The Online Safety Act (‘the Act’) introduces new requirements on providers of online services, which are services made available by means of the internet.

The requirements aim to help keep people in the UK – especially children – safe from illegal and harmful content online. The Act applies to online services that have links with the UK, even if the provider or the service is based or registered outside of the UK.

If you or your organisation provides an online service, such as a website or an app, this checker can help you understand if the Act applies to it and what you can do next.

Categories of service the Act applies to

The Act applies to three categories of online services:

  • user-to-user services
  • search services
  • online services where the provider of the service publishes or displays pornographic content

If a service falls into one or more of these categories, or is a combined service, it will be subject to the legal requirements for each relevant category. A combined service is a user-to-user service that includes a search engine.

You can find more detail about these service types below, and we’ll refer back to them as you use the checker.

Information you’ll need to provide

As you complete this checker, you will be asked about:

  • links your service may have with the UK
  • the type of online service you provide
  • the kinds of content users can encounter on your service

The checker should take around 10 minutes to complete.

The outcome of this checker is indicative only and does not constitute legal advice. It is for you to assess your services and/or seek independent specialist advice to determine whether your service (or the relevant parts of it) are subject to the regulations and understand how to comply with the relevant duties under the Act.

The Online Safety Act (‘the Act’) introduces new requirements on providers of online services, which are services made available by means of the internet.

The requirements aim to help keep people in the UK – especially children – safe from illegal and harmful content online. The Act applies to online services that have links with the UK, even if the provider or the service is based or registered outside of the UK.

If you or your organisation provides an online service, such as a website or an app, this checker can help you understand if the Act applies to it and what you can do next.

Categories of service the Act applies to

The Act applies to three categories of online services:

  • user-to-user services
  • search services
  • online services where the provider of the service publishes or displays pornographic content

If a service falls into one or more of these categories, or is a combined service, it will be subject to the legal requirements for each relevant category. A combined service is a user-to-user service that includes a search engine.

You can find more detail about these service types below, and we’ll refer back to them as you use the checker.

Information you’ll need to provide

As you complete this checker, you will be asked about:

  • links your service may have with the UK
  • the type of online service you provide
  • the kinds of content users can encounter on your service

The checker should take around 10 minutes to complete.

The outcome of this checker is indicative only and does not constitute legal advice. It is for you to assess your services and/or seek independent specialist advice to determine whether your service (or the relevant parts of it) are subject to the regulations and understand how to comply with the relevant duties under the Act.

We often use the term ‘online service’ to refer to an ‘internet service’ as defined under the Act. ‘Internet services’ includes websites and applications accessed through the internet, or by a combination of the internet and an electronic communications service. For example, if a service partly uses the internet and partly uses the public switched telephone network, it still counts as an internet service. This includes services accessed through mobile apps or web browsers.

The relevant legal requirements under the Act can apply all of the internet service you provide or the parts of it that fall in the scope. Multiple legal requirements will apply to your service if it falls within two or more of the above listed categories.

Under the Act, the responsibility for compliance with the safety duties lies with the provider of the regulated service. 

User-to-user services

The provider is the entity that has control over who can use the user-to-user part of the service. If no entity has control, but an individual or individuals do, they are then treated as the provider.

Search services

The provider is the entity that has control over the operations of the search engine, those operations which enable users to make search requests and generate responses to those requests. If no entity has control, but an individual or individuals do, they are then treated as the provider.

Combined services

A combined service is a regulated user-to-user service that includes a public search engine, such as an online service with both a user-to-user part and search engine, and is subject to the duties applicable to each.

The provider is the entity that has control over:

  1. who can use the user-to-user part of the service, and
  2. the operations of the search engine

Other online services

The provider of an internet service, other than a user-to-user service or a search service, is the entity that has control over which content is published or displayed on the service.

