The UK Online Safety Bill was passed by Parliament earlier this week and is expected to soon become law through royal assent. The Online Safety Act (UK OSA) will impose a series of sweeping obligations, including risk assessment, content moderation, and age assurance requirements, on a variety of online services that enable user-generated content, including but not limited to social media and search providers.

Among the most notable aspects of the UK OSA are its “duties of care.” The law will impose a series of affirmative obligations to assess and mitigate safety risks.

Safety Risk Assessments

Services in scope will need to conduct “illegal content risk assessments” for numerous categories of content, including child sexual abuse material (CSAM), terrorism, suicide, violent threats, harassment, drugs, weapons, and nonconsensual nudity.

Certain services will also have heightened duties of care and additional risk assessment requirements. For example, those services that are “likely to be accessed by children” under 18 years of age will also need to conduct children’s risk assessments and take additional measures in relation to harmful and age-inappropriate content.

Other Notable Safety Requirements

The UK OSA will also require providers to, among other things:

  • Quickly remove illegal content or prevent it from appearing.
  • Prevent children under 18 from accessing harmful and age-inappropriate content.
  • Enforce age limits and age assurance measures.
  • Provide reporting and complaints procedures for children and their parents.
  • Offer user empowerment tools, such as an option to filter out harmful content.
  • Enforce published terms and content policies.

Certain safety measures will be required of all services, and others will depend on how platforms are categorized under the law.


Ofcom, the UK regulator in charge of overseeing telecommunications, has been confirmed as the regulator for online safety and will have the authority to enforce the UK OSA and impose fines of up to £18M or 10% of a company’s global revenue. Company executives could also face criminal action for certain violations. Ofcom has announced that it will soon begin working on codes of practice in furtherance of a phased approach to implementation and enforcement.


Providers of services in scope may wish to begin assessing how best to integrate the UK OSA’s requirements into ongoing compliance efforts for other online safety laws in the United States, EU, and around the world, including the Digital Services Act.