Ofcom’s Children’s Risk Assessment

From 25th July 2025, games businesses that offer user-to-user services accessible by UK children must comply with new safety requirements under the Online Safety Act. Ofcom’s Protection of Children Codes of Practice set out detailed expectations for how services should reduce the risk of harm to children online.

If your game includes user interaction or communication features, it is likely to be in scope. By 24 July, you are required to complete and document a Children’s Risk Assessment. This assessment must:

• Identify potential risks of harmful content to children;
• Assess the likelihood and potential impact of those risks;
• Set out the measures your service will take to mitigate them;
• Ensure that your approach is regularly reviewed and kept up to date.

Examples of mitigation measures include:

• Safer algorithms and content recommendation systems
• Effective human and automated moderation
• Simple and accessible reporting tools
• Clear, age-appropriate terms and guidance
• Strong internal processes and governance

It’s important to note that compliance is risk-based: what’s expected will depend on your service’s size, functionality and risk profile. You’re not required to follow the Codes word-for-word, but if you take an alternative approach, you must be able to prove your measures are equally effective in protecting children.

Ukie is actively engaging with Ofcom to ensure the final guidance recognises the specific features of video games, including age gating, session-based communication and parental controls, that already play a role in reducing harm. The Protection of Children Codes form part of a wider implementation of the Online Safety Act, with further compliance requirements expected in the months ahead.

To help members navigate these complex obligations, we’ve worked with Lewis Silkin to produce an exclusive member only factsheet.

This guide summarises what the Codes mean for your business, the actions required before the deadline, and how to demonstrate ongoing compliance. Members with questions about the Codes or wider regulatory developments, please contact Ukie or or our legal partners at Lewis Silkin.