UK Online Safety Act Compliance: The 2025 Guide for Businesses

The UK Online Safety Act marks a pivotal shift in how online services must protect users from harmful and illegal content. Enforced by Ofcom, the Act introduces stringent duties for online platforms, search engines, messaging services, and other regulated digital services.
Businesses that fail to comply risk fines of up to £18 million or 10% of global turnover - making compliance not just a legal necessity but a core operational priority.

For companies operating in sectors such as iGaming, social media, marketplaces, and fintech, the Act’s requirements - from risk assessments to age verification and transparency reporting - demand proactive implementation.

Identomat offers advanced KYC, AML, and identity verification solutions, helping businesses meet the Act’s standards while maintaining a smooth user experience and protecting against fraud.

Background & Purpose of the Act

The UK Online Safety Act was introduced to address the growing risks posed by harmful and illegal content online, with a particular focus on protecting children and vulnerable users.
Unlike earlier self-regulatory approaches, the Act imposes legally binding duties on service providers to actively monitor, detect, and remove prohibited material.

Key drivers for the legislation include:

● Rapid growth of user-generated content and its misuse for harmful activities.

● Rising instances of online fraud, hate speech, and child exploitation material.

● Increasing political and public pressure for stronger platform accountability.

The Act aligns the UK more closely with global trends in digital safety regulation, while introducing unique obligations tailored to the UK’s legal environment - drawing some parallels but also distinct differences from the EU’s Digital Services Act (DSA).

Ofcom serves as the central enforcement body, with powers to investigate, demand information, issue penalties, and even block access to non-compliant services in extreme cases.

Who Must Comply & Scope

The UK Online Safety Act applies to a broad range of online platforms and services that facilitate user interaction, content sharing, or public communication.
Compliance obligations are not limited to UK-based businesses - they also extend to international companies that provide services accessible in the UK.

Core Categories of Regulated Service

1. User-to-User Services

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• Platforms that allow users to share or interact with user-generated content, such as social media platforms, online forums, dating apps, and community sites.
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• Examples: Facebook, Instagram, TikTok, niche community platforms.

2. Search Services

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• Search engines and directories that index and display content, including results that could lead to harmful or illegal material.
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• Examples: Google, Bing, internal search tools on large content platforms.

3. High-Risk Industry Platforms

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• Services where the risk of harm is elevated due to industry nature, such as:
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 – iGaming and betting sites (age verification obligations are critical here)
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 – Online marketplaces (fraud prevention & counterfeit goods detection)
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 – Messaging services with end-to-end encryption (child safety and proactive monitoring considerations)

4. Hybrid Services

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• Platforms that combine multiple functionalities, such as marketplaces with built-in messaging or streaming features.

International Scope

The Act has extraterritorial reach, meaning:

• If your platform can be accessed from the UK, you may be in scope - even if your company is based elsewhere.

• This aligns with global enforcement patterns seen in other digital safety laws, such as the EU Digital Services Act.

Determining Your Service Category

Ofcom’s framework encourages businesses to conduct a comprehensive service risk assessment to:

• Identify which category their service falls into.

• Map applicable obligations, which may vary depending on size, reach, and risk level.

• Prioritize child safety and proactive monitoring if your service is deemed high-risk.

Implications for Identomat’s Target Sectors

• iGaming Operators → Must implement age verification and anti-fraud measures before account creation.

• Social Media Platforms → Need strong content moderation and abuse reporting systems.

• Marketplaces → Must screen listings for illegal products and provide clear reporting channels.

• Fintech Platforms → Should integrate KYC/AML checks to prevent platform misuse.

Tip: Even if your service is not directly named in Ofcom’s scope, your risk profile may still bring you under compliance obligations - especially if your platform hosts user-generated content or processes financial transactions.

Core Compliance Requirements

The UK Online Safety Act sets out a clear framework of obligations for regulated online services, designed to protect users from harmful and illegal content.
While the exact duties vary by service type and risk category, all in-scope businesses must meet strict standards in several key areas.

1. Conduct and Maintain a Risk Assessment

Every regulated service must perform a comprehensive and ongoing risk assessment. This means looking beyond obvious threats and assessing the ways your platform’s features could contribute to harm. For example, Ofcom expects platforms to consider how algorithms, recommendation systems, and search functionalities might amplify illegal or harmful content.

The risk assessment should be documented, updated regularly, and ready for inspection by Ofcom. Failing to keep it current could lead to enforcement action.
For high-risk sectors such as iGaming, social media, and online marketplaces, this process is especially critical because user interactions often involve sensitive data, financial transactions, or vulnerable audiences.

