Online Safety Act Implementation: What’s Changing and What’s Next
As new age assurance rules take effect this week, techUK looks at what’s changing now – and what’s still to come under the Online Safety Act.
This week marks a major moment for Online Safety Act implementation, as the 25 July 2025 deadline approaches for companies in scope to comply with Ofcom’s child safety duties.
User-to-user services – that are considered likely to be accessed by children – must now take steps to prevent young users from encountering certain types of harmful material. This includes preventing access to “primary priority”content, such as pornography and content promoting suicide or self-harm, and reducing exposure to other “priority” harms.
To meet these new responsibilities, some services will need to implement “highly effective” age assurance measures. The implementation of these rules represents one of the most significant steps towards full rollout of the Online Safety Act.
Passed in October 2023, the Online Safety Act is one of the UK’s most wide-ranging digital laws. It introduces new legal duties for online services, aimed at reducing harm to users, particularly children. These include requirements to tackle illegal content, introduce safety-by-design features, and operate with greater transparency and accountability.
Ofcom, the UK’s online safety regulator, is responsible for enforcing the Act. Since late 2023, it has been working through a phased implementation plan - engaging with stakeholders and publishing guidance to help services understand their responsibilities.
So far, the rollout has been structured around three main phases:
Phase 1: Tackling illegal content
Phase 2: Content harmful to children
Phase 3: Duties for categorised services
Each phase brings its own guidance, codes of practice, and compliance timelines. Implementation will continue into early 2026, with further duties - especially for larger platforms — expected over the next 12 to 18 months.
This week’s deadline marks a critical shift from planning to delivery - as age checks become a legal expectation, and the next stage of the Act comes into force.
What’s changing in July 2025?
From 25 July 2025, Ofcom’s Protection of Children Codes of Practice will come into effect - a major milestone in the rollout of the Online Safety Act. These Codes introduce binding duties for online services that are likely to be accessed by children, with the aim of reducing children’s exposure to harmful content and requiring stronger safety systems by default.
The Codes apply to both user-to-user and search services and were finalised by Ofcom in early July, following Parliamentary approval. From this point on, services in scope must either follow the detailed safety measures set out in the Codes, or demonstrate that they are applying equally effective alternative approaches.
Foruser-to-user services, duties focus on proportionate and effective measures to:
Prevent children from encountering the most harmful content - such as pornography, self-harm, suicide, or eating disorder material - using highly effective age assurance..
Protect children from a wider range of harmful material, including bullying, hate content, violent imagery, and dangerous challenges (priority content), as well as other content that poses a material risk of harm (non-designated content).
Mitigate both the risks and the potential impact of exposure to harmful content, using insights from a service’s children’s risk assessment.
Set out safety measures clearly in terms of service, and maintain accessible reporting and complaints mechanisms.
For search services, the duties are similar in scope but tailored to search functionality. They include:
Minimising the risk of children being exposed to harmful results - particularly the most high-risk content
Managing risks for different age groups based on the outcome of a children’s risk assessment
Publishing a publicly available statement on how these duties are being met
Providing clear routes to report harmful content and raise complaints
These new requirements are part of Phase 2 of Ofcom’s implementation roadmap. Earlier this year, services were expected to complete children’s access assessments and children’s risk assessments between April and July to inform their approach to compliance.
From this point onwards, Ofcom will be able to enforce compliance. This includes the power to impose fines or take action against services that fail to meet their safety duties.
Expected – July 2025
Ofcom is expected to publish the Register of Categorised Services, formally designating which online services fall under specific regulatory categories within the Act. Categorised services are likely to face additional duties and will have the opportunity to respond to consultations before these requirements come into force.
Deadline: 20 October 2025 Consultation on Additional Safety Measures, expected to close on 20 October, sets out proposed requirements for categorised services – including content moderation systems, governance standards, and systemic risk controls.
