--- title: "What should teams do about Illegal Content Risk Assessment under the UK Online Safety Act?" canonical_url: "https://www.sorena.io/artifacts/uk/online-safety-act/faq/illegal-content-risk-assessment" source_url: "https://www.sorena.io/artifacts/uk/online-safety-act/faq/illegal-content-risk-assessment" author: "Sorena AI" description: "UK Online Safety Act guidance for Illegal Content Risk Assessment, with practical decisions, evidence, edge cases, and external source citations." published_at: "2026-05-09" updated_at: "2026-05-09" keywords: - "UK Online Safety Act" - "Illegal Content Risk Assessment" - "UK Online Safety Act Illegal Content Risk Assessment" - "compliance checklist" - "practical guidance" - "Compliance" - "Regulatory guidance" --- **[SORENA](https://www.sorena.io/)** - AI-Powered GRC Platform [Home](https://www.sorena.io/) | [Solutions](https://www.sorena.io/solutions) | [Artifacts](https://www.sorena.io/artifacts) | [About Us](https://www.sorena.io/about-us) | [Contact](https://www.sorena.io/contact) | [Portal](https://app.sorena.io) --- # What should teams do about Illegal Content Risk Assessment under the UK Online Safety Act? UK Online Safety Act guidance for Illegal Content Risk Assessment, with practical decisions, evidence, edge cases, and external source citations. *Artifact Guide* *UK* *Illegal Content Risk Assessment* ## UK Online Safety Act Illegal Content Risk Assessment Illegal Content Risk Assessment decisions under the UK Online Safety Act should be written in operational language: who is in scope, what must happen, what evidence proves it, and when escalation is needed. Use this guide to turn official requirements into scope, evidence, owner, and review decisions. This guidance is practical, source-linked, and should be validated against current legal and policy requirements before implementation. This page explains the illegal content risk assessment duty in practical terms: which regulated user-to-user and search services are in scope, what the assessment is for, when it should be done, and what evidence teams should keep. ## What the illegal content risk assessment duty means in practice Under the Online Safety Act, user-to-user services and search services in scope must assess the risks of illegal content on their services and use that assessment to decide what proportionate measures to take. For user-to-user services, section 9 covers illegal content risk assessment duties; for search services, section 26 does the same. A visitor should first confirm whether the service is a regulated user-to-user service or search service, then check whether it is exempt, and then map the service features and user flows that could expose users to illegal content. The practical outcome should be a recorded decision, an owner, and a review date. If the service is in scope, the assessment should happen before or when the service becomes subject to the regime, and it should be kept up to date as the service changes. Schedule 3 sets out timing rules for illegal content risk assessments. - Confirm whether the service is a regulated user-to-user service or a search service, and whether any schedule 1 exemption applies. - Identify the parts of the service where illegal content could be encountered, disseminated, or amplified. - Record the assessment owner, evidence, and next review point so the decision can be revisited when the service changes. Sources for this answer: - [Online Safety Act 2023](https://www.legislation.gov.uk/ukpga/2023/50/contents?ref=sorena.io) - Primary legal source for the illegal content risk assessment duty, scope, exemptions, and timing. - [Online Safety Act 2023](https://www.legislation.gov.uk/ukpga/2023/50/contents?ref=sorena.io) - Primary legal source for search service duties. - [Online Safety Act 2023](https://www.legislation.gov.uk/ukpga/2023/50/contents?ref=sorena.io) - Primary legal source for the timing of assessments. ## What evidence should teams keep for Illegal Content Risk Assessment under the UK Online Safety Act? Useful evidence is not just a safety policy. Keep the source, service map, risk assessment, mitigation evidence, age-assurance rationale, terms/complaints