Do I need to care about complying?

❗️

Yes.
Fines are £18m or 10% of global turnover, whichever is greater.


Ofcom doesn't care if you're small

Here are some comments from Ofcom’s latest statement “Volume 1: Overview scope and regulatory approach” from their finalised guidance regarding the Online Safety Act:


“Services cannot decline to take steps to protect children because it is too expensive or inconvenient – protecting children is a priority. All services, even the smallest, will have to take action”

It doesn't matter if you're a small game; you have to comply.
No excuses.


”By now, all services must have carried out assessments to determine whether they are in scope of the children’s safety duties. We anticipate that most services not using highly effective age assurance will be in scope of the regulatory package we are confirming today.”

Services in scope of the children’s safety duties now have until 24 July 2025 to complete and record their children’s risk assessments, as explained in the Children’s Risk Assessment Guidance. There’s lots of work which you should have completed by now, and if you haven’t - do it now. The most important and major deadlines are coming up. Don’t miss them.


“We can now confirm that our proposals will also include measures to protect children from grooming through the use of highly effective age assurance. By the end of 2025, we will publish our final guidance on wider protections for women and girls following our consultation in February 2025.”

This is an evolving and expanding topic which will progress further legislatively to further protect users, which means service providers will have to continue evolving their processes and adjusting their product/service offering to ensure compliance, as the compliance changes.

Additionally; you need to remember that the Online Safety Act has been enacted for the first time in the UK, but it is not unique. Australia has passed their version and it is coming into regulation at the end of 2025, and EU member states are in the process of passing their own versions (the DSA is already in effect, and it is likely that user-to-user provisions will be added).


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This is not just a one-off tick box exercise.

It is clear that this is not a one-off tick box exercise for today, and it’s not something that you can ignore.
This is a global area of focus, and will be ever-developing over the coming years.