
11
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FAQ module

Does the UK Online Safety Act apply to this service?

A practical scope test for user-to-user, search, and provider-pornography services under the UK Online Safety Act, including UK links and exemptions.

3 items
FAQ module

How Ofcom and ICO duties overlap for online services

How the UK Online Safety Act, UK GDPR, Data Protection Act 2018, and Children's Code apply together to safety technologies and children's data.

3 items
FAQ module

How Ofcom enforces the UK Online Safety Act

Ofcom information notices, investigations, representations, confirmation decisions, penalties, remediation, and court-based service restrictions.

3 items
FAQ module

How to complete a children's access assessment

The two-stage UK Online Safety Act children's access assessment, evidence, timing, reassessment triggers, and next duties.

3 items
FAQ module

How to complete an illegal content risk assessment

UK Online Safety Act illegal content risk assessment scope, required elements, deadlines, review triggers, records, and resulting safety measures.

3 items
FAQ module

Is This a User-to-user or Search Service Under the UK Online Safety Act?

Classify user-to-user, search, and combined services under the UK Online Safety Act, apply the UK-links and exemption tests, and identify the next duties.

4 items
FAQ module

Ofcom Transparency Reporting FAQ

Who receives Ofcom transparency notices, what Schedule 8 can require, the 2026 notice process, first-report timing, and evidence controls.

3 items
FAQ module

Online Safety Act moderation, reporting, and complaints

How UK Online Safety Act duties shape content moderation, user reporting, complaints, reinstatement, terms, records, and human oversight.

3 items
FAQ module

UK Online Safety Act categories: thresholds and duties

How Category 1, 2A, and 2B thresholds work, how Ofcom categorises services, and what the July 2026 register means.

3 items
FAQ module

When Are Senior Managers Liable Under the UK Online Safety Act?

When section 110 can make a named senior manager liable for an Online Safety Act information offence, the available defences, and the controls to keep.

4 items
FAQ module

When is age assurance required under the UK Online Safety Act?

When UK Online Safety Act services need highly effective age assurance, what Ofcom expects, and how UK data protection law applies.

3 items
Question 1

What decision sequence should a provider follow?

First map who provides the service, who generates content, who can encounter it, whether a search engine presents results, whether the provider publishes pornographic content, and which functions are distinct parts. Apply the UK-links test and every relevant Schedule 1 exemption. User count does not decide baseline scope.

For a regulated Part 3 service, complete and maintain the illegal content risk assessment and children's access assessment. If children are likely to access the service or part, complete the children's risk assessment and child-safety controls. Apply age assurance where the Act or Ofcom code requires it. Categorisation and transparency reporting are additional layers for services on Ofcom's register.

  • Record the service and provider scope before assigning individual duties.
  • Use separate conclusions for Part 3 user-to-user, search, combined-service, and Part 5 provider-pornography functions.
  • Link every conclusion to an owner, evidence, review trigger, and implemented control.
Question 2

Which dates matter for an existing regulated service?

Existing Part 3 services had to complete their first illegal content risk assessment by 16 March 2025 and first children's access assessment by 16 April 2025. Services likely to be accessed by children had to complete their first children's risk assessment by 24 July 2025 and apply child-protection measures from 25 July 2025. Part 5 provider-pornography age-assurance duties took effect on 17 January 2025.

These dates are not a safe calendar for a new or changed service. New services generally have three months for the relevant initial assessments, while significant changes can require assessment before launch. Negative children's access conclusions must be repeated within 12 months or sooner when triggered, and risk assessments must be kept up to date.

  • Use the service's own launch, scope-change, and significant-change dates to calculate current obligations.
  • Keep annual reviews and regulator-guidance changes in the compliance calendar.
  • Do not treat a missed historical deadline as permission to wait for the next annual review.
Question 3

Which additional regimes should be checked?

Category 1, 2A, and 2B status adds duties but does not create baseline scope. Ofcom published its register on 10 July 2026. Transparency reporting applies after an annual Ofcom notice to a categorised-service provider; Ofcom's current roadmap places first reports in 2027.

UK data-protection law applies alongside online-safety duties when safety systems process personal data. Age assurance, moderation, profiling, and recommender controls may require a lawful-basis analysis, data protection impact assessment, transparency, minimisation, security, retention, and rights handling. The Children's Code has its own scope test.

  • Check Ofcom's current register rather than self-certifying formal category status.
  • Keep Ofcom and ICO analyses separate but linked to the same service and data flow.
  • Prepare evidence for information notices before enforcement rather than reconstructing decisions after a request.
Primary sources

References and citations

legislation.gov.uk
Referenced sections
  • Defines Part 3 user-to-user, search, and combined services.
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Organise recurring Online Safety Act risk assessments across product, safety, data, engineering, legal, and governance teams.
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Understand when a named senior manager or corporate officer can face personal liability for Online Safety Act information offences and how to control the risk.
UK Online Safety Act Service Classification Workflow
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Move from UK Online Safety Act service scope to Category 1, 2A, or 2B threshold analysis without confusing categorisation with basic coverage.
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Understand who must publish an Online Safety Act transparency report, what an Ofcom notice controls, and how to prepare traceable reporting data.
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