Artifact GuideUKChildren's Access Assessment

UK Online Safety Act Children's Access Assessment

Every regulated Part 3 user-to-user and search service must decide whether children are likely to access the service or a distinct part of it.

This guide explains Ofcom's two-stage test, the evidence needed for a negative conclusion, review timing, and the next child-safety assessment.

Author
Sorena AI
Published
May 9, 2026
Updated
Jul 25, 2026
Questions
3

Structured answer sets in this page tree.

Primary sources
5

Cited legal and guidance references.

Publication metadata
Sorena AI
Published May 9, 2026
Updated Jul 25, 2026
Overview

A is a gateway decision, not a children's risk assessment. It asks whether anyone under 18 can normally access the service and, if so, whether children use it in significant numbers or the service is likely to attract them. A service cannot rely on terms that say '18+' without evidence that access is prevented.

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3 of 3 questions
Question 1

How does the two-stage test work?

Stage one asks whether children can normally access the service or a particular part of it. A provider can conclude they cannot only where highly effective age assurance and access controls prevent users who have not been identified as adults from entering. Self-declared age, an age statement in terms, or a weak gate does not support that conclusion.

If children can access the service, stage two asks whether the is met: there is a significant number of child users, or the service is of a kind likely to attract a significant number of children. Assess actual and foreseeable use, not only the intended audience. A conclusion can differ between distinct parts of one service.

  • Define the service or part being assessed and treat a child as a person under 18.
  • Use user data, research, complaints, content, design, marketing, competitors, and foreseeable circumvention to assess actual use and likely attraction.
  • Record the steps and detailed evidence supporting the result, especially any conclusion that the service is not likely to be accessed by children.
Citations
Question 2

When is the assessment due and when must it be repeated?

The initial deadline for services already in scope was 16 April 2025. A user-to-user or search service that later comes into scope must complete the assessment within three months of the first day it becomes available to UK users.

If the provider concludes that the service is not likely to be accessed by children, it must repeat the assessment within 12 months, and sooner where the Act or Ofcom guidance requires. Reassess before or after relevant changes as required, including changes to design, operation, target market, age controls, or evidence of child use.

  • Set a dated annual reassessment trigger for every negative conclusion.
  • Start an earlier review when a product change could alter child access or attraction, or when new evidence contradicts the existing conclusion.
  • Keep prior versions and change logs so reviewers can see why the outcome changed or remained the same.
Citations
Question 3

What happens if children are likely to access the service?

The provider must complete a suitable and sufficient children's risk assessment for the affected service or part and comply with the applicable child-safety, record-keeping, and review duties. For existing services, the first children's risk assessment deadline was 24 July 2025 and child-protection measures applied from 25 July 2025.

A negative access conclusion does not remove the baseline illegal-content duties. It also does not settle whether the Children's Code applies, because the data-protection and Online Safety Act tests have different legal sources and should be assessed separately.

  • Open the children's risk assessment with the access-assessment scope, evidence, affected age groups, and service parts.
  • Map the risk findings to proportionate systems and processes, Ofcom code measures or documented alternatives, owners, and test evidence.
  • Keep the privacy and Online Safety Act analyses connected but record their separate legal conclusions.
Citations
Primary sources

References and citations

legislation.gov.uk
Referenced sections
  • Defines when a service is likely to be accessed by children and the child user condition.
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