The service you provide has links with the UK if any of the following apply:

  • it has a significant number of UK users
  • UK users form a target market
  • it is capable of being used by UK users, and there are reasonable grounds to believe there is a material risk of significant harm to UK users

The risk of significant harm applies to the user-generated content on a user-to-user service, or the search content of a search service. This criteria does not apply to providers of pornographic content.

UK users could include:

  • anyone based in the UK who visits or interacts with your website, app, or other kind of online service – such as customers, clients, subscribers or visitors
  • individual people, entities or organisations in the UK, whether they are registered with you (such as having an account) or not

The service you provide has links with the UK if any of the following apply:

  • it has a significant number of UK users
  • UK users form a target market
  • it is capable of being used by UK users, and there are reasonable grounds to believe there is a material risk of significant harm to UK users

The risk of significant harm applies to the user-generated content on a user-to-user service, or the search content of a search service. This criteria does not apply to providers of pornographic content.

UK users could include:

  • anyone based in the UK who visits or interacts with your website, app, or other kind of online service – such as customers, clients, subscribers or visitors
  • individual people, entities or organisations in the UK, whether they are registered with you (such as having an account) or not

Does your online service have links with the UK?

A target market is a specific group of people or organisations that you are aiming your service toward.

The UK could be a target market for your service for a range of reasons, such as:

  • being designed for UK users
  • being promoted or marketed toward UK users
  • generating revenue from UK users either:
    • directly, such as via subscriptions or sales, or
    • indirectly, such as through advertising to UK users, including people or organisations
  • including functionalities or content that is tailored for UK users, or
  • having a UK domain or providing a UK contact address and/or telephone contact number

Even if the UK is not a target market, your service will still have links to the UK if any part of it has a significant number of UK users.

UK users could include, but is not limited to:

  • any individual, entity or organisation based in the UK who visits or views a service, they do not have to be registered with the service
  • any individual, entity or organisation based in the UK who generates, shares or uploads user-generated content (this may include messages, images, videos, comments or audio) on the service that may be encountered by other users of the service
  • any individual, entity or organisations based in the UK who has encountered search content in or via search results, they do not have to be registered with the service
  • any individual, entity or organisation who submits a search query on a search service

Employees (including volunteers), contractors, consultants or auditors who access the service during the course of their work for you in providing that internet service are not classed as UK users for the purposes of the Act.

The Act does not set out how many UK users is considered ‘significant’ for the purposes of considering whether a service has 'links with the UK'. 

Whether a user is registered or not does not matter.

You should be able to explain your judgement of the number of users you have, especially if you think you do not have a significant number of UK users.

Services that publish or display regulated pornographic content

For services that publish or display regulated pornographic content (Part 5 services), the threshold of a 'significant number of UK users' is not necessarily determined only by a large audience. Even if a site has a relatively small user base, the concept of 'significant number of UK users' should be understood as meaning that the number of UK users on the service is material in the nature and context of the service in question. Therefore, it is important that providers evaluate their UK presence carefully within their specific context, and not assume they do not have links with the UK just because their user numbers aren't large.

We’ll ask you a few questions to help you check whether your online service has any links to the UK.

The UK could be a target market for your service

A target market is a specific group of people (or organisations) that you are aiming your service toward.

The UK could be a target market for your service for a range of reasons, such as:

  • being designed for UK users
  • being promoted or marketed toward UK users
  • generating revenue from UK users either:
    • directly (such as via subscriptions or sales); or
    • indirectly (such as through advertising to UK users, including people or organisations);
  • including functionalities or content that is tailored for UK users; or
  • having a UK domain or providing a UK contact address and/or telephone contact number

For the avoidance of doubt, a service could still meet the UK links test if it has a significant number of UK users even if the UK is not a target market for that service. Alternatively, if the UK is a target market but the service does not have a significant number of UK users, the UK links test would be met in respect of that service.

We’ll ask you a few questions to help you check whether your online service has any links to the UK.

The UK could be a target market for your service

A target market is a specific group of people (or organisations) that you are aiming your service toward.