records, and Ofcom-readiness trail together. - Source URL and quote used for the decision. - Scope notes, screenshots, data-flow or system references, and role mapping. - Implementation ticket, approval record, exception notes, and review date. Sources for this answer: - [UK Government - Online Safety Act explainer](https://www.gov.uk/government/publications/online-safety-act-explainer/online-safety-act-explainer?ref=sorena.io) - Evidence support for the FAQ answer. - [Online Safety Act: Protection of Children Codes of Practice - explanatory memorandum](https://www.gov.uk/government/publications/online-safety-act-protection-of-children-codes-of-practice-explanatory-memorandum/online-safety-act-protection-of-children-codes-of-practice-explanatory-memorandum?ref=sorena.io) - Evidence support for the FAQ answer. - [UK Government - Online Safety Act collection](https://www.gov.uk/government/collections/online-safety-act?ref=sorena.io) - Evidence support for the FAQ answer. ## Which mistakes create risk when handling Illegal Content Risk Assessment under the UK Online Safety Act? The common failure pattern is treating online safety as generic moderation without checking service scope, child access, illegal content duties, code measures, age assurance, complaints, and transparency reporting. - Using an old threshold, deadline, source page, or contract template without checking current source text. - Treating a source-linked exception as a general exemption for every product or data flow. - Publishing notices, controls, or answers that do not match the actual product behavior. Sources for this answer: - [Online Safety Act - Illegal Content Codes of Practice 2024: explanatory memorandum](https://www.gov.uk/government/publications/online-safety-act-illegal-content-codes-of-practice-2024-explanatory-memorandum/online-safety-act-illegal-content-codes-of-practice-2024-explanatory-memorandum?ref=sorena.io) - Risk and boundary support for the FAQ answer. - [UK Government - Online Safety Act explainer](https://www.gov.uk/government/publications/online-safety-act-explainer/online-safety-act-explainer?ref=sorena.io) - Risk and boundary support for the FAQ answer. - [Online Safety Act: Protection of Children Codes of Practice - explanatory memorandum](https://www.gov.uk/government/publications/online-safety-act-protection-of-children-codes-of-practice-explanatory-memorandum/online-safety-act-protection-of-children-codes-of-practice-explanatory-memorandum?ref=sorena.io) - Risk and boundary support for the FAQ answer. - [UK Government - Online Safety Act collection](https://www.gov.uk/government/collections/online-safety-act?ref=sorena.io) - Risk and boundary support for the FAQ answer. ## Primary sources - [Online Safety Act - Illegal Content Codes of Practice 2024: explanatory memorandum](https://www.gov.uk/government/publications/online-safety-act-illegal-content-codes-of-practice-2024-explanatory-memorandum/online-safety-act-illegal-content-codes-of-practice-2024-explanatory-memorandum?ref=sorena.io) - The GOV.UK memorandum supports this illegal-content risk-assessment guidance by explaining the Online Safety Act illegal-content codes and related provider duties. - Quote: "Notice Online Safety Act - Illegal Content Codes of Practice 2024: explanatory memorandum Published 17 December 2024 Contents" - [UK Government - Online Safety Act explainer](https://www.gov.uk/government/publications/online-safety-act-explainer/online-safety-act-explainer?ref=sorena.io) - Supports Illegal Content Risk Assessment under the UK Online Safety Act. - Quote: "The Online Safety Act 2023 (the Act) is a new set of laws that protects children and adults online." - [Online Safety Act: Protection of Children Codes of Practice - explanatory memorandum](https://www.gov.uk/government/publications/online-safety-act-protection-of-children-codes-of-practice-explanatory-memorandum/online-safety-act-protection-of-children-codes-of-practice-explanatory-memorandum?ref=sorena.io) - Supports Illegal Content Risk Assessment under the UK Online Safety Act. - Quote: "This document section concerns the Protection of children codes of practice under the Online Safety