The Online Safety Act: What Digital Providers Must Do to Stay Compliant in 2025

The Online Safety Act (OSA) establishes a broad regulatory framework for providers of user-to-user services and search services with links to the UK. Service providers that fail to comply with the OSA face serious financial and legal consequences. Notably, Ofcom has the authority to impose fines of up to £18 million or 10% of global revenue, making non-compliance a significant risk for digital businesses.

A key milestone arrived on 17 March 2025, requiring service providers in scope to implement safety measures against illegal content and activities in line with Ofcom’s illegal content Codes of Practice.[1] Illegal content and activities include (amongst others) sexual exploitation and abuse of children and adults, harassment and stalking, animal cruelty, terrorism, and fraud and financial offences.[2]

Looking ahead, by 16 April 2025, all relevant user-to-user and search services – defined as ‘Part 3’ services (which includes those with user-generated content such as social media sites) – must carry out a children’s access assessment to determine whether their service, or parts of it, are likely to be accessed by children (in line with Ofcom’s guidance[3]). If a service provider’s completed children’s access assessment determines that its service is likely to be accessed by children, or if a children’s access assessment is not completed, then children safety duties will apply to the service. The children safety duties require platforms to conduct a separate children’s risk assessment and to put measures in place to protect children from harmful content.

Ofcom is finalising its Protection of Children Codes and risk assessment guidance which will outline recommended compliance measures. These are expected to be published in April 2025, with children’s risk assessments due from July 2025.[4]

[1] https://www.ofcom.org.uk/online-safety/illegal-and-harmful-content/codes-of-practice/

[2] https://www.ofcom.org.uk/online-safety/illegal-and-harmful-content/guide-for-services/

[3] https://www.ofcom.org.uk/online-safety/protecting-children/statement-age-assurance-and-childrens-access/

[4] https://www.ofcom.org.uk/online-safety/protecting-children/age-checks-to-protect-children-online/#:~:text=We%20will%20publish%20our%20Protection,that%20is%2C%20within%20three%20months