New age assurance requirements: what does this mean for children’s online safety?

2025 has been described by Ofcom, the UK regulator, as the ‘Year of Action’ when it comes to implementing the Online Safety Act. And, last month, the Protection of Children Codes entered into force – meaning that platforms in scope are now required to comply with certain safety measures if their services are likely to be accessed by a child.

Most notable is that platforms are now required to use highly effective age assurance to prevent children from accessing harmful content, including pornography, and ensure age-appropriate experiences online. This builds on measures to prevent all users from accessing illegal content – including Child Sexual Abuse Content – as set out in the Illegal Harms Codes.

What is age assurance?

The term ‘age assurance’ covers both age estimation (age range based on behaviour and physical characteristics) and age verification (determining an individual’s actual age). Ofcom’s Highly Effective Age Assurance (HEAA) Guidance outlines how different types of services can implement HEAA, including specific requirements regarding technical accuracy, robustness, reliability and fairness.

Methods capably of being effective include photo-identification matching, facial age estimation and email-based age estimation. Self-declaration is not a form of age assurance which is highly effective, and platforms must not host or share content encouraging use of VPNs to get around the new requirements.

Why is age assurance important to the IWF?

Establishing the age of a user, and whether the user is a child or young person (under 18) or not, is foundational to the success of measures which ensure age-appropriate experiences and prevent exposure to illegal or inappropriate content.

We particularly welcome the requirement for platforms to ensure children cannot access pornography. Exposure to this content at an inappropriately early age can normalise harmful sexual behaviours and is increasingly being linked to growing sexual violence against girls and young women. Many pornography providers  - both big and small - have now implemented age assurance measures across their services and Ofcom has asserted that “it will be harder for children in the UK to access online porn than in any other OECD country.”

Additionally, age assurance enables platforms to tailor user experiences and take proportionate measures relating to the design or operation of the service to effectively mitigate and manage the risks of harm to children in different age groups. IWF had previously raised concerns about a “one-size-fits-all” approach to under 18s, noting the importance of age-appropriate experiences for different age groups. Following a consultation on the draft measures, we were pleased to see the regulator take on board IWF’s call for age-appropriate access to content, features, and functionalities, by making adjustments to the content moderation and recommender settings.

Public response to age assurance       

Contrary to a lot of recent reports, YouGov polling has found that a majority of the public (69%) support the new rules requiring age verification to access websites that may contain pornographic material, including 46% who do so “strongly”.

The Online Safety Act Network, of which IWF is a proud member, has published an explainer which addresses some of the misconceptions that have taken hold since the duties came into force on 25 July 2025. For example, there have been some concerns following the surge in VPN downloads, which highlights the need for Governments to work together to introduce standardised and enforceable age assurance measures. However, there is a lack of evidence on the age of users downloading VPNs, and, regardless, children will be unable to view harmful content involuntarily. 

Next steps

Ultimately, these Codes are an important step to minimise harm and deliver more positive outcomes for children.

But there is still more to be done. For example, further consideration should also be given to ensuring that adults are not able to pose as children, which we know is often a tactic used by offenders to groom children into sharing ‘self-generated’ imagery.

IWF Membership

At the IWF, we believe the Online Safety Act has the potential to transform child safety online.

Companies looking to ensure their platforms comply with the provisions set out in the UK Online Safety Act and contribute to making the internet a safer place for all can apply to join the Internet Watch Foundation as Members.

Members can gain access to a range of cutting-edge datasets and alerts, to protect their platforms, brands and customers from known child sexual abuse material content, as well as early insights into threats and trends. 

Learn more about our Membership and how you can join us by visiting our website or contacting our team directly at [email protected].

For information on complying with the Online Safety Act, head to Ofcom’s guide for services.