As of 25 July 2025, new child safety duties under the Online Safety Act have come into force, requiring online platforms to implement robust safety measures to prevent children from accessing illegal or harmful content. The consequences for non-compliance are significant, making it essential for online providers to understand their new obligations.
The rollout of the Online Safety Act has been underway for several months. Initially, platforms were required to assess and mitigate the risk of users encountering illegal content. Now, the focus has shifted to age assurance.
Following the publication of the Children’s Safety Codes of Practice, platforms had three months to conduct a Child Access Assessment to determine whether their services were likely to be accessed by children. In practice, most platforms are likely accessible to children, so many providers were then required to complete a “suitable and sufficient” risk assessment and implement appropriate safety measures—particularly around age verification.
Who Is Affected?
Since January 2025, platforms that publish their own pornographic content, including generative AI tools (for example, adult websites) had to ensure that children, under 18, were not able to encounter pornographic content, through the implementation of “highly effective” age checks. Ofcom opened an enforcement programme into age assurance measures across the adult sector to ensure these platforms were complying with their duties.
From 25 July 2025, all websites that allow user-to-user generated pornographic content to be shared, which will include social media platforms, are required to implement age checks.
How Should Platforms Comply?
Previously, users could simply tick a box to confirm they were over 18, even on pornographic websites – this is no longer acceptable. While Ofcom has not mandated specific technologies, it has outlined examples of acceptable age verification methods, including:
- Credit card checks
- Digital identity services
- Facial age estimation
Several companies have already publicly stated that they will be ensuring compliance with these new obligations. For example, Pornhub has announced it will introduce enhanced age checks, and X (formerly Twitter) plans to use AI-powered facial age estimation to verify users’ ages.
What Are the Risks of Non-Compliance?
Ofcom has significantly ramped up its enforcement efforts, launching multiple investigations into websites that have failed to comply with both the new child safety duties and earlier illegal content regulations. Following the introduction of the Illegal Content Codes and the Children’s Safety Codes of Practice—particularly as they apply to Part 5 service providers—Ofcom moved swiftly to identify non-compliant platforms. While some investigations have since concluded, several remain ongoing, signalling Ofcom’s firm and proactive approach to ensuring compliance with the Online Safety Act.
While enforcement involves several steps, ultimately Ofcom can impose fines of up to £18 million or 10% of global revenue, whichever is greater. In addition, the regulator’s jurisdiction is broad: any service accessible in the UK—regardless of where it is based—must comply if it targets or is used by UK users.
What’s Next?
The introduction of the new child safety duties under the Online Safety Act marks a pivotal moment in the UK’s approach to online regulation. As platforms adapt to these sweeping changes, the emphasis is now firmly on proactive compliance, transparency, and accountability. While the regulatory landscape continues to evolve, one thing is clear: the era of minimal safeguards and passive moderation is over.
Online providers must now strike a careful balance—implementing robust protections for children without compromising user privacy or accessibility. With Ofcom’s enforcement powers expanding and further guidance on the horizon, the coming months will be critical in shaping how these duties are interpreted and enforced in practice. For tech companies, the message is clear: act now, or face serious consequences.
About the author
Alice Trotter is an Associate in the Criminal Litigation team. Alice’s practice includes all areas of criminal litigation, with particular expertise in Online Safety, serious and general crime, and white-collar crime. She represents individuals and corporate clients from the initial stages of an investigation through to trial.
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