The UK's safety act reached video apps in stages

What was announced or recorded

The Online Safety Act 2023 received Royal Assent on 26 October 2023, creating duties for providers of 'user-to-user' services, defined in the Act as services where content generated or uploaded by one user may be encountered by another, and for search services. A companion government explainer, as retrieved on 16 September 2026, states that Ofcom is the appointed regulator, with powers including fines of up to 18 million pounds or 10 per cent of qualifying worldwide revenue, whichever is greater, and that protection-of-children codes were laid in Parliament on 24 April 2025 with a three-month window for services to complete children's risk assessments by 24 July 2025.

What the documents establish

The Act's own text ties duties to a functional definition, user-to-user interaction and content encounter, rather than to a content genre, so a scope question for a drama app turns on whether it carries user-generated comments, reviews or user uploads alongside its licensed episodes, not on whether the episodes themselves are dramatic content. The explainer's list of in-scope service types names social media, video-sharing platforms, forums, dating services and messaging services explicitly, but does not name subscription video-on-demand or curated episode catalogues as a category, which leaves a curated, non-interactive drama app's status less directly stated by these two documents than a platform with open user comment sections.

Announced versus delivered

Royal Assent delivered a statute with duties on the books; the explainer's 2025 dates show delivery arriving in stages afterward, codes laid, a risk-assessment deadline, and a stated 'summer 2025' point for the child-safety regime to take full effect, rather than all at once at Assent. A dossier should not treat the 2023 Assent date as the date duties became enforceable; the explainer's own later dates are what mark when specific obligations came due.

What to watch

Editorially, the open question for a curated drama catalogue is whether Ofcom's own categorisation guidance, expected to be consulted on in early 2026 per the explainer, treats a comment-free episode app as out of user-to-user scope, or whether any interactive feature, such as ratings or a discussion thread, is enough to bring it in.

• Does the app carry any user-to-user feature, such as comments or uploads, alongside its episodes?
• Which specific 2025 duty date applies to the service in question, rather than the 2023 Assent date?
• Has Ofcom issued guidance placing curated video-on-demand catalogues inside or outside scope?

A statute's Assent date marks when a duty was created in law, not when it began to bind a specific service, and the two dates can sit nearly two years apart, as they do here.