Act (OSA)" - [UK Government - Online Safety Act collection](https://www.gov.uk/government/collections/online-safety-act?ref=sorena.io) - Supports Illegal Content Risk Assessment under the UK Online Safety Act. - Quote: "The Online Safety Act 2023 (the Act) protects children and adults online." - [UK Government - Statement of Strategic Priorities for Online Safety](https://www.gov.uk/government/publications/statement-of-strategic-priorities-for-online-safety/final-statement-of-strategic-priorities-for-online-safety?ref=sorena.io) - Supports Illegal Content Risk Assessment under the UK Online Safety Act. - Quote: "Providers must use risk and evidence-based approaches to ensure there is no room for illegal content and activity on their platforms." ## Topic Guides - [How should teams decide whether UK Online Safety Act applies?](/artifacts/uk/online-safety-act/faq/regulated-service-scope.md): UK Online Safety Act guidance for Regulated Service Scope, with practical decisions, evidence, edge cases, and external source citations. - [UK Online Safety Act Age Assurance Guide](/artifacts/uk/online-safety-act/age-assurance.md): UK Online Safety Act guidance for Age Assurance, with practical decisions, evidence, edge cases, and external source citations. - [UK Online Safety Act Age Assurance Options Guide](/artifacts/uk/online-safety-act/age-assurance-options.md): UK Online Safety Act guidance for Age Assurance Options, with practical decisions, evidence, edge cases, and external source citations. - [UK Online Safety Act Age Assurance Selection Workflow Guide](/artifacts/uk/online-safety-act/age-assurance-selection-workflow.md): UK Online Safety Act guidance for Age Assurance Selection Workflow, with practical decisions, evidence, edge cases, and external source citations. - [UK Online Safety Act Applicability Test Guide](/artifacts/uk/online-safety-act/applicability-test.md): Practical guidance for the UK Online Safety Act applicability test, with practical decisions, evidence, edge cases, and external source citations. - [UK Online Safety Act Categorisation Guide](/artifacts/uk/online-safety-act/categorisation.md): UK Online Safety Act guidance for Categorisation, with practical decisions, evidence, edge cases, and external source citations. - [UK Online Safety Act Checklist](/artifacts/uk/online-safety-act/checklist.md): Practical guidance for the UK Online Safety Act checklist, with practical decisions, evidence, edge cases, and external source citations. - [UK Online Safety Act Children's Access Assessment Guide](/artifacts/uk/online-safety-act/children-s-access-assessment.md): UK Online Safety Act guidance for Children's Access Assessment, with practical decisions, evidence, edge cases, and external source citations. - [UK Online Safety Act Children's Safety Duties Guide](/artifacts/uk/online-safety-act/children-safety-duties.md): UK Online Safety Act guidance for Children's Safety Duties, with practical decisions, evidence, edge cases, and external source citations. - [UK Online Safety Act Complaint And Appeal Handling Workflow Guide](/artifacts/uk/online-safety-act/complaint-and-appeal-handling-workflow.md): UK Online Safety Act guidance for Complaint And Appeal Handling Workflow, with practical decisions, evidence, edge cases, and external source citations. - [UK Online Safety Act Compliance Guide](/artifacts/uk/online-safety-act/compliance.md): Practical guidance for the UK Online Safety Act compliance, with practical decisions, evidence, edge cases, and external source citations. - [UK Online Safety Act Content Moderation And Appeals Guide](/artifacts/uk/online-safety-act/content-moderation-and-appeals.md): UK Online Safety Act guidance for Content Moderation And Appeals, with practical decisions, evidence, edge cases, and external source citations. - [UK Online Safety Act Deadlines and Compliance Calendar Guide](/artifacts/uk/online-safety-act/deadlines-and-compliance-calendar.md): UK Online Safety Act guidance for Deadlines and Compliance Calendar, with practical decisions, evidence, edge cases, and external source citations. - [UK Online Safety Act Enforcement And Penalties Guide](/artifacts/uk/online-safety-act/enforcement-and-penalties.md): UK