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Duties under the Online Safety Act 2023 to protect children from encountering pornographic content through the use of highly effective age assurance.
First Time Videos LLC (in respect of the site FTVGirls.com and FTVMilfs.com)
10 June 2025
Ofcom opened an enforcement programme in January 2025 into age assurance measures across the adult sector, initially focusing on regulated providers’ compliance with the Part 5 duties.
We are now investigating whether First Time Videos LLC has failed/is failing to comply with its duties under the Online Safety Act 2023 to protect children from encountering pornographic content through the use of highly effective age assurance.
Relevant Legal Provision: Section 81 of the Online Safety Act 2023
In accordance with section 132 of the Online Safety Act 2023 (‘the Act’), on 18 June 2026 we issued First Time Videos LLC (‘First Time Videos’) with a Confirmation Decision in relation to its failure to comply with section 81 of the Act.
Ofcom has determined that First Time Videos has failed to comply with section 81 of the Act. Section 81 imposes a duty on providers of services that fall under Part 5 of the Act to ensure, through the use of highly effective age verification or age estimation (or both), that children are not normally able to encounter content that is regulated provider pornographic content.
We are imposing a penalty on First Time Videos of £80,000 in respect of the contravention of section 81. This penalty was set having regard to our Penalty Guidelines.
A non-confidential version of the Confirmation Decision will be published in due course.
Following an investigation, Ofcom has provisionally determined that there are reasonable grounds to believe that First Time Videos LLC has failed to comply with section 81 of the Online Safety Act (‘the Act’).
Section 81 imposes a duty on providers of services that fall under Part 5 of the Act to ensure, through the use of highly effective age verification or age estimation (or both), that children are not normally able to encounter content that is regulated provider pornographic content.
Ofcom therefore issued a provisional notice of contravention to First Time Videos LLC on 30 March 2026 under section 130 of the Act.
The notice sets out the facts that Ofcom has relied upon to reach its provisional view, the actions we propose to take, and the rationale for those decisions. First Time Videos LLC will now have a period of 20 working days to make representations to Ofcom, which will be carefully considered before reaching a final decision.
On 12 December 2025, Ofcom issued a formal information notice to First Time Videos LLC under section 100 of the Act. As at the date of this announcement, we have not received a response to the information notice. Ofcom has therefore now expanded this investigation to include considering whether First Time Videos LLC has failed, or is failing, to comply with its duty to respond accurately to an information notice sent under the Act.
In January 2025, Ofcom decided to open an enforcement programme under the Online Safety Act (OSA). The programme focusses on the duties for part 5 services to implement highly effective age assurance to prevent children from accessing pornography.
Today we have opened an investigation into First Time Videos LLC, (in relation to the studio sites, FTVGirls.com and FTVMilfs.com). The service does not appear to have taken steps to implement highly effective age assurance on their services, as required under section 81 of the Online Safety Act.
Ofcom’s investigation will examine whether there are reasonable grounds to believe that the company has failed, or is failing, to comply with its duties under section 81 in Part 5 of the Online Safety Act 2023 (the ‘Act’) to protect children from encountering pornographic content through the use of highly effective age assurance.
We will provide an update on this investigation in due course. Ofcom’s Online Safety Enforcement Guidance sets out how Ofcom will normally approach enforcement under the Act. This includes our approach to information gathering and analysis and the procedural steps we must take to fairly determine the outcome of the investigation.