The UK could be a target market for your service for a range of reasons, such as:

  • being designed for UK users
  • being promoted or marketed toward UK users
  • generating revenue from UK users either:
    • directly (such as via subscriptions or sales); or
    • indirectly (such as through advertising to UK users, including people or organisations);
  • including functionalities or content that is tailored for UK users; or
  • having a UK domain or providing a UK contact address and/or telephone contact number

For the avoidance of doubt, a service could still meet the UK links test if it has a significant number of UK users even if the UK is not a target market for that service. Alternatively, if the UK is a target market but the service does not have a significant number of UK users, the UK links test would be met in respect of that service.

Does your service have the UK as one of its target markets?

Your service may have a significant number of UK users

The Act does not set out how many UK users is considered ‘significant’. You should be able to explain your judgement of the number of users you have, especially if you think you do not have a significant number of UK users.

Users of your service should be counted as UK users if they are:

  • individuals within the UK
  • entities that have been formed or incorporated in the UK

You should count these users regardless of whether they are, or are not, registered with your service. 

Your service may have a significant number of UK users

The Act does not set out how many UK users is considered ‘significant’. You should be able to explain your judgement of the number of users you have, especially if you think you do not have a significant number of UK users.

Users of your service should be counted as UK users if they are:

  • individuals within the UK
  • entities that have been formed or incorporated in the UK

You should count these users regardless of whether they are, or are not, registered with your service. 

Does your service have a significant number of UK users?

Does your service have links to the UK?

We’ll ask you a few questions to help you check whether your online service has any links to the UK.

The UK could be a target market for your service

A target market is a specific group of people (or organisations) that you are aiming your service toward.

The UK could be a target market for your service for a range of reasons, such as:

  • being designed for UK users
  • being promoted or marketed toward UK users
  • generating revenue from UK users either:
    • directly (such as via subscriptions or sales); or
    • indirectly (such as through advertising to UK users, including people or organisations);
  • including functionalities or content that is tailored for UK users; or
  • having a UK domain or providing a UK contact address and/or telephone contact number

For the avoidance of doubt, a service could still meet the UK links test if it has a significant number of UK users even if the UK is not a target market for that service. Alternatively, if the UK is a target market but the service does not have a significant number of UK users, the UK links test would be met in respect of that service.

We’ll ask you a few questions to help you check whether your online service has any links to the UK.

The UK could be a target market for your service

A target market is a specific group of people (or organisations) that you are aiming your service toward.

The UK could be a target market for your service for a range of reasons, such as:

  • being designed for UK users
  • being promoted or marketed toward UK users
  • generating revenue from UK users either:
    • directly (such as via subscriptions or sales); or
    • indirectly (such as through advertising to UK users, including people or organisations);
  • including functionalities or content that is tailored for UK users; or
  • having a UK domain or providing a UK contact address and/or telephone contact number

For the avoidance of doubt, a service could still meet the UK links test if it has a significant number of UK users even if the UK is not a target market for that service. Alternatively, if the UK is a target market but the service does not have a significant number of UK users, the UK links test would be met in respect of that service.

Does your service have the UK as one of its target markets?

Your service may have a significant number of UK users

The Act does not set out how many UK users is considered ‘significant’. You should be able to explain your judgement of the number of users you have, especially if you think you do not have a significant number of UK users.

Users of your service should be counted as UK users if they are:

  • individuals within the UK
  • entities that have been formed or incorporated in the UK

You should count these users regardless of whether they are, or are not, registered with your service.

Services that publish or display regulated provider pornographic content

For services that publish or display regulated pornographic content (Part 5 services), the threshold of a 'significant number of UK users' is not necessarily determined only by a large audience. Even if a site has a relatively small user base, the concept of  'significant number of UK users' should be understood as meaning that the number of UK users on the service is material in the nature and context of the service in question. Therefore, it is important that providers evaluate their UK presence carefully within their specific context, and not assume they are exempt from having links with the UK just because their user numbers aren't large.

