Page 21 - The Katten Kattwalk - Summer 2025 - Issue 29
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as requirements for governance and accountability, Ofcom is consulting on changes to the requirement
content moderation, and reporting and complaints. of blocking and muting user controls, as well as
disabling comments for services between 700,000
However, there are additional measures, including and 7 million monthly UK users, as opposed to only
age assurance processes and default settings for services with 7 million monthly UK users.
children. It is expected that the same “comply or The consultation closes on July 22, 2025, and is
explain” approach and the “forbearance period” of up available here. There is also an existing consultation
to six months would apply, as such by February 2026, on the draft guidance for how to protect women
platforms should have these measures implemented, and girls online, which closes May 23, 2025, and
failing which enforcement penalties of fines of up to is available here.
£18 million or 10 percent of global turnover, whichever
is higher, could apply to those in default. Phase 2 implementation of the OSA is well and truly
underway, and two additional risk assessments and
Next Steps
over 70 recommended measures will add significant
We advise that platforms should use their existing obligations to platform providers on top of their
Illegal Harms Risk Assessment to aid in constructing duties on illegal harms. The overlap of risks should
their Children’s Risk Assessment. Adult content make it easier for platforms, but considerations
providers who have yet to implement “highly effective should be made to ensure that these and overlapping
age assurance” will have to update their Children’s assessments complement each other and are
Access Assessment once it is implemented by July consistent.
2025; as such, it is unlikely they will need to conduct *Larry Wong, a trainee in our London office, contributed to this
a Children’s Risk Assessment. article.
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