Identomat’s role: Integrating KYC, AML, and fraud prevention tools into your onboarding process can significantly reduce platform misuse, making your risk profile more favourable under Ofcom’s guidelines.

2. Remove Illegal Content Promptly

Under the Act, platforms must take swift and effective action to remove illegal content once it is detected or reported. This includes - but is not limited to - child sexual abuse material (CSAM), terrorism-related material, and content constituting criminal offences under UK law.

Larger services are expected to have proactive monitoring systems in place, combining automated detection with human review. Even platforms offering end-to-end encryption may be required to demonstrate they can detect and mitigate serious risks without violating user privacy.

Failure to act quickly not only puts users at risk but could result in fines of up to £18 million or 10% of global turnover.

3. Implement Age Verification and Access Controls

If your platform provides adult content, gambling services, or any activity with legal age restrictions, you must implement robust age verification. The law demands methods that are both reliable and privacy-preserving - meaning you can’t rely on self-declaration or easily bypassed systems.

In high-risk sectors like iGaming, failure to verify a user’s age before granting access can lead to severe regulatory penalties and reputational damage.

Identomat’s role: Our age verification technology uses government-issued ID checks combined with biometric confirmation, ensuring compliance without introducing unnecessary friction for legitimate users.

4. Establish Robust Content Moderation Policies

Content moderation is at the heart of the Act’s safety objectives. Platforms must have clear, published policiesexplaining what content is prohibited and how moderation decisions are made. These policies should be enforced consistently and transparently.

An effective moderation framework often includes:

• AI-powered content filtering to identify harmful material at scale.

• Human moderation teams for nuanced or borderline cases.

• User reporting tools that are easy to find and use.

By documenting and publishing your moderation process, you not only comply with the law but also build user trust.

5. Provide Transparency Reporting

Transparency reports are now a legal obligation for many regulated services. These reports must outline:

• The number and categories of harmful content reports received.

• The average time taken to remove content.

• The measures taken to protect children and vulnerable users.

These reports serve as both a compliance measure for Ofcom and a trust-building tool for your users, showing you take their safety seriously.

6. Enable User Reporting and Appeal Mechanisms

Every platform must provide accessible ways for users to report illegal or harmful content. Once a report is submitted, the user should receive an acknowledgement and information about how the platform will handle their concern.

Equally important is the appeals process - users whose content is removed must have a clear and fair way to challenge the decision. This not only meets compliance standards but also protects your platform from accusations of bias or unfair censorship.

7. Cooperate Fully with Ofcom

Ofcom has the authority to demand information, inspect compliance measures, and issue enforcement actions. Platforms must respond to information requests promptly and implement relevant safety codes of practice where applicable.

Non-cooperation can result in severe penalties, including service blocking - a risk that can destroy a brand’s UK presence overnight.

Bottom line: Compliance with the UK Online Safety Act is not a one-off exercise. It requires continuous monitoring, updating, and improvement - a process where technology providers like Identomat can play a vital supporting role.

How the Act Protects Children Online, and the Age Verification Requirements

One of the primary objectives of the UK Online Safety Act is to create a safer digital environment for children. The legislation recognises that children are among the most vulnerable online users and sets out specific, enforceable duties for service providers to protect them from harmful or illegal content.

Child Protection as a Core Compliance Goal

The Act requires regulated services to identify, assess, and mitigate risks to children. This includes protection from:

• Inappropriate or harmful content such as pornography, violence, or self-harm promotion.

• Contact risks from adults attempting to groom or exploit children.

• Conduct risks, including cyberbullying, harassment, and hate speech.

Service design plays a key role here. Platforms are expected to adjust algorithms, privacy settings, and recommendation systems to limit children’s exposure to risk, and provide clear, accessible safety tools. Ofcom’s forthcoming codes of practice will formalise these measures.

Age Verification Obligations

To make these protections enforceable, the Act mandates robust age verification for access to adult content and age-restricted services. This is not limited to pornography sites - it includes iGaming operators, online marketplaces selling restricted goods, and streaming platforms hosting mature-rated material.

Key requirements:

• Accuracy over self-declaration → Birth date fields alone do not comply.

• Privacy-first design → Verification must meet UK data protection requirements.

• Ongoing security checks → Systems must adapt to prevent circumvention.

Identomat’s Age Verification Solution

Identomat offers a purpose-built age verification solution that aligns perfectly with the UK Online Safety Act’s standards, combining security, speed, and a frictionless user experience.

Core capabilities include:

• Document Verification – Instant scanning of passports, driving licences, and national ID cards from multiple jurisdictions.

• Biometric Face Matching – AI-powered facial recognition to confirm the ID belongs to the person using it.