Your service may have a significant number of UK users

The Act does not set out how many UK users is considered ‘significant’. You should be able to explain your judgement of the number of users you have, especially if you think you do not have a significant number of UK users.

Users of your service should be counted as UK users if they are:

  • individuals within the UK
  • entities that have been formed or incorporated in the UK

You should count these users regardless of whether they are, or are not, registered with your service.

Services that publish or display regulated provider pornographic content

For services that publish or display regulated pornographic content (Part 5 services), the threshold of a 'significant number of UK users' is not necessarily determined only by a large audience. Even if a site has a relatively small user base, the concept of  'significant number of UK users' should be understood as meaning that the number of UK users on the service is material in the nature and context of the service in question. Therefore, it is important that providers evaluate their UK presence carefully within their specific context, and not assume they are exempt from having links with the UK just because their user numbers aren't large.

Does your service have a significant number of UK users?

Does your service have links to the UK?

User-to-user services are online services that enable its users to generate, upload or share content (such as images, videos, messages, comments or audio) directly on the service which may be encountered by other user(s) of the service.

It does not matter if the content is actually shared with other user(s), as long as the services allow such sharing. This is known as ‘user-generated content’, which is defined as any content—including text, images, videos, audio, or messages—that is generated, uploaded, or shared by a user on a platform, which can then be seen or encountered by other users.

This includes services that allow users to:

  • send private messages between users
  • share content generated by an AI chatbot with other users
  • upload or create their own generative AI chatbots for other users to encounter

Types of user-to-user services

Types of user-to-user services can include:

  • audio sharing services
  • dating services
  • discussion forums and chat rooms
  • file-sharing services
  • fundraising services
  • gaming services
  • marketplaces and listing services
  • messaging services
  • information sharing services
  • review services
  • services with user-generated pornographic content
  • social media services
  • video-sharing services

To answer the question of whether you provide a user-to-user service, you do not need to consider content that you publish directly as the online service provider. This question is about what users can do on your service.

User-to-user services are online services that enable its users to generate, upload or share content (such as images, videos, messages, comments or audio) directly on the service which may be encountered by other user(s) of the service.

It does not matter if the content is actually shared with other user(s), as long as the services allow such sharing. This is known as ‘user-generated content’, which is defined as any content—including text, images, videos, audio, or messages—that is generated, uploaded, or shared by a user on a platform, which can then be seen or encountered by other users.

This includes services that allow users to:

  • send private messages between users
  • share content generated by an AI chatbot with other users
  • upload or create their own generative AI chatbots for other users to encounter

Types of user-to-user services

Types of user-to-user services can include:

  • audio sharing services
  • dating services
  • discussion forums and chat rooms
  • file-sharing services
  • fundraising services
  • gaming services
  • marketplaces and listing services
  • messaging services
  • information sharing services
  • review services
  • services with user-generated pornographic content
  • social media services
  • video-sharing services

To answer the question of whether you provide a user-to-user service, you do not need to consider content that you publish directly as the online service provider. This question is about what users can do on your service.

Do you provide a user-to-user service?

Bots as users of a service

A bot or other automated tool is to be regarded as a user of a service if the functions of the bot or tool include interacting with user-generated content, and the bot or tool is not controlled by or on behalf of the provider of the service

AI-generated content as user-generated content

Any AI-generated content such as text, audio, images or videos that are shared by users on a user-to-user service is user-generated content and is regulated in the same way as human-generated content. For example, deepfake fraud material is regulated no differently to human-generated fraud material. It does not matter whether that content was created on the platform, where it is shared on the service or if it has been uploaded by a user from elsewhere.

Generative AI tools within user-to-user services

Where a service includes a generative AI tool with a feature that enables users to share generated content with other users of the same service, that tool will be considered part of the user-to-user service. This includes, for example, chatbots with a group chat functionality that enables multiple users to interact with a chatbot at the same time. A service would also be considered a user-to-user service where it allows users to upload or create their own generative AI chatbots for other users to encounter. This includes services that provide tools for users to create chatbots that mimic the personas of real and fictional people, which can be submitted to a chatbot library for others to interact with.

