UK Online Safety Act Online Safety Risk Assessment Template
Use this template to record the assessment boundary, evidence, risk pathway, affected users, design contribution, controls, residual risk, and accountable approval.
It is a working record, not an official Ofcom form. Adapt it to the separate illegal-content or children's risk-assessment duty that applies.
Use one controlled record for each applicable Part 3 Online Safety Act risk assessment. The template is a Sorena working aid, not an Ofcom form. It records the service boundary, statutory assessment type, evidence, risk pathways, current controls, residual risk, accountable approval, and review triggers so a later reviewer can reconstruct the decision.
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Section 1
How should an Online Safety Act risk assessment template be used?
Use a separate controlled record for each illegal-content or children's risk assessment and keep the identifiable as its own decision. Existing services had first-assessment deadlines of 16 March 2025 for illegal content, 16 April 2025 for children's access, and 24 July 2025 for children's risk where triggered. For a new or newly in-scope service, record the applicable three-month period; for a significant change, approve the relevant assessment before release.
For each material risk, record the content or harm kind separately, the encounter or dissemination pathway, affected users and characteristics, likelihood evidence, severity evidence, service-design contribution, existing controls, control test, residual risk, in-force Ofcom code measure or documented effective alternative, action, owner, deadline, and monitoring trigger. For illegal-content assessments, include each priority-illegal-content kind, other illegal content, and, for user-to-user services, commission or facilitation of priority offences.
The evidence index should state the source system, date range, query or test method, version, limitations, retention location, and the conclusion supported. A score without a written rationale and retrievable evidence does not let a later reviewer reconstruct the decision.
Finish with unresolved assumptions, rejected controls and reasons, dependencies, interim restrictions, approval conditions, any required public summary, and event-driven review triggers. Planned work is an action, not an operating control.
Header: provider, service, assessment type, statutory provision, version, preparer, reviewers, accountable approver, launch or change date, and linked .
Service evidence: functions, user journeys, recommendation and search systems, messaging, business model, user numbers, child-user evidence, complaints, reports, prevalence, reach, and data gaps.
Risk record: inherent risk, control design, operating evidence, residual risk, code comparison, action, owner, due date, and acceptance decision.
Review record: significant-change decision, accuracy concerns, monitoring threshold, Ofcom's recommended review at least every 12 months, event-driven trigger, and revision history.
ICO source for age-assurance and data-protection fields in the Online Safety risk assessment template. ICO opinion on age assurance for the Children’s Code and proportionate implementation.
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Section 2
Which fields belong in each record?
Keep each field decision-relevant. Service facts establish scope; evidence fields establish what is known; risk rows show the statutory analysis; control rows show what operates now; action rows show work still due; approval and review fields show who accepted the result and when it must be reopened.
Service scope: legal entity, service boundary, UK link, functions, exemptions, users, and children's-access result.
Risk evidence: content or harm kind, pathway, affected group, metric or qualitative evidence, date range, method, limitation, and confidence.
Control evidence: design, operating owner, deployment coverage, test method, result, dependency, and failure mode.
Decision record: residual risk, action, due date, interim control, approver, acceptance reason, monitoring threshold, and review trigger.
ICO source for age-assurance and data-protection fields in the Online Safety risk assessment template. ICO opinion on age assurance for the Children’s Code and proportionate implementation.
ICO review source for child-privacy observations that can inform template review and improvement fields.
Children's code
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Section 3
When should the template or assessment change?
Review the template when a completed assessment cannot be reproduced, a required statutory factor has nowhere to be recorded, actions are mistaken for operating controls, or reviewers cannot tell which evidence supports a conclusion. Reopen the assessment itself whenever the applicable accuracy or significant-change trigger is met.
Sample records and trace each material conclusion to evidence and each mitigation to an operating test.
Require data limitations and unresolved assumptions to remain visible at approval.
Remove fields that never affect a decision and add fields only for a demonstrated evidence or ownership gap.
Keep a revision history when the service, evidence, scoring rationale, control, or acceptance decision changes.
ICO source for age-assurance and data-protection fields in the Online Safety risk assessment template. ICO opinion on age assurance for the Children’s Code and proportionate implementation.
ICO source for age-assurance and data-protection fields in the Online Safety risk assessment template. ICO opinion on age assurance for the Children’s Code and proportionate implementation.