--- title: "UK Online Safety Act Illegal Content Duties" canonical_url: "https://www.sorena.io/artifacts/uk/online-safety-act/illegal-content-duties-explained" source_url: "https://www.sorena.io/artifacts/uk/online-safety-act/illegal-content-duties-explained" author: "Sorena AI" description: "Grounded guide to UK Online Safety Act illegal content duties covering user-to-user and search services, illegal content risk assessments." published_at: "2026-02-21" updated_at: "2026-02-21" keywords: - "UK Online Safety Act illegal content duties" - "illegal content risk assessment" - "priority offences online safety act" - "Ofcom illegal harms" - "illegal content duties" - "priority offences" --- **[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) --- # UK Online Safety Act Illegal Content Duties Grounded guide to UK Online Safety Act illegal content duties covering user-to-user and search services, illegal content risk assessments. *Duty Guide* *Illegal Content* ## Illegal Content Duties Explained Illegal content duties are already in force and Ofcom can enforce them. Treat the illegal content risk assessment as the control design baseline for moderation, detection, escalation, and law enforcement cooperation. All in-scope user-to-user and search services need systems and processes to reduce the risk that their services are used for illegal activity and to take down illegal content when it appears. The government implementation materials state that the illegal risk assessment deadline was 16 March 2025 and that Ofcom could enforce the regime from 17 March 2025. ## Build around the illegal content risk assessment The assessment is not a policy summary. It should identify the illegal content and illegal activity risks created by service features, user behavior, recommendation logic, reporting paths, and abuse vectors. Controls should map directly to the risk scenarios the assessment identifies. - Document risk by feature, user group, and abuse pathway - Separate baseline detection, response, and escalation controls - Tie each risk to a named owner and review frequency ## Prioritise the priority offences and serious harm vectors Government materials highlight priority offences and high harm areas such as fraud, extreme pornography, harassment, stalking, and public order offences. Small but risky services remain a stated enforcement priority even where the service is not large. The right control set for a suicide forum, a general social platform, and a search service will not look the same. - Focus proactive measures on the most serious and prevalent risks for the service - Document where the service must act before a user report arrives - Review whether recommendation, ranking, or search design increases exposure ## Use March 2025 as the live baseline, not a future aspiration The illegal harms codes were approved after being laid on 16 December 2024, and Ofcom published risk assessment guidance and its policy statement on the same day. That means services should now be operating inside a live regime, not a draft one. Evidence should therefore show not only policy intent but actual execution since the March 2025 deadline. - Keep dated copies of risk assessments and post-assessment updates - Retain moderation metrics and enforcement QA from the live period - Capture changes made after the policy statement and code approval *Recommended next step* *Placement: near the end of the main content before related guides* ## Use Illegal Content Duties Explained as a cited research workflow Research Copilot can take Illegal Content Duties Explained from getting cited answers and faster research on this topic to a reusable workflow inside Sorena. Teams working on Illegal Content can keep owners, evidence, and next steps aligned without copying this guide into separate documents. - [Open Research Copilot for Illegal Content Duties Explained](/solutions/research-copilot.md): Start from Illegal Content Duties Explained and answer scope, timing, and interpretation questions with cited outputs. - [Talk through Illegal Content](/contact.md): Review your current process, evidence gaps, and next steps for Illegal Content Duties Explained. ## Primary sources - [Online Safety Act 2023](https://www.legislation.gov.uk/ukpga/2023/50/contents?ref=sorena.io) - Primary legislation for scope, duties, risk assessment, enforcement, transparency, and complaints provisions. - [Online Safety Act explainer](https://www.gov.uk/government/publications/online-safety-act-explainer/online-safety-act-explainer?ref=sorena.io) - Current government implementation status, deadlines, and plain language explanation of the regime. - [Statement of Strategic Priorities for Online