• Liveness Detection – Prevents spoofing by ensuring the user is physically present during verification.

• Customizable User Flows – Flexible integration to suit iGaming, streaming, marketplace, and other high-risk industries.

• GDPR-Compliant Data Handling – Ensures all sensitive user data is securely processed and stored in compliance with UK and EU regulations.

By adopting Identomat’s solution, businesses can:

• Meet Ofcom’s requirements without guesswork.

• Reduce compliance risk by preventing underage access.

• Preserve conversion rates by keeping the onboarding process quick and intuitive.

In short - Identomat bridges the gap between regulatory compliance and commercial efficiency, enabling companies to meet their legal obligations while maintaining trust with their users.

What About Larger Platforms and Specific Industries – Are There Extra Requirements?

The UK Online Safety Act uses a risk-based compliance model, meaning obligations scale according to the platform’s size, reach, and risk profile.
While all regulated services must meet the core compliance standards, larger platforms and high-risk industries are subject to stricter, more frequent, and more resource-intensive obligations.

Larger Platforms: Higher Standards of Responsibility

Platforms classified by Ofcom as Category 1 services - typically large social media networks, major messaging services, or other widely used platforms - face additional duties because of their broad public influence and potential to cause harm.

• Proactive Detection and Removal – Category 1 platforms must continuously monitor for illegal and harmful content, rather than relying solely on user reports. This often requires advanced AI detection systems paired with human moderation to act before harm spreads.

• Enhanced Risk Assessments – These platforms must conduct more detailed and frequent risk assessments, including analysis of how product features like algorithms, search functions, and recommendation engines could amplify harmful content.

• Additional Transparency Requirements – Ofcom expects Category 1 services to produce more granular transparency reports, covering moderation decisions, appeals processes, and enforcement actions in detail.

• Public Policy Commitments – Platforms must show how their policies align with the Act’s child protection and safety objectives, often requiring public commitments and regular policy reviews.

Industry-Specific Compliance Pressures

Certain industries are inherently high-risk under the Act, leading to stricter oversight and specialised compliance requirements.

iGaming & Betting

• Mandatory Age Verification – Operators must confirm a user’s age before account creation, using robust and privacy-preserving methods. Weak systems risk allowing underage gambling, which can result in heavy fines and licence revocation.

• Continuous Fraud Monitoring – The high financial stakes in iGaming make platforms prime targets for identity theft, bonus abuse, and other fraud schemes. Ongoing transaction monitoring is expected.

• Detailed Risk Reporting – Operators must keep detailed compliance records and report player safety measures to both Ofcom and gambling regulators.

Identomat’s role: Delivers AI-driven age checks, KYC/AML workflows, and continuous fraud detection to ensure iGaming operators meet both gambling regulations and Online Safety Act requirements.

Online Marketplaces

• Screening for Prohibited or Dangerous Goods – Platforms must actively detect and remove listings that involve unsafe or illegal products. Automated keyword filtering and image recognition often play a role here.

• Rapid Takedown Processes – Once identified, illegal listings must be removed promptly to avoid harm and regulatory penalties.

• Seller Identity Verification – Verifying the legitimacy of sellers is critical to preventing fraud and counterfeit goods sales.

Identomat’s role: Offers automated seller verification through document checks, ID scanning, and database screening to stop fraudulent vendors before they go live.

Social Media & User-Generated Content Platforms

• Scalable Content Moderation – These platforms must handle potentially millions of uploads per day, requiring advanced AI detection combined with trained human moderators.

• Harassment and Abuse Prevention – Policies must specifically address cyberbullying, hate speech, and targeted harassment, especially against vulnerable users.

• Child-Specific Safety Features – Default privacy settings, restricted messaging options, and curated content feeds are often mandated for underage users.

Identomat’s role: Augments moderation systems with identity verification to deter anonymous abuse, improve accountability, and create safer community spaces.

Fintech & Payment Platforms

• Fraud and Scam Prevention – Platforms must guard against phishing, account takeovers, and synthetic identities, which are often used to launder money or commit financial fraud.

• Transaction Monitoring – Real-time monitoring to detect unusual payment patterns or suspicious activities is essential.

• Identity Cross-Checks – Matching user information against official databases and sanctions lists is key for compliance.

Identomat’s role: Provides seamless AML screening, transaction monitoring, and identity verification integration to prevent misuse while keeping user onboarding smooth.

What Are the Penalties for Non-Compliance, and How Does Ofcom Enforce the Act?

The UK Online Safety Act gives Ofcom extensive powers to enforce compliance. Penalties are designed to be severe enough to act as a real deterrent, ensuring platforms take their obligations seriously.
Non-compliance can damage not only a company’s finances but also its reputation, operational continuity, and market access.