Expected – August to November 2025
Ofcom is expected to begin issuing draft and final transparencynotices to categorised services. These notices will outline specific reporting obligations, including how services assess risks, apply safety measures, and prepare to publish annual transparency reports from 2026.
Expected – Q4 2025
The Secretary of State for Science, Innovation and Technology is expected to lay regulations before Parliament to set the Qualifying Worldwide Revenue (QWR) threshold. Providers whose global turnover exceeds the threshold (anticipated to be £250 million) will be required to notify Ofcom and pay annual regulatory fees.
Expected – October 2025 to March 2026
Ofcom is expected to open a consultation on further duties for categorised services, covering proposals on systemic risk management, governance obligations, and other long-term regulatory measures. While responding will be voluntary, this will be a key opportunity for industry to help shape the future of the regime.
Expected – 31 December 2025
The super-complaints regime is expected to come into force. This new mechanism will allow designated organisations to escalate systemic issues—such as repeated failures by a service to uphold safety duties—directly to Ofcom. It aims to strengthen the role of civil society and ensure that widespread or unresolved harms are addressed more effectively.
Preparing for the online safety fees regime
Another key element of implementation is the introduction of a fees and penalties regime, enabling Ofcom to recover the costs of delivering its online safety duties.
On 26 June 2025, Ofcom published its final policy statement confirming that regulated providers will need to pay annual fees if their Qualifying Worldwide Revenue (QWR) exceeds £250 million. However, providers with less than £10 million in UK-derived revenue will be exempt from fees, even if they exceed the global threshold.
The QWR model is designed to ensure proportionality and is expected to be backed by secondary legislation in late 2025, when the Secretary of State for Science, Innovation and Technology lays the regulations before Parliament. Ofcom is due to publish further guidance on calculating QWR later this year.
By October 2025, the fees regime comes into force, and in-scope providers should notify Ofcom of their liability. This will mark another shift toward embedding the long-term operational framework of the OSA.
Get in touch
techUK is working with members on the ongoing implementation of the Online Safety Act. For any questions, or to get involved in our online safety work, please contact [email protected], or reach out to the team below.
Samiah Anderson
Head of Digital Regulation, techUK
Samiah Anderson
Head of Digital Regulation, techUK
Samiah Anderson is the Head of Digital Regulation at techUK.
With over six years of Government Affairs expertise, Samiah has built a solid reputation as a tech policy specialist, engaging regularly with UK Government Ministers, senior civil servants and UK Parliamentarians.
Before joining techUK, Samiah led several public affairs functions for international tech firms and coalitions at Burson Global (formerly Hill & Knowlton), delivering CEO-level strategic counsel on political, legislative, and regulatory issues in the UK, EU, US, China, India, and Japan. She is adept at mobilising multinational companies and industry associations, focusing on cross-cutting digital regulatory issues such as competition, artificial intelligence, and more.
She holds a BA (Hons) in Politics, Philosophy, and Economics from the University of London, where she founded the New School Economics Society, the Goldsmiths University chapter of Rethinking Economics.
Audre joined techUK in July 2023 as a Policy Manager for Data. Previously, she was a Policy Advisor in the Civil Service, where she worked on the Digital Markets, Competition and Consumers Bill at the Department for Science, Innovation and Technology, and at HM Treasury on designing COVID-19 support schemes and delivering the Financial Services and Markets Bill. Before that, Audre worked at a public relations consultancy, advising public and private sector clients on their communications, public relations, and government affairs strategy.
Prior to this, Audre completed an MSc in Public Policy at the Korea Development Institute and a Bachelor's in International Relations and History from SOAS, University of London. Outside of work, she enjoys spending time outdoors, learning about new cultures through travel and food, and going on adventures.
Dani joined techUK in February 2025 as a Policy Manager in the Digital Regulation team.
Prior to this, Dani worked in political monitoring where she was a consultant for Digital, Culture, Media and Sport. In this role, she developed a strong understanding of parliamentary procedure, closely following all of the major developments in the tech centre and working with several key stakeholders and regulators.