If you’re not sure whether you provide a user-to-user service, we have listed some examples of service types that typically allow user-generated content. These services may be considered user-to-user services under the Act.

These examples should help you consider the features and functionalities of your service and make a judgement on whether it is likely to be a user-to-user service. 

If you’re not sure whether you provide a user-to-user service, we have listed some examples of service types that typically allow user-generated content. These services may be considered user-to-user services under the Act.

These examples should help you consider the features and functionalities of your service and make a judgement on whether it is likely to be a user-to-user service. 

Is your service any of the following types?

Audio sharing services typically enable users to share, store, and listen to audio files such as music, podcasts, and voice recordings. Some services also allow users to upload and stream audio files that can be accessed by other users. They allow users to create and share playlists and discover new music, including searching for and subscribing to content uploaded by other users.

Online dating services enable users to find and communicate with romantic or sexual partners. Users can post pictures of themselves, create user profiles, send private messages, and filter by demographic or location. Users are often paired using algorithms that use the information they enter when creating their user profiles.

Discussion forums and chat rooms allow users to send or post messages that can be read by the public or an ‘open’ group of people. Spoken or written communication in chat rooms typically takes place in real-time, whereas posting messages in discussion forums does not. These services often allow users to follow or subscribe to other users, as well as search and react to content uploaded by other users.

File storage and file-sharing services enable users to upload, store, manage and distribute digital media. This content can be shared through unique hyperlinks or URLs which includes sharing files and embedding stored content (such as images and videos) into other services. Some file-sharing services allow users to edit files in real time alongside other users.

Fundraising services typically enable users to create fundraising campaigns and collect donations from users. These services often allow users to share progress related to the fundraising campaign and accept online (in-service) payments. Users can also search for content generated by other users, and campaign pages often allow posting of text and images.

Online gaming services allow for user-to-user interaction in partially or fully simulated virtual environments. Users may interact by creating or manipulating avatars, objects, and the environments themselves, and/or by using voice and messaging functionalities.

Information-sharing services are primarily focused on providing user-generated information to other users. Typically, users can post text and images and search for content uploaded by other users, but some users can also edit and collaborate on content. While there can be a crossover between discussion forums and information-sharing services, the presentation of information may differ and the interaction between users may be more sequential or discursive on forums. 

Online marketplaces and listing services enable users to buy and sell goods or services. They often allow users or providers to create pages that advertise their products. Users can often search for content and send direct messages to other users.

These services generate revenue from sales, hosting third-party sellers, subscriptions, and advertising.

Services facilitate consumer-to-consumer as well as business-to-consumer sale of goods, and other services are targeted at a sub-set of the market. In these cases, the adverts themselves may be user-generated content regulated under the Act.

Adult Service Websites (ASWs) are a type of marketplace website used to facilitate the sale of sexual services. They host user-generated content, adverts, that are commonly pornographic in nature, which are regulated under the Online Safety Act.

Messaging services enable users to send and receive messages that can only be viewed or read by a specific recipient or group of people. Some services apply encryption to this kind of messaging. Most of these services also allow users to share images and videos, and make and receive video calls.

Reviewing services enable users to create and view critical appraisals of people, businesses, products, or services. They allow users to review a wide variety of topics, such as films, restaurants, and employers. These services typically allow users to review goods or services by posting written reviews, pictures, and ratings.

Social media services enable users to build communities around common interests or connections. They typically allow users to find, follow, and communicate with each other through direct messaging, posting or sharing content, as well as commenting and reacting to content.

Some services allow users to upload and share pornographic content in the form of videos, images, or audio, which can be viewed by other users of the service. Such content would be user-generated content.

Video-sharing services enable users to connect, upload and share videos. Some video-sharing services also support livestreaming. They typically allow users to communicate with each other through private messaging, posting content, and reacting to content. Users can also follow or subscribe to creators of content.