Financial Penalties

• Up to £18 Million or 10% of Global Turnover – Ofcom can impose fines of up to the higher of these two amounts. For large global companies, the 10% turnover penalty can easily run into the hundreds of millions, making compliance far more cost-effective than risking violations.

• Daily Penalty Accruals – In some cases, fines can be applied on a daily basis until the issue is resolved, significantly increasing the financial impact over time.

• Calculation Based on Severity – Ofcom assesses the gravity of the offence, whether harm was caused, and if the company acted negligently or deliberately.

Service Restriction and Blocking

• Blocking Access to Non-Compliant Services – Ofcom has the authority to require internet service providers (ISPs) to block access to platforms that fail to comply. This can instantly remove a service from the UK market.

• Traffic Restrictions – In some cases, Ofcom may order partial restrictions, throttling a service’s UK reach until it meets compliance obligations.

• Disruption to Revenue Streams – Being blocked or restricted means loss of UK-based ad revenue, subscriptions, and user engagement.

Criminal Liability for Executives

• Personal Accountability – Senior managers and company directors can face personal criminal charges for certain breaches, particularly those related to child safety or failing to comply with Ofcom notices.

• Potential for Imprisonment – In the most severe cases, non-compliance could lead to custodial sentences for responsible individuals.

• Increased Pressure on Leadership – These provisions ensure compliance is treated as a top-level strategic priority.

Reputational Damage

• Loss of Public Trust – Non-compliance can erode user confidence, especially if breaches involve child safety or high-profile illegal content cases.

• Negative Media Coverage – Ofcom’s penalties are public, and press coverage often amplifies the reputational fallout.

• Impact on Partnerships – Businesses risk losing partners, advertisers, or investors concerned about regulatory risk.

How Ofcom Enforces Compliance

• Information Notices – Ofcom can demand detailed documentation, data, and evidence of compliance. Failure to respond accurately and promptly is itself a breach.

• Audits and Inspections – The regulator may conduct scheduled or surprise audits to review a platform’s safety measures, moderation systems, and risk assessments.

• Codes of Practice – Ofcom issues industry-specific codes outlining best-practice compliance measures. While not mandatory, deviating from these requires proof that your alternative approach is equally effective.

• Enforcement Notices – Formal orders to correct compliance failures, often with strict deadlines and follow-up checks.

Where Identomat Helps You Stay Enforcement-Ready

• Automated Compliance Records – Keep a verifiable trail of identity checks, age verifications, and fraud prevention measures that can be produced instantly if Ofcom requests evidence.

• Risk Mitigation Tools – Identomat’s KYC, AML, and age verification solutions directly address high-risk areas most likely to attract enforcement action.

• Faster Response to Notices – With built-in reporting tools, platforms can respond to Ofcom’s information requests quickly and accurately, reducing the likelihood of escalation.

• Future-Proofing – Continuous updates to align with evolving Ofcom codes and safety guidelines.

The penalties for non-compliance are too costly to ignore, both financially and operationally. Proactive compliance - supported by technology partners like Identomat - is the most reliable defence against fines, service disruption, and reputational damage.

When Do the Requirements Take Effect? - Key Timelines and Deadlines

The UK Online Safety Act is being rolled out in phases to give platforms time to adjust their systems, policies, and technologies.
However, Ofcom has made it clear that early preparation is essential - waiting until the last moment increases compliance risk and could result in enforcement action before all systems are ready.

Initial Commencement

• Royal Assent in October 2023 – This is when the Act formally became law, setting the legal foundation for enforcement. While many provisions require secondary legislation and Ofcom codes before they apply, the law’s framework is already in place.

• Preparatory Obligations Begin – Even before deadlines, platforms are expected to begin internal reviews, mapping obligations to their current safety and compliance measures.

Ofcom’s Code of Practice Rollout

• First Codes Expected Within 12 Months – Ofcom is tasked with producing sector-specific codes of practice outlining compliance expectations. These will clarify requirements for different service categories.

• Consultation Periods – Ofcom will open consultations before finalising each code, allowing industry feedback. Engaging early in this process can give platforms more influence over practical rules.

• Adoption Timeline – Once codes are finalised, businesses are expected to implement relevant measures within set compliance windows (often six months).

Phased Enforcement

• High-Risk Services First – Ofcom has indicated it will prioritise enforcement in sectors with the highest potential for harm, such as iGaming, adult content platforms, and large social networks.

• Broader Enforcement to Follow – Lower-risk and smaller platforms will have slightly longer lead times, but will still face full compliance checks eventually.