She has an undergraduate degree in History from the University of Bristol and an MPhil in Modern European History from the University of Cambridge.
Outside of tech, Dani has a strong interest in addiction policy, particularly towards drugs, having written her dissertation on the topic as well as several subsequent research projects. In her spare time, she enjoys cooking and following all things motoring, whether that be F1, MotoGP or Formula E.
Oliver is a Junior Policy Manager at techUK, working across Public Affairs and Digital Regulation policy. He supports the organisation’s engagement with government and parliament, contributes to shaping techUK’s regulatory agenda, and plays a key role in coordinating political outreach, policy projects, and flagship events.
He joined techUK in November 2023 as a Team Assistant to the Policy and Public Affairs team, before stepping into his current role. He has been closely involved in efforts to ensure the tech sector’s voice is heard in the policymaking process.
Oliver holds a Master’s in Policy Research from the University of Bristol and a BSc in Policy from Swansea University. During his studies, he contributed to mental health research as a Student Research Assistant for the SMaRteN network.
Outside of work, Oliver is a keen debater and remains active in the UK debating community, having previously led the Swansea University Debating Union. He enjoys exploring complex issues from multiple perspectives and values clear, thoughtful communication in policy discussions.
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Antony Walker is deputy CEO of techUK, which he played a lead role in launching in November 2013.
Antony is a member of the senior leadership team and has overall responsibility for techUK’s policy work. Prior to his appointment in July 2012 Antony was chief executive of the Broadband Stakeholder Group (BSG), the UK’s independent advisory group on broadband policy. Antony was closely involved in the development of broadband policy development in the UK since the BSG was established in 2001 and authored several major reports to government. He also led the development of the UK’s world leading Open Internet Code of Practice that addresses the issue of net neutrality in the UK. Prior to setting up the BSG, Antony spent six years working in Brussels for the American Chamber of Commerce following and writing about telecoms issues and as a consultant working on EU social affairs and environmental issues. Antony is a graduate of Aberdeen University and KU Leuven and is also a Policy Fellow Alumni of the Centre for Science and Policy at Cambridge University.
As Head of Public Affairs, Alice supports techUK’s strategic engagement with Westminster, Whitehall and beyond. She regularly works to engage with ministers, members of the UK’s parliaments and senior civil servants on techUK’s work advocating for the role of technology in the UK’s economy as well as wider society.
Alice joined techUK in 2022. She has experience working at both a political monitoring company, leading on the tech, media and telecoms portfolio there, and also as an account manager in a Westminster-based public affairs agency. She has a degree from the University of Sheffield in Politics and Philosophy.
Edward leads the Digital Economy programme at techUK, which includes our work on online safety, fraud, and regulation for growth initiatives.
He has prior experience working for the Department for Digital, Culture, Media and Sport and has previously worked for a number of public affairs consultancies specialising in research and strategy, working with leading clients in the technology and financial services sectors.
Nimmi Patel is the Head of Skills, Talent and Diversity at techUK. She works on all things skills, education, and future of work policy, focusing on upskilling and retraining. Nimmi is also an Advisory Board member of Digital Futures at Work Research Centre (digit). The Centre research aims to increase understanding of how digital technologies are changing work and the implications for employers, workers, job seekers and governments.
Prior to joining the techUK team, she worked for the UK Labour Party and New Zealand Labour Party, and holds an MA in Strategic Communications at King’s College London and BA in Politics, Philosophy and Economics from the University of Manchester. She also took part in the 2024-25 University of Bath Institute for Policy Research Policy Fellowship Programme and is the Education and Skills Policy Co-lead for Labour in Communications.
Samiah Anderson is the Head of Digital Regulation at techUK.
With over six years of Government Affairs expertise, Samiah has built a solid reputation as a tech policy specialist, engaging regularly with UK Government Ministers, senior civil servants and UK Parliamentarians.