Safety](https://www.gov.uk/government/publications/statement-of-strategic-priorities-for-online-safety?ref=sorena.io) - July 2025 strategic priorities for Ofcom, including safety by design, age assurance, and small but risky services. ## Related Topic Guides - [UK Online Safety Act Age Assurance Options | Age Estimation, Verification, and Child Access Controls](/artifacts/uk/online-safety-act/age-assurance-options.md): Grounded age assurance guide for the UK Online Safety Act covering January 2025 pornography guidance, highly effective age assurance. - [UK Online Safety Act Applicability Test | Regulated Service, Exemptions, and UK Scope](/artifacts/uk/online-safety-act/applicability-test.md): Grounded UK Online Safety Act applicability test covering regulated user-to-user and search services, Schedule 1 exemptions, provider pornography scope. - [UK Online Safety Act Checklist | Scope, Risk, Child Safety, Moderation, and Evidence](/artifacts/uk/online-safety-act/checklist.md): Audit-ready UK Online Safety Act checklist covering service scope, illegal risk assessment, child access and child risk assessment, moderation, complaints. - [UK Online Safety Act Children Safety Duties | Child Access, Child Risk, and Age Assurance](/artifacts/uk/online-safety-act/children-safety-duties.md): Grounded guide to UK Online Safety Act children safety duties covering section 81 timing, children access assessments, children risk assessments. - [UK Online Safety Act Compliance Program | Governance, Controls, and Ofcom Readiness](/artifacts/uk/online-safety-act/compliance.md): Program design guide for UK Online Safety Act compliance covering governance, scope, assessments, moderation, age assurance, complaints, metrics. - [UK Online Safety Act Content Moderation and Appeals | Complaints, Terms Enforcement, and Redress](/artifacts/uk/online-safety-act/content-moderation-and-appeals.md): Grounded guide to UK Online Safety Act moderation and appeals requirements covering sections 21, 32, 71, and 72, complaints design, terms enforcement. - [UK Online Safety Act Deadlines and Compliance Calendar | 2023 to 2026 Milestones](/artifacts/uk/online-safety-act/deadlines-and-compliance-calendar.md): Grounded UK Online Safety Act calendar covering 26 October 2023 enactment, 31 January 2024 offences, 16 December 2024 illegal harms codes. - [UK Online Safety Act Enforcement and Penalties | Ofcom Notices, Penalties, and Escalation](/artifacts/uk/online-safety-act/enforcement-and-penalties.md): Grounded UK Online Safety Act enforcement guide covering Ofcom information notices, senior manager naming, confirmation decisions. - [UK Online Safety Act FAQ | Scope, Child Duties, Categories, and Ofcom Enforcement](/artifacts/uk/online-safety-act/faq.md): Practical FAQ on the UK Online Safety Act covering who is in scope, what changed in 2025, child access and risk assessments, age assurance, category duties. - [UK Online Safety Act Penalties and Fines | GBP 18 Million, 10 Percent Revenue, and Liability](/artifacts/uk/online-safety-act/penalties-and-fines.md): Grounded penalty guide for the UK Online Safety Act covering the GBP 18 million or 10 percent worldwide revenue cap. - [UK Online Safety Act Requirements | Sections, Deadlines, Controls, and Evidence](/artifacts/uk/online-safety-act/requirements.md): Detailed UK Online Safety Act requirements guide mapping scope, illegal content duties, child safety duties, terms enforcement, complaints, categorisation. - [UK Online Safety Act Risk Assessment Template | Illegal Content and Child Safety Template](/artifacts/uk/online-safety-act/online-safety-risk-assessment-template.md): Practical UK Online Safety Act risk assessment template covering service profile, harms inventory, controls, residual risk, child access, child safety. - [UK Online Safety Act Risk Assessments Playbook | How to Run Illegal and Children Risk Reviews](/artifacts/uk/online-safety-act/risk-assessments-playbook.md): Operational playbook for UK Online Safety Act risk assessments covering sequencing, ownership, evidence collection, control design. - [UK Online Safety Act Service Scope and Categorization | Category 1, 2A, 2B, and Part 3 Logic](/artifacts/uk/online-safety-act/service-scope-and-categorization.md): Grounded service scope and categorisation guide for the UK Online Safety Act covering Part 3 logic, likely to be accessed by children, Category 1, 2A. - [UK Online Safety Act vs EU Digital Services Act | Scope, Child Safety, and Enforcement Differences](/artifacts/uk/online-safety-act/online-safety-act-vs-dsa.md): Practical comparison of the UK Online Safety Act and the EU Digital Services Act covering regulated service models, illegal content frameworks. --- [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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