The Online Safety Act – Outlook For 2025

The Online Safety Act

The 2025 Outlook for UK Online Safety: What Every Service Must Know

The Online Safety Act 2023 (OSA) introduced sweeping regulations aimed at reducing illegal harms and improving user protection across digital platforms. As we approach 2025, new laws will come into force, increasing the obligations of providers and online search platforms while enhancing Ofcom’s enforcement powers.

With implementation deadlines set throughout the year, including key dates such as March 2025, July 2025, and October 2025, organizations must be proactive in meeting their duty to prevent illegal content and online harms. This article provides a detailed outlook for 2025, covering the policy changes, compliance requirements, and strategies in-scope services must adopt.

Ofcom’s Expanding Enforcement Powers

Overview

The OSA became law after it received royal assent on 26 October 2023, granting Ofcom the authority to regulate platforms and providers. As of 2025, Ofcom’s enforcement role will expand significantly, particularly concerning:

  • Risk assessments and compliance obligations
  • Transparency reports submission
  • Issuing draft transparency notices for non-compliance
  • Business disruption measures for serious violations

Key Dates for Enforcement

Date Regulatory Action
December 2024 Platforms must prepare for compliance with new measures
February 2025 Draft assessment guidance will be finalized
March 2025 New enforcement rules come into force
July 2025 Stronger penalties introduced for major violations
Early 2026 Full-scale implementation and final reviews

Ofcom’s enforcement approach will involve issuing fines based on worldwide revenue, banning services, and forcing tech companies to implement stricter systems and processes to reduce the risk of their services being used in a way that is illegal.

Stricter Rules for Illegal Content and Online Harms

The Online Safety Act 2023 requires providers to assess and mitigate risks associated with illegal or harmful content, including:

  • Terrorism
  • Fraud and financial scams
  • Pornography and age-inappropriate content
  • Harmful misinformation and disinformation

Platforms likely to be accessed by children must implement stricter age assurance measures. This aligns with the protection of children’s codes, ensuring that minors do not interact with illegal content.

Compliance Measures for Providers

✔ Risk assessment within three months of designation as an in-scope service
✔ Implement systems and processes to monitor and remove illegal harms
✔ Publish transparency reports to demonstrate compliance
✔ Adopt the protection of children codes to enhance safety measures

Failure to comply could lead to severe enforcement actions, affecting business operations and revenue streams.

The Duty of Care and Compliance Obligations

The OSA introduces a strengthened duty for digital services to comply with new regulations designed to protect users, particularly vulnerable groups.

Providers must determine whether their service is likely to pose risks related to:

  • Exposure to illegal content
  • Dissemination of harmful materials
  • The risk of such services being used for exploitation

Risk assessments will be required before platforms can legally operate within the UK’s regulatory framework. Additionally, platforms must conduct a children’s risk assessment within three months if they fall under the register of categorized services.

Transparency Reports and Draft Guidance for 2025

Mandatory Reporting

By early 2026, Ofcom’s enforcement will require platforms to publish transparency reports detailing:

  • Illegal harms detected and removed
  • Actions taken to comply with draft guidance
  • Updates on implementing systems and processes

The first OSA compliance reports will be due March 2025, with further assessment guidance in April 2025. These reports must include data on measures taken to protecting women and girls, as well as general user safety.

New Regulations for Online Search Platforms

Online search platforms such as Google and Bing must introduce secondary legislation to protect users from illegal harms. This includes:

  • Stricter moderation of illegal or harmful search results
  • Proactive fraud detection mechanisms
  • Removal of criminal content before it reaches users

By October 2025, search engines must comply with stricter regulations. Platforms will also need to integrate risk assessments that align with the UK’s new policy framework.

Business Disruption and Compliance Risks

With new laws coming into effect, businesses must comply to avoid penalties. The threshold for enforcement will be stricter, with a focus on:

  • Implementing systems and processes to prevent the spread of illegal content
  • Ensuring that services are used in a way that aligns with the OSA
  • Risk assessment guidance in April 2025 to help businesses adapt

Non-compliance may result in:

✔ Financial penalties based on worldwide revenue
✔ Restrictions on services being used within the UK
✔ Forcing providers to remove harmful content as soon as possible

2025-2026 Roadmap for the Online Safety Act

The roadmap for OSA compliance includes multiple deadlines, starting from December 2024 through early 2026.

Phase Implementation Step
December 2024 Final compliance preparations
Published in January 2025 Early draft codes released
February 2025 Additional consultation with stakeholders
March 2025 Initial provisions come into force
April 2025 Release of risk assessment guidance
July 2025 Platforms must apply updated measures
October 2025 Enforcement of register of categorised services
Early 2026 Full regulatory compliance required

These updates reflect the evolving policy and legal landscape in the UK’s digital ecosystem.

Conclusion

The Online Safety Act 2023 is ushering in a new era of digital compliance. Providers and online search platforms must align with Ofcom’s enforcement rules, ensuring that illegal harms and harmful content are minimized.

Key Takeaways:

✔ Platforms must complete a risk assessment within three months of designation
✔ New laws will require systems and processes to reduce risk
✔ Non-compliance could result in business disruption and financial penalties

With provisions coming into force around key dates in 2025, platforms must comply with these new laws to avoid Ofcom’s enforcement actions.

Would your business be ready for implementation in 2025?