Online Safety Act guidance for Enforcement And Penalties, with practical decisions, evidence, edge cases, and external source citations. - [UK Online Safety Act FAQ](/artifacts/uk/online-safety-act/faq.md): Practical guidance for the UK Online Safety Act FAQ, with practical decisions, evidence, edge cases, and external source citations. - [UK Online Safety Act ICO Overlap Guide](/artifacts/uk/online-safety-act/ico-overlap.md): UK Online Safety Act guidance for ICO Overlap, with practical decisions, evidence, edge cases, and external source citations. - [UK Online Safety Act Illegal Content Duties Explained Guide](/artifacts/uk/online-safety-act/illegal-content-duties-explained.md): UK Online Safety Act guidance for Illegal Content Duties Explained, with practical decisions, evidence, edge cases, and external source citations. - [UK Online Safety Act Illegal Content Risk Assessment Guide](/artifacts/uk/online-safety-act/illegal-content-risk-assessment.md): UK Online Safety Act guidance for Illegal Content Risk Assessment, with practical decisions, evidence, edge cases, and external source citations. - [UK Online Safety Act Moderation And Appeals Guide](/artifacts/uk/online-safety-act/moderation-and-appeals.md): UK Online Safety Act guidance for Moderation And Appeals, with practical decisions, evidence, edge cases, and external source citations. - [UK Online Safety Act Ofcom Enforcement Guide](/artifacts/uk/online-safety-act/ofcom-enforcement.md): UK Online Safety Act guidance for Ofcom Enforcement, with practical decisions, evidence, edge cases, and external source citations. - [UK Online Safety Act Ofcom enforcement: penalty tiers, investigations, and senior manager liability](/artifacts/uk/online-safety-act/faq/ofcom-enforcement.md): UK Online Safety Act guidance for Ofcom Enforcement, with practical decisions, evidence, edge cases, and external source citations. - [UK Online Safety Act Online Safety Risk Assessment Template Guide](/artifacts/uk/online-safety-act/online-safety-risk-assessment-template.md): UK Online Safety Act guidance for Online Safety Risk Assessment Template, with practical decisions, evidence, edge cases, and external source citations. - [UK Online Safety Act penalties and fines Guide](/artifacts/uk/online-safety-act/penalties-and-fines.md): UK Online Safety Act guidance for penalties and fines, with practical decisions, evidence, edge cases, and external source citations. - [UK Online Safety Act Regulated Service Scope Guide](/artifacts/uk/online-safety-act/regulated-service-scope.md): UK Online Safety Act guidance for Regulated Service Scope, with practical decisions, evidence, edge cases, and external source citations. - [UK Online Safety Act Requirements Guide](/artifacts/uk/online-safety-act/requirements.md): Practical guidance for the UK Online Safety Act requirements, with practical decisions, evidence, edge cases, and external source citations. - [UK Online Safety Act Risk Assessment Workflow Guide](/artifacts/uk/online-safety-act/risk-assessment-workflow.md): UK Online Safety Act guidance for Risk Assessment Workflow, with practical decisions, evidence, edge cases, and external source citations. - [UK Online Safety Act Risk Assessments Playbook Guide](/artifacts/uk/online-safety-act/risk-assessments-playbook.md): UK Online Safety Act guidance for Risk Assessments Playbook, with practical decisions, evidence, edge cases, and external source citations. - [UK Online Safety Act Senior Manager Liability Guide](/artifacts/uk/online-safety-act/senior-manager-liability.md): UK Online Safety Act guidance for Senior Manager Liability, with practical decisions, evidence, edge cases, and external source citations. - [UK Online Safety Act Service Classification Workflow Guide](/artifacts/uk/online-safety-act/service-classification-workflow.md): UK Online Safety Act guidance for Service Classification Workflow, with practical decisions, evidence, edge cases, and external source citations. - [UK Online Safety Act Service Scope and Categorization Guide](/artifacts/uk/online-safety-act/service-scope-and-categorization.md): UK Online Safety Act guidance for Service