Online safety The UK’s Online Safety Act (OSA) came into force on 26 October 2023. It applies to user-to-user services and search services as well as pornographic content services. For user-to-user services (the category most likely to be relevant to gaming companies), its requirements focus on online user-generated content. The OSA regulates illegal content using chat functionality, and that and certain specified types of user-to-user gaming services pose harmful content, focusing especially specific risks of harm. on content harmful to children on Games with the following services likely to be accessed by them. functionalities are likely to be In relation to the most harmful types in scope: of content likely to be accessed by children, age verification/estimation Text or voice chat functionality must be used (subject to a limited (team chat in team-based games, exception). or chat in large open servers which bring player avatars together). The OSA is very wide-ranging and There is an exemption for services Ofcom (the OSA’s regulator) estimates that only enable user-generated that around 100,000 online services content in the form of SMS, email could be in scope. Offline games or MMS messages and/or one-to- won’t be impacted, but Ofcom one live aural communications has highlighted that some games allow user interaction by creating or Games built around the manipulating avatars, objects and the generation and sharing of user- environment themselves, and/or by generated content. 152