Artifact GuideUKRequirements

UK Online Safety Act Requirements

This page summarizes the UK Online Safety Act requirements in plain English: in-scope services must reduce illegal content risks, protect children from harmful and age-inappropriate content, give adults more control on Category 1 services, provide reporting and complaints routes, and meet Ofcom's record-keeping and enforcement expectations.

Requirements depend on the regulated service part, child-access result, content and risk, provider-pornography status, formal category, and current Ofcom instruments.

Author
Sorena AI
Published
May 9, 2026
Updated
Oct 15, 2026
Overview

Start by identifying the service and its regulated parts. All regulated Part 3 user-to-user and search services have illegal-content, children's access assessment, reporting, complaints, privacy, freedom-of-expression, record, and review duties. Child-accessible services, provider-pornography services, and formally categorised services have additional requirements.

Section 1

Which duty sets apply to each service part?

For every regulated Part 3 service, complete and keep up to date an illegal-content risk assessment, implement proportionate safety systems and processes for the applicable user-to-user or search duties, provide content-reporting and complaints procedures, address freedom of expression and privacy, and keep the records required by sections 23 or 34.

Every Part 3 service must also complete a children's access assessment. If children are likely to access the service or a part of it, complete a separate children's risk assessment, implement the applicable protection-of-children duties, keep the assessment current, and record the measures and reviews.

A service with UK links that publishes or displays provider pornographic content falls under Part 5 and must use age verification or age estimation that meets the Act's effectiveness standard so children are not normally able to encounter that content. User-uploaded pornography on a Part 3 service must be analysed under the relevant Part 3 child-safety duties.

Formal categorisation adds requirements. Category 1 duties include user empowerment, identity verification, protections and procedures for specified content, terms, complaints, and assessments. Category 1 and 2A services have fraudulent-advertising and specified risk-record duties; Category 1, 2A, and 2B services can have transparency-reporting duties. Fee duties use a separate qualifying-worldwide-revenue threshold and exemptions. Confirm the current commencement, notice, and code for each deliverable.

  • Map each duty to the user-to-user part, search engine, provider-pornography service, child-accessible part, or registered category.
  • Treat as a statutory compliance route; record the rationale and evidence for any alternative measure.
  • Attach one accountable owner, control evidence, review trigger, and current source to every duty.
  • Separate binding law and issued codes from guidance, consultations, and draft additional-duty proposals.
Section 2

Who owns the duties, and what evidence is needed?

The provider should assign one accountable executive or senior owner for the service-level program and named operational owners for scope, risk assessments, moderation, search, recommender systems, age assurance, reporting, complaints, terms, privacy, records, and regulator responses.

The evidence set should show the approved service boundary, assessments, risk-to-control mapping, code or alternative-measure rationale, implementation and testing, terms and user journeys, complaints outcomes, review dates, incidents, and any information supplied to Ofcom.

  • Keep separate records for the illegal-content and children's risk assessments even where they share evidence.
  • Use the same service boundary in the scope memo, risk records, category analysis, terms, and Ofcom responses.
  • Record why each control is proportionate to the risk, service size, capacity, design, and user base.
  • Reopen the duty map after a significant product change, new risk evidence, category entry, Ofcom notice, or updated issued code.
Section 3

Which service distinctions change the duty map?

The most common mapping error is applying the right topic to the wrong service part. User-to-user and search duties use different statutory language, and provider pornographic content has a separate Part 5 regime.

Another error is treating categorisation as the start of compliance. Core Part 3 duties apply to regulated services whether or not Ofcom places them in Category 1, 2A, or 2B.

  • Do not assume all child-safety duties require the same age-assurance method; select controls from the risk and the exact statutory or code measure.
  • Do not assume compliance with an Ofcom code resolves UK GDPR, equality, consumer, intellectual-property, or other legal duties.
  • Do not treat an Ofcom template as mandatory wording unless the source says it is; the provider remains responsible for an accurate, complete record.
  • Escalate service-boundary, illegal-content, age-assurance, and category questions that cannot be resolved from documented facts.
Section 4

How should teams implement and maintain the requirements?

Build the requirements register in order: scope; illegal-content assessment; core safety, reporting, complaints, privacy, and record duties; children's access; child-safety duties; provider pornography; formal category; and any Ofcom notice or information request.

Existing-service deadlines in 2025 have passed. New or changed services must use the Act and Ofcom guidance's event-based timing, including assessment before significant changes and the applicable three-month periods after a service or duty comes into scope.

  • Use the checklist page to verify deliverables only after this duty map identifies what applies.
  • Track completed historic milestones separately from ongoing review, complaint, record, and control duties.
  • For a registered Category 1 or 2A service, capture Ofcom's current expectation to provide updated illegal-content risk-assessment records by October 2026.
  • Review the current Ofcom regulatory-documents page before relying on a code or guidance version.
Primary sources

References and citations

legislation.gov.uk3 citations
Referenced sections
  • Primary source for the complete duty framework and service-specific legal conditions.
  • Primary legislation for Part 3, Part 5, categorised-service, Ofcom, record, information, and enforcement requirements.
  • Binding distinctions among service types, duties, content, child access, provider pornography, and categories.
ofcom.org.uk2 citations
Referenced sections
  • Current issued codes, risk and access guidance, content guidance, and record-keeping guidance.
  • Current issued codes and guidance for illegal-content, child-safety, assessment, content-judgement, and record duties.
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