Scope and Categorization, with practical decisions, evidence, edge cases, and external source citations. - [UK Online Safety Act Transparency Reporting Guide](/artifacts/uk/online-safety-act/transparency-reporting.md): UK Online Safety Act guidance for Transparency Reporting, with practical decisions, evidence, edge cases, and external source citations. - [UK Online Safety Act User-to-user And Search Services Guide](/artifacts/uk/online-safety-act/user-to-user-and-search-services.md): UK Online Safety Act guidance for User-to-user And Search Services, with practical decisions, evidence, edge cases, and external source citations. - [UK Online Safety Act vs Dsa Guide](/artifacts/uk/online-safety-act/online-safety-act-vs-dsa.md): UK Online Safety Act guidance for Online Safety Act vs Dsa, with practical decisions, evidence, edge cases, and external source citations. - [What should teams do about Age Assurance under the UK Online Safety Act?](/artifacts/uk/online-safety-act/faq/age-assurance.md): UK Online Safety Act guidance for Age Assurance, with practical decisions, evidence, edge cases, and external source citations. - [What should teams do about Categorisation under the UK Online Safety Act?](/artifacts/uk/online-safety-act/faq/categorisation.md): UK Online Safety Act guidance for Categorisation, with practical decisions, evidence, edge cases, and external source citations. - [What should teams do about Children's Access Assessment under the UK Online Safety Act?](/artifacts/uk/online-safety-act/faq/children-s-access-assessment.md): UK Online Safety Act guidance for Children's Access Assessment, with practical decisions, evidence, edge cases, and external source citations. - [What should teams do about Ico Overlap under the UK Online Safety Act?](/artifacts/uk/online-safety-act/faq/ico-overlap.md): UK Online Safety Act guidance for Ico Overlap, with practical decisions, evidence, edge cases, and external source citations. - [What should teams do about Moderation And Appeals under the UK Online Safety Act?](/artifacts/uk/online-safety-act/faq/moderation-and-appeals.md): UK Online Safety Act guidance for Moderation And Appeals, with practical decisions, evidence, edge cases, and external source citations. - [What should teams do about Senior Manager Liability under the UK Online Safety Act?](/artifacts/uk/online-safety-act/faq/senior-manager-liability.md): UK Online Safety Act guidance for Senior Manager Liability, with practical decisions, evidence, edge cases, and external source citations. - [What should teams do about Transparency Reporting under the UK Online Safety Act?](/artifacts/uk/online-safety-act/faq/transparency-reporting.md): UK Online Safety Act guidance for Transparency Reporting, with practical decisions, evidence, edge cases, and external source citations. - [What should teams do about User-to-user And Search Services under the UK Online Safety Act?](/artifacts/uk/online-safety-act/faq/user-to-user-and-search-services.md): UK Online Safety Act guidance for User-to-user And Search Services, with practical decisions, evidence, edge cases, and external source citations. *Recommended next step* *Placement: after the practical guidance* ## Turn UK Online Safety Act Illegal Content Risk Assessment into assigned work Use this UK Online Safety Act guide to turn Illegal Content Risk Assessment into owners, evidence requests, review checkpoints, and reusable operating records inside Sorena. - [Open Assessment Autopilot for UK Online Safety Act](/solutions/assessment.md): Turn Illegal Content Risk Assessment into scoped questions, evidence fields, and review tasks. - [Review UK Online Safety Act source evidence](/solutions/research-copilot.md): Use Research Copilot to answer follow-up questions with cited source material. - [Talk through implementation](/contact.md): Review scope, evidence, owners, and the next compliance actions with Sorena. --- [Privacy Policy](https://www.sorena.io/privacy) | [Terms of Use](https://www.sorena.io/terms-of-use) | [DMCA](https://www.sorena.io/dmca) | [About Us](https://www.sorena.io/about-us) (c) 2026 Sorena AB (559573-7338). 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