The user-to-user service you provide may be exempt from the Act if there are limitations to the way users can communicate or the content they can interact with.

Where content exemptions apply

Your user‑to‑user service will be exempt from the duties required by the Act if either of the following applies.

  1. The only way is by:
  • posting comments or reviews relating to provider content;
  • sharing such comments or reviews on a different internet service;
  • expressing a view on such comments or reviews, on provider content, by means of—

(i)applying a “like” or “dislike” button or other button of that nature,

(ii)applying an emoji or symbol of any kind,

(iii)engaging in yes/no voting, or

(iv)rating or scoring the content (or the comments or reviews) in any way (including giving star or numerical ratings);

  1. The only user-generated content (other than identifying content) enabled by the service is:
  • SMS messages
  • MMS messages
  • emails
  • one-to-one live aural communications – live audio communication such as Voice over Internet Protocol (VOIP) calls between two users that is not accompanied by text or video and are not recordings of such content

The user-to-user service you provide may be exempt from the Act if there are limitations to the way users can communicate or the content they can interact with.

Where content exemptions apply

Your user‑to‑user service will be exempt from the duties required by the Act if either of the following applies.

  1. The only way is by:
  • posting comments or reviews relating to provider content;
  • sharing such comments or reviews on a different internet service;
  • expressing a view on such comments or reviews, on provider content, by means of—

(i)applying a “like” or “dislike” button or other button of that nature,

(ii)applying an emoji or symbol of any kind,

(iii)engaging in yes/no voting, or

(iv)rating or scoring the content (or the comments or reviews) in any way (including giving star or numerical ratings);

  1. The only user-generated content (other than identifying content) enabled by the service is:
  • SMS messages
  • MMS messages
  • emails
  • one-to-one live aural communications – live audio communication such as Voice over Internet Protocol (VOIP) calls between two users that is not accompanied by text or video and are not recordings of such content

Provider content includes:

  • content you publish as the provider of the service
  • content published on your service by a person acting on behalf of you as the provider, including where the publication of the content is effected or controlled by means of
    • software or an automated tool or algorithm applied by you as the provider or by a person acting on your behalf, or
    • an automated tool or algorithm made available on the service by you as the provider or by a person acting on your behalf.

Where content exemptions do not apply

User comments or reviews on user-generated content would be in scope of the Act. This includes user reviews or comments on third party sellers offering goods or services on online that meet the definition of user-generated content

If users can interact with any kind of content generated by other users, or can communicate through the service via online messaging (other than email. SMS, MMS or one to one aural communications), content exemptions do not apply to your service.

If regulated provider pornographic content is published or displayed on the service, and the service has links with the United Kingdom.

Where content exemptions do not apply

User comments or reviews on user-generated content would be in scope of the Act. This includes user reviews or comments on third party sellers offering goods or services on online that meet the definition of user-generated content

If users can interact with any kind of content generated by other users, or can communicate through the service via online messaging (other than email. SMS, MMS or one to one aural communications), content exemptions do not apply to your service.

If regulated provider pornographic content is published or displayed on the service, and the service has links with the United Kingdom.

Do any exemptions apply to the user-generated content on your online service? 

Select all that apply.

Under the Act, ‘content’ means anything communicated using an online service, whether publicly or privately. This can include:

  • data
  • music
  • oral communications
  • photographs
  • videos
  • visual images
  • written material or messages

A search service means an online service which is, or includes, a search engine that enables users to search more than one website and / or database.

If you provide a user-to-user service with a public search engine that you control, this is treated as a combined service. The search engine part of the combined service is subject to the duties that apply to search services.

Generative AI tools can also count as search services if they meet these criteria. For example, tools that answer user queries that include ‘live’ internet results from searching more than one website and/or database, whether in a standalone chatbot or another GenAI integration.

What does not count as providing a search service

If you provide a service that only searches one website or database - for example, where your website has a search feature to find content internally on your website – you are not considered to be providing a search service.