Before joining techUK, Samiah led several public affairs functions for international tech firms and coalitions at Burson Global (formerly Hill & Knowlton), delivering CEO-level strategic counsel on political, legislative, and regulatory issues in the UK, EU, US, China, India, and Japan. She is adept at mobilising multinational companies and industry associations, focusing on cross-cutting digital regulatory issues such as competition, artificial intelligence, and more.
She holds a BA (Hons) in Politics, Philosophy, and Economics from the University of London, where she founded the New School Economics Society, the Goldsmiths University chapter of Rethinking Economics.
Audre joined techUK in July 2023 as a Policy Manager for Data. Previously, she was a Policy Advisor in the Civil Service, where she worked on the Digital Markets, Competition and Consumers Bill at the Department for Science, Innovation and Technology, and at HM Treasury on designing COVID-19 support schemes and delivering the Financial Services and Markets Bill. Before that, Audre worked at a public relations consultancy, advising public and private sector clients on their communications, public relations, and government affairs strategy.
Prior to this, Audre completed an MSc in Public Policy at the Korea Development Institute and a Bachelor's in International Relations and History from SOAS, University of London. Outside of work, she enjoys spending time outdoors, learning about new cultures through travel and food, and going on adventures.
Mia focuses on shaping a policy environment that fosters the expansion of the UK tech sector while maximising the transformative potential of technology across all industries.
Prior to joining techUK, Mia worked as a Senior Policy Adviser at the Confederation of British Industry (CBI) within the Policy Unit.
Mia holds an MSc in International Development from the University of Manchester and a BA(Hons) in Politics and International Relations from the University of Nottingham.
Archie Breare joined techUK in September 2022 as the Telecoms Programme intern, and moved into the Policy and Public Affairs team in February 2023.
Before starting at techUK, Archie was a student at the University of Cambridge, completing an undergraduate degree in History and a master's degree in Modern British History.
In his spare time, he likes to read, discuss current affairs, and to try and persuade himself to cycle more.
Dani joined techUK in February 2025 as a Policy Manager in the Digital Regulation team.
Prior to this, Dani worked in political monitoring where she was a consultant for Digital, Culture, Media and Sport. In this role, she developed a strong understanding of parliamentary procedure, closely following all of the major developments in the tech centre and working with several key stakeholders and regulators.
She has an undergraduate degree in History from the University of Bristol and an MPhil in Modern European History from the University of Cambridge.
Outside of tech, Dani has a strong interest in addiction policy, particularly towards drugs, having written her dissertation on the topic as well as several subsequent research projects. In her spare time, she enjoys cooking and following all things motoring, whether that be F1, MotoGP or Formula E.
Oliver is a Junior Policy Manager at techUK, working across Public Affairs and Digital Regulation policy. He supports the organisation’s engagement with government and parliament, contributes to shaping techUK’s regulatory agenda, and plays a key role in coordinating political outreach, policy projects, and flagship events.
He joined techUK in November 2023 as a Team Assistant to the Policy and Public Affairs team, before stepping into his current role. He has been closely involved in efforts to ensure the tech sector’s voice is heard in the policymaking process.
Oliver holds a Master’s in Policy Research from the University of Bristol and a BSc in Policy from Swansea University. During his studies, he contributed to mental health research as a Student Research Assistant for the SMaRteN network.
Outside of work, Oliver is a keen debater and remains active in the UK debating community, having previously led the Swansea University Debating Union. He enjoys exploring complex issues from multiple perspectives and values clear, thoughtful communication in policy discussions.
Tess joined techUK as an Policy and Public Affairs Team Assistant in November of 2024. In this role, she supports areas such as administration, member communications and media content.
Before joining the Team, she gained experience working as an Intern in both campaign support for MPs and Councilors during the 2024 Local and General Election, and working for the Casimir Pulaski Foundation on defence and international secuirty. She has worked for multiple charities, on issues such as the climate crisis, educational inequality and Violence Against Women and Girls (VAWG). In 2023, Tess obtained her Bachelors of Arts in Politics and International Relations from the University of Nottingham.
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