Closed
Duties under the Online Safety Act 2023 to protect children from encountering pornographic content through the use of highly effective age assurance.
9 May 2025
15 January 2026
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 Itai Tech Ltd 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.
Section 81 of the Online Safety Act 2023
Ofcom has today published the non-confidential version of the Confirmation Decision that we issued to Itai Tech Ltd on 20 November 2025 in relation to its failure to comply with section 81 of the Act and its failure to comply with a statutory information request.
The Decision concerns our investigation into Itai Tech Ltd’s compliance with its duties 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, and to respond to a request for information.
In response to our investigation, Itai Tech Ltd has implemented a block to restrict users with UK IP addresses from accessing its service. Itai Tech Ltd has paid the penalty set out in the Confirmation Decision. This investigation is now closed.
Itai Tech Ltd remains subject to obligations under the Online Safety Act 2023 and Ofcom will continue to monitor the service.
In accordance with section 132 of the Online Safety Act 2023 (‘the Act’), we have issued Itai Tech Ltd with a Confirmation Decision in relation to its failure to comply with section 81 of the Act and its failure to comply with a statutory information request.
Ofcom has determined that Itai Tech Ltd 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 Itai Tech Ltd of £50,000 in respect of the contravention of section 81. This penalty was set having regard to our Penalty Guidelines.
Ofcom has also determined that Itai Tech Ltd has failed to comply with section 102(8) of the Act by failing to respond to a statutory request for information within the specified time frame issued as part of the investigation.
Following the issue of the Provisional Decision on 17 September 2025, Itai Tech Ltd provided us with the outstanding information initially requested during the investigation.
We have imposed a penalty of £5,000 in respect of the breach of section 102(8)(a), again having regard to our Penalty Guidelines.
A non-confidential version of the Confirmation Decision will be published shortly.
We have made no finding on ongoing compliance and we will continue to monitor geoblocking on the site going forward.
Following an investigation, Ofcom has provisionally determined that there are reasonable grounds to believe Itai Tech Ltd has failed / is failing to comply with section 81 of the Online Safety Act (OSA). Section 81 imposes a duty on providers of services that fall under Part 5 of the OSA 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 Itai Tech Ltd on 17 September 2025 under section 130 of the OSA. The notice also sets out our provisional view that Itai Tech Ltd has infringed its duties under section 102(8) of the OSA by failing to respond to a statutory request for information issued as part of the investigation.
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. Itai Tech 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 24 June 2025, Ofcom issued a formal information notice to Itai Tech Ltd under section 100 of the Online Safety Act. As at the date of this announcement, no response has been received. Accordingly, Ofcom has expanded the scope of the investigation to consider whether Itai Tech Ltd has failed to comply with the statutory requirements of that notice. In addition to examining the company’s compliance with its duty to implement highly effective age assurance measures to prevent children from accessing pornographic content, we are now also investigating its failure to respond to Ofcom’s information notice.
Next steps
We are currently gathering and analysing evidence to establish whether Itai Tech Ltd has breached its duties under the Act. If our assessment indicates non-compliance, we will issue a provisional notice of contravention, giving Itai Tech Ltd the opportunity to make representations before we make our final decision.
We will provide updates on this investigation as soon as possible.
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 Itai Tech Ltd, (in relation to the ‘nudification’ site, Undress.cc). 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 each of the companies 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 these investigations 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.
CW/01297/05/25