Trying to track the staggered implementation of the UK Online Safety Act 2023 (“OSA”)? You are in safe hands here. See the latest updates and key dates below.

18 September 2025 – Ofcom issues provisional notice of contravention to launches investigation into whether Itai Tech Ltd has failed to comply with the Online Safety Act 2023

Ofcom has provisionally found that Itai Tech Ltd may have breached Section 81 of the Online Safety Act by failing to use effective age verification or estimation to prevent children from accessing pornographic content. A provisional notice of contravention was issued on 17 September 2025, also citing failure to respond to a statutory information request under Section 102(8). Itai Tech now has 20 working days to respond before Ofcom makes a final decision.

16 September 2025 - Ofcom consults on guidance for preserving information about a child’s online activity following their death

Under the OSA, Ofcom can support coroners’ or procurators fiscal investigations into child deaths by issuing Coroner Information Notices to request data from online services. The Data (Use and Access) Act (DUAA), effective from 30 September 2025, requires Ofcom to issue Data Preservation Notices (DPNs) to tech firms to preserve a child’s data and activity following their death, preventing deletion or alteration before a Coroner Information Notice is issued.

Ofcom has launched a consultation on proposed updates to the Online Safety Information Powers Guidance, focusing on the use of DPNs. The consultation also covers minor revisions to the Coroner Information Notices guidance, informed by early experience handling coroners’ requests. Responses are open until 28 October 2025.

11 September 2025 - Ofcom investigates 22 more porn sites under new age-check rules

Ofcom has launched formal investigations into four companies running 22 pornography websites to assess compliance with the Online Safety Act’s new age-check requirements. These sites were prioritized due to their high user numbers, increased traffic since the 25 July deadline, and the risk of harm they pose. Together, they attract over 8 million unique UK visitors each month.

8 September 2025 - Online safety laws to strengthen to protect people of all ages from self-harm content

The government will amend the Online Safety Act to make content encouraging or assisting serious self-harm a ‘priority offence’ for users of all ages, expanding protections beyond children to include adults. Tech companies will be legally required to proactively detect and remove this harmful material before it reaches vulnerable individuals. The new regulations are expected to come into force 21 days after parliamentary approval, anticipated this autumn.

8 September 2025Ofcom launches consultation on online safety super-complaints guidance

Ofcom has launched a consultation on super complaint guidance. Under the Online Safety Act, expert organisations representing users or the public can raise a ‘super-complaint’ with Ofcom. Super-complaints allow such expert organisations to present robust evidence and facts about the most significant online harms and restrictions on free expression arising on regulated online services. Ofcom’s draft guidance on super-complaints explains what super-complaints are, their role in online safety regulation, eligibility criteria for organizations looking to bring a super-complaint, rules and procedures for making a super-complaint, and the typical process Ofcom follows in relation to super-complaints. Responses to the consultation are to be submitted by 3 November 2025.

1 September 2025Ofcom launches third consultation to implement the online safety fees regime

Ofcom has launched its third consultation on guidance intended to aid providers in making a fees regime notification under the Online Safety Act 2023 (Fees Notification) Regulations 2025. The consultation sets out Ofcom’s proposed guidance on the process for preparing and submitting fees-related notifications. The guidance also outlines the details and substantiating evidence that should be included and provides instructions for accessing and using the fees portal which will be used to submit fees-related notifications. Ofcom is accepting responses to the consultation until 1 October 2025.

The online safety fees regime is expected to come into force later this year. Under the regime, regulated service providers with qualifying revenues above a specified threshold will be required to contribute an annual fee to Ofcom to cover the costs of discharging its new online safety functions.

28 August 2025Investigation into Duplanto Ltd and its compliance with the duty to prevent children from encountering pornographic content through the use of age assurance

Ofcom has opened an investigation into Duplanto Ltd, which runs a pornographic website, and will examine whether there are reasonable grounds to believe that the provider has failed, or is failing, to prevent children from encountering pornographic content on its site. This is now the 5th live investigation related to the new age-check requirements under the Online Safety Act, following 4 other investigations announced immediately after the new requirements came into force on 25 July 2025.

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