Ofcom announced on 9 July 2025 that it has contacted certain providers of “user-to-user” and “search” services that are “likely to be accessed by children”, requesting that they submit records of their children’s risk assessments (“CRA”) by 7 August 2025 or face enforcement action.

As noted in our previous blogpost here, in-scope providers have until 24 July 2025 to complete their first CRA—meaning that Ofcom is initiating enforcement on risk assessments early.

Since our last blog post, on 4 July 2025, Ofcom’s final Children Codes of Practice for user-to-user and search services (“Codes”) completed the Parliamentary process and were published. As anticipated, in-scope providers have until 25 July 2025 to comply with children’s safety duties.

Against this backdrop, Ofcom has made clear its intention to continue introducing new measures to implement the Online Safety Act and strengthen the existing Codes and illegal content codes of practice (which were published on 24 February 2025). On 30 June 2025, Ofcom published new proposals aimed at preventing illegal content from going viral, detecting the source of illegal content and protecting children against the risks of livestreaming. Stakeholders have until 20 October 2025 to submit feedback on the proposals. 

The Covington team is working with a range of clients on OSA compliance, including preparing risk assessments, and engaging with Ofcom on the OSA. Please reach out to a member of the team if you need assistance with preparing a CRA and/or complying with the Codes.

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Photo of Shona O'Donovan Shona O'Donovan

Shóna O’Donovan is an associate in the technology regulatory group in the London office. She advises clients, particularly in the technology industry, on a range of data protection, e-privacy, intermediary liability and online content issues under EU, UK, and Irish law.

Shóna provides…

Shóna O’Donovan is an associate in the technology regulatory group in the London office. She advises clients, particularly in the technology industry, on a range of data protection, e-privacy, intermediary liability and online content issues under EU, UK, and Irish law.

Shóna provides strategic advice to companies on complying with data protection, e-privacy and online content laws, as well as defending organizations in cross-border, contentious investigations and regulatory enforcement before EU and UK regulators. In this context, she has represented clients in responding to regulatory requests relating to their compliance with the GDPR, the ePrivacy Directive, the Digital Services Act, the Audiovisual Media Services Directive and the Online Safety Act 2023. She also regularly advises clients on how these laws intersect with one another.

In her current role, Shóna gained experience on secondment to the data protection team of a global technology company. In a previous role, she spent seven months on secondment to the European data protection team of a global social media company.

Shóna co-leads Covington’s pro bono work with the Schools Consent Project, and regularly delivers workshops on sexual consent in schools across London. She also regularly provides pro bono advice to non-profits on complying with data protection laws.

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Photo of Jane Pinho Jane Pinho

Jane Pinho co-chairs Covington’s Entertainment and Media Industry Group and is a partner in the Technology and Communications practice and the International Business Reorganization practice. She has advised international streaming services on their content acquisition strategies, on new product launches and global expansions…

Jane Pinho co-chairs Covington’s Entertainment and Media Industry Group and is a partner in the Technology and Communications practice and the International Business Reorganization practice. She has advised international streaming services on their content acquisition strategies, on new product launches and global expansions, and on media regulation and licensing for the past decade.

Jane works with media industry leaders with global operations, including streaming services, video games and interactive entertainment companies, and social media platforms. She has particular experience advising in relation to the creation, acquisition, and distribution of digital content in the UK and Europe, in relation to the multi-territory launch, expansion, monetization and marketing of digital media products and services and in relation to compliance with the UK’s broadcasting, on-demand, video-sharing platform and online safety regimes, representing clients facing regulatory scrutiny. She also has experience advising media and technology companies on UK and EU consumer protection law, including on an investigation by the EU Commission and the Consumer Protection Co-operation Network.

Jane is also a key figure in Covington’s International Business Reorganization practice. She has managed global post-acquisition business reorganizations, pre-sale and pre-spin business separations and tax reorganizations for companies with substantial global footprints for more than a decade.

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