Scope GuideCategories and Duty Layers

Service Scope and Categorization

Do not mix baseline duties with categorised service duties.

The first question is whether the service is a regulated Part 3 service. The second is whether it later enters Category 1, 2A, or 2B.

Author
Sorena AI
Published
Feb 21, 2026
Updated
Feb 21, 2026
Sections
3

Structured answer sets in this page tree.

Primary sources
3

Cited legal and guidance references.

Publication metadata
Sorena AI
Published Feb 21, 2026
Updated Feb 21, 2026
Overview

UK OSA work gets cleaner when you split it into layers. Layer one is basic Part 3 coverage for regulated user-to-user and search services. Layer two is whether the service is likely to be accessed by children. Layer three is whether the service becomes a categorised service with extra transparency, accountability, or user empowerment duties.

Section 1

Treat categorisation as an overlay, not the starting point

The Act imposes base duties on in-scope services before category-specific duties arrive. Many teams lose time by jumping straight to Category 1 debates instead of finishing the base illegal-content and child-safety analysis.

Keep the base duties live even if the service is not yet on an Ofcom register.

  • Complete baseline Part 3 scope analysis first
  • Track category signals separately in governance reporting
  • Avoid delaying core controls while waiting for category confirmation
Section 2

Use the live implementation sequence

The government states that the threshold regulations for Category 1, 2A, and 2B were laid on 16 December 2024. Ofcom expected to publish the register of categorised services in summer 2025 and to consult on additional duties from early 2026.

That means teams should plan for category exposure before formal listing if the service is near threshold or strategically likely to be included.

  • Track user scale, functionality, and other threshold related characteristics
  • Prepare for annual transparency reporting if category exposure is realistic
  • Pre-build terms, complaints, and internal metrics needed for extra duties
Section 3

Watch the categories that change operational design

Category 1 services carry the most visible extra user empowerment and terms of service duties. Category 2A covers major search services and Category 2B covers other categorised user-to-user services.

The right preparation is not only legal analysis. It is building reporting, metrics, user controls, and complaints data in a way that can scale into the category regime.

  • Category 1: terms enforcement consistency and adult user control tooling
  • Category 2A and 2B: transparency and accountability planning
  • All categories: clean metrics definitions before reporting is mandated
Recommended next step

Use Service Scope and Categorization as a cited research workflow

Research Copilot can take Service Scope and Categorization from clarifying scope and applicability with cited answers to a reusable workflow inside Sorena. Teams working on Service Scope can keep owners, evidence, and next steps aligned without copying this guide into separate documents.

Primary sources

References and citations

legislation.gov.uk
Referenced sections
  • Primary legislation for scope, duties, risk assessment, enforcement, transparency, and complaints provisions.
gov.uk
Referenced sections
  • Current government implementation status, deadlines, and plain language explanation of the regime.
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