• Continuous Updates – Requirements may evolve based on technological changes, emerging risks, and Ofcom’s updated risk assessments.

Mandatory Reporting Dates

• Transparency Reports – Platforms required to submit transparency reports will have fixed annual or biannual submission deadlines, to be confirmed by Ofcom for each service category. Missing these dates is a direct breach of the Act.

• Incident Reporting – In some cases, serious safety incidents must be reported immediately, outside of regular reporting cycles.

Where Identomat Helps You Meet Deadlines

• Rapid Implementation – Identomat’s KYC, AML, and age verification tools can be deployed quickly, allowing platforms to meet early enforcement deadlines without heavy development delays.

• Automated Evidence Gathering – Our system stores verifiable compliance data, making it easy to prepare for Ofcom reporting requirements.

• Adaptable Workflows – As Ofcom releases new codes of practice, Identomat’s modular integrations allow businesses to adjust processes without major overhauls.

While the Act’s full obligations are being introduced in stages, the clock is already ticking. Platforms that invest in compliance systems now - rather than waiting for final deadlines - will be in the strongest position to avoid disruption when enforcement begins.

How Can Businesses Meet Online Safety Act Requirements Effectively (and How Can Solutions Like Identomat Help)?

The UK Online Safety Act sets out ambitious safety standards - but meeting them effectively requires a strategic, technology-driven approach.
Rather than treating compliance as a one-off legal exercise, businesses should see it as an ongoing operational commitment backed by reliable systems, clear policies, and proactive monitoring.

1. Start with a Comprehensive Compliance Audit

• Assess Current Gaps – Compare your existing policies, moderation systems, and verification processes against the Act’s requirements. This ensures you know where you’re compliant and where urgent improvements are needed.

• Risk Profile Mapping – Identify the areas of your service most likely to cause compliance challenges, such as user-generated content, underage access, or fraud exposure.

Identomat’s role: Our tools provide ready-made modules for age verification, KYC, and fraud detection, which can be quickly integrated into existing workflows to address high-risk areas immediately.

2. Implement Robust Age Verification

• Use Reliable, Privacy-Preserving Methods – Age verification should go beyond self-declaration and comply with UK data protection standards.

• Minimise User Friction – Choose solutions that verify identity quickly without creating unnecessary onboarding delays.

Identomat’s role: Our AI-powered verification combines ID document scanning, biometric face matching, and liveness detection to ensure accurate results in seconds - keeping both users and regulators satisfied.

3. Strengthen Content Moderation and Reporting Tools

• Adopt a Hybrid Approach – Combine AI-based detection tools for scale with human moderators for nuanced decisions.

• Make User Reporting Simple – Reports should be easy to submit, acknowledged automatically, and processed quickly.

Identomat’s role: Identity verification can be linked to user accounts to reduce anonymous abuse, improve moderation accuracy, and deter repeat offenders.

4. Maintain Clear, Public Safety Policies

• Transparency Builds Trust – Publish terms of service and content policies in accessible language so users understand platform rules.

• Align Policies with Ofcom’s Codes – This reduces enforcement risk and shows regulators you’re proactive.

Identomat’s role: Verified user onboarding helps enforce these policies by ensuring accountability from the first interaction.

5. Prepare for Continuous Reporting

• Track Metrics from Day One – Keep records of moderation actions, verification checks, and safety measures implemented.

• Automate Where Possible – Manual reporting is resource-heavy; automated systems save time and reduce errors.

Identomat’s role: Our platform automatically logs compliance actions, creating a verifiable audit trail that can be submitted directly to Ofcom.

6. Stay Ahead of Regulatory Changes

• Monitor Ofcom Updates – New codes of practice and guidance can alter compliance obligations quickly.

• Test & Adapt Processes Regularly – Treat compliance as a living process, not a fixed checklist.

Identomat’s role: Our integrations are modular, allowing you to adapt verification, fraud prevention, and reporting workflows as requirements evolve - without rebuilding your entire system.

Businesses that combine policy, people, and technology will meet the UK Online Safety Act’s requirements most effectively. Partnering with Identomat means having a single, integrated solution for verification, fraud prevention, and compliance reporting - reducing risk while improving operational efficiency.

Conclusion

UK Online Safety Act compliance is a substantial effort but one that can ultimately make your service more robust and trustworthy. By understanding the law’s requirements, using available tools like Identomat for identity and age verification, and diligently following Ofcom’s guidance, businesses can navigate 2025 and beyond with an effective safety strategy.

Compliance should not be seen as just avoiding penalties, but as embracing a higher standard for your online community – which in turn can be a competitive advantage in an era where users are increasingly concerned about online safety and well-being.

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