Page 18 - The Katten Kattwalk - Summer 2025 - Issue 29

LONDON LEGAL LENS

Byte-Sized Protection:

Keeping Kids Safe Online,

One Risk Assessment

at a Time

By Terry Green

he protection of children on the internet has been a huge focus in the media
lately, from calls for protection of children online from bereaved parents
travelling to the United States to calls from the Duke and Duchess of Sussex
Tfor more to be done.
On April 24, the UK Office of Communications (Ofcom) published a major policy
statement containing six volumes and eight finalized guidance as part of its Phase 2
implementation of the Online Safety Act (OSA) for protecting children from harm online.
Given the media coverage and Ofcom’s policy statement, the protection of children
online is under even greater scrutiny than before.
As part of OSA Phase 1 implementation, Ofcom has shown that it is serious with its
enforcement on platforms’ OSA duties. In this article, we explore what additional
measures will be implemented to keep kids safe online.
The Children’s Access Assessment (Deadline of April 16, 2025)

From April 16, 2025, all platforms regulated under the OSA (i.e., platforms anywhere
in the world with links to the United Kingdom) are expected to have completed their
Children’s Access Assessment. Platforms need to assess (at a minimum every 12 months)
whether it is likely for children to access their platform, with considerations of:
1. Is it possible for children to normally access the service; and

2. Either:

a. Are there a significant number of children who are users of the service; or

b. Is the service of a kind likely to attract a significant number of children?
Satisfying these questions will result in the outcome that it is likely for children to
access the assessor’s platform. While this is relatively easy to complete, it demonstrates
the expectation from the OSA and Ofcom for all providers to consider the impact and
risk of children’s access on their platform even if they provide adult-only content (such as

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