Using or embedding a search engine provided by a third party or external provider (for example, as a plug-in) does not make you the provider of that search engine, although the third party may still be providing a search service.

A search service means an online service which is, or includes, a search engine that enables users to search more than one website and / or database.

If you provide a user-to-user service with a public search engine that you control, this is treated as a combined service. The search engine part of the combined service is subject to the duties that apply to search services.

Generative AI tools can also count as search services if they meet these criteria. For example, tools that answer user queries that include ‘live’ internet results from searching more than one website and/or database, whether in a standalone chatbot or another GenAI integration.

What does not count as providing a search service

If you provide a service that only searches one website or database - for example, where your website has a search feature to find content internally on your website – you are not considered to be providing a search service.

Using or embedding a search engine provided by a third party or external provider (for example, as a plug-in) does not make you the provider of that search engine, although the third party may still be providing a search service.

Do you provide a search service?

Under the Act, a search engine is a service or functionality which enables users to search more than one website and/or database or, in principle, to search all websites and/or databases.

This includes so-called ‘vertical’ search engines. These are focused on a specific topic, product or service, and return results based on an underlying API or equivalent technical means. 

Generative AI tools that meet the above criteria may also be regulated as search services under the Act. Whether this is the case will depend on the technical operation of the tool, among other factors. 

Generative AI tools that generate response to user queries based on the search of more than one website and/or database are likely to meet the Act’s definition of ‘search engine’. Depending on how a generative AI tool is made available to users, it may be a ‘search service’ or a ‘combined service’. This includes tools that modify, augment or facilitate the delivery of search results on an existing search service. It also includes standalone GenAI tools, such as chatbots, that provide responses to users that include ‘live’ internet results and are generated based on the search of more than one website and/or database.

For example, in response to a user query about health information, a standalone generative AI tool might serve up live results drawn from health advice websites and patient chat forums; this would make it a search service regulated by the Act.It is possible for both standalone chatbots and ‘AI summaries’ on traditional search services to be regulated in line with the duties that apply to providers of search services.

Some online services are exempt from the Act.

If all or part of the service is an internal business service or is provided by a public body, education or childcare provider, exemptions will apply to that part of the service.

Internal business services



Internal business services are exempt if they are any of the following:

  • business intranets
  • content management systems
  • customer relationship management systems
  • database management systems
  • productivity and collaboration tools

External business services

An external business service includes any third-party tool, platform, consultancy, or technology solution that helps a business comply with safety regulations, mitigate risks, and protect users from harmful content. Examples include but are not limited to age-verification systems and moderation tools.

If a primary website or app uses such an external business service, that third party is also responsible for safety. Ofcom can hold both the main company and the outside provider legally responsible if they fail to keep users safe from illegal or harmful content.

Services provided by public bodies


Services provided by a public authority only in the exercise of its public functions are exempt if they are provided by any of the following:

  • UK Parliament
  • devolved legislatures such as Scottish Parliament, Senedd Cymru and the Northern Ireland Assembly
  • foreign government
  • public bodies in and outside of the UK

Services provided by UK education and childcare providers

Specific types of education and childcare services are exempt from the Act's regulatory duties if they are provided solely for the purposes of that education or childcare. Exempt categories listed in Part 2 Schedule 1 of the Act include childcare providers, further and higher education, and special education needs.

Some online services are exempt from the Act.

If all or part of the service is an internal business service or is provided by a public body, education or childcare provider, exemptions will apply to that part of the service.

Internal business services



Internal business services are exempt if they are any of the following:

  • business intranets
  • content management systems
  • customer relationship management systems
  • database management systems
  • productivity and collaboration tools

External business services

An external business service includes any third-party tool, platform, consultancy, or technology solution that helps a business comply with safety regulations, mitigate risks, and protect users from harmful content. Examples include but are not limited to age-verification systems and moderation tools.

If a primary website or app uses such an external business service, that third party is also responsible for safety. Ofcom can hold both the main company and the outside provider legally responsible if they fail to keep users safe from illegal or harmful content.

