UK Online Safety Act Senior Manager Liability

Senior Manager Liability is the part of the Act that can make a named senior manager personally relevant to enforcement for certain information offences. In practice, teams should confirm whether the service is in scope, which duty or notice applies, and whether the responsible manager has the authority and oversight to respond.

Start by deciding whether the service is in scope and which illegal-content, children-safety, age-assurance, user-empowerment, transparency, complaints, risk-assessment, or Ofcom enforcement duty is triggered. The answer should name the exact trigger, affected product or process, required action, owner, evidence, and escalation point.

Keep the Online Safety Act source, service-scope decision, user-to-user/search feature map, risk assessment, code-of-practice mapping, age-assurance evidence, and Ofcom-facing record together.

Ownership should sit with the team that can change service design, moderation, recommender systems, age assurance, reporting, complaints, terms, or transparency data, with legal and trust-safety review.

Evidence should show service categorisation, illegal-content risk assessment, children access assessment, children risk assessment, mitigation controls, age-assurance decisions, terms/complaints records, and Ofcom reporting readiness.

Most Online Safety Act mistakes happen at the boundary between user-to-user, search, pornography, category, child-access, illegal-content, and transparency duties.

Use this section before launching a user feature, recommender change, moderation change, age-assurance flow, complaint process, or transparency-reporting process.

Use an Online Safety Act workflow that captures service scope, user groups, risk assessment, code mapping, child-access status, mitigation owner, evidence, and Ofcom escalation path.

The output should be a service-scope memo, risk assessment, children access assessment, mitigation plan, age-assurance decision, complaint workflow, or transparency-report evidence pack.