UK Online Safety Act Regulated Service Scope

A Part 3 user-to-user service is an internet service through which content generated, uploaded, or shared by one user may be encountered by another user. A Part 3 search service is an internet service that is, or includes, a search engine. A combined service can contain both parts, and each part may have different duties.

Part 5 separately covers an internet service on which the provider publishes or displays regulated provider pornographic content. A service may therefore be outside the Part 3 user-to-user and search definitions but still have Part 5 duties.

The provider's location is not decisive. A service has UK links if it has a significant number of UK users, targets the UK market, or is capable of UK use and there are reasonable grounds to believe that UK users face a material risk of significant harm from content on or accessible through it.

Schedule 1 exempts specified services or parts of services, including email, SMS and MMS, one-to-one live aural communications, limited functionality, certain internal business services, and services provided by public bodies or qualifying education and childcare providers. Each exemption has conditions. An exempt function does not automatically exempt the rest of a combined product.

Comments and reviews on provider content can fall within the limited-functionality exemption only if the statutory conditions are met. File storage, group messaging, forums, dating, gaming, social media, and content-sharing features can be user-to-user services even when interaction is not the product's main purpose. Apply the definitions to the actual journey rather than the marketing label.

For the limited-functionality exemption, users must be able to communicate only through comments or reviews on provider content, sharing those comments or reviews on another service, reactions such as likes, emojis, votes or ratings, and identifying content connected with those activities. User-generated content is not provider content for this test. Schedule 1 paragraph 6 also removes the paragraphs 1–5 exemptions where regulated provider pornographic content is published or displayed and the section 80(4) UK-links test is met.

The scope record should be short enough to review but detailed enough to reproduce the decision. Include a service map, the relevant statutory definition, UK-links evidence, every exemption considered, the provider entity, and the product owner. State any assumptions and the event that will trigger reassessment.

Scope is only the gateway. If a Part 3 service is regulated, the provider must address illegal-content duties and complete a children's access assessment. Categorisation, transparency reporting, and some additional duties are later questions; a service can be regulated without appearing on Ofcom's categorised-services register.