Services provided by public bodies


Services provided by a public authority only in the exercise of its public functions are exempt if they are provided by any of the following:

  • UK Parliament
  • devolved legislatures such as Scottish Parliament, Senedd Cymru and the Northern Ireland Assembly
  • foreign government
  • public bodies in and outside of the UK

Services provided by UK education and childcare providers

Specific types of education and childcare services are exempt from the Act's regulatory duties if they are provided solely for the purposes of that education or childcare. Exempt categories listed in Part 2 Schedule 1 of the Act include childcare providers, further and higher education, and special education needs.

Do any exemptions apply to your online service?

Select all that apply

The Act defines pornographic content as content produced solely or principally for the purpose of sexual arousal.

Pornographic content includes audio, image and video content. It does not include text or written content.

All online services that allow pornographic content are in scope of the Act.

The Act defines pornographic content as content produced solely or principally for the purpose of sexual arousal.

Pornographic content includes audio, image and video content. It does not include text or written content.

All online services that allow pornographic content are in scope of the Act.

Does your online service allow pornographic content?

Select all that apply.

This content is referred to as 'provider pornographic content' and services with this content are regulated under Part 5 of the Act. Types of online service that could include this content are pornography studios or paysites.

These types of online services could include pornography tube, cam or fan sites. They could also include generative AI tools purposefully designed to allow users to create pornography.

These types of online services could include a social media service that allow pornographic content. 
They could also include generative AI tools that can generate pornography alongside other types of non-pornographic content.

Pornographic content means content of such a nature that it is reasonable to assume that it was produced solely or principally for the purpose of sexual arousal.

Explicit depictions of sexual activity

  • Depictions of sexual acts such as masturbation, oral sex, penetration or ejaculation, including where these acts are performed with or on a sex toy.
    Content depicting full frontal nudity or depicting genitals, breasts or buttocks to elicit sexual arousal
  • Any content focusing on the breasts (with or without exposed nipple, depending on the context), genitals or buttocks or depicting full frontal nudity.
  • Videos showing an individual with exposed or partially exposed genitals, breasts or buttocks where they are using language associated with sexual activity or pornography (for example, ‘milf’ or ‘horny’), or strongly suggesting sexual activity (for example, moaning or simulating masturbation or oral sex).
  • An autonomous sensory meridian response (ASMR) video where sexually suggestive sounds are combined with full or partial nudity.

Fetish material

  • Depictions of an individual with their breasts, buttocks or genitals exposed depicting bondage, discipline, sadism and/or masochism (BDSM) or any other fetish depictions.
  • Depictions of an individual being whipped or restrained containing language associated with sexual activity or pornography (for example, ‘milf’ or ‘horny’), or other strong suggestions of sexual activity (for example, moaning or simulating sexual activity).

Explicit audio material

Audio material includes graphic descriptions of sexual activity and/or sexual soundscapes, (for example, moaning combined with rhythmic bodily contact sounds) that are sexual in nature and are intended solely or principally for sexual arousal.

Section 2 of our Guidance on content harmful to children (PDF, 802.06 KB) contains further details on what Ofcom considers to be pornographic content, including additional content and examples.

The online service you provide may publish pornographic content which is published or displayed on a service by the service provider itself, or an individual acting on behalf of the service provider. We anticipate the types of service that publish this content are studios and paysites.

This content is referred to as ‘regulated provider pornographic content’ and services with this content are regulated under Part 5 of the Act. 

Provider pornographic content includes:

  • pornographic content generated on the service by means of an automated tool or algorithm within the service
  • thumbnails of pornographic images or videos which are hosted on the server of a third party
  • pornographic content created by a user using generative AI tools made available by the service

Your service may allow user-generated pornographic content, which is any content that is generated by the user. This content may be generated directly on the service or uploaded/shared from elsewhere and can be encountered by other users.

All user-to-user and search services are regulated under Part 3 of the Online Safety Act.

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