
BBK Manifesto 2025: protect children with strict enforcement of Online Safety Act
The new Online Safety Act must be effectively enforced with consistent penalties and clear rules if children are to be kept safe on the internet, BBK says.
As a lawyer representing survivors of child abuse, I know how vital it is that the law keeps pace with the risks that children face in the digital world. The internet is part of everyday life for children, but it is also a place where offenders can exploit them and where harmful material is only ever a few clicks away.
The Online Safety Act, passed in October 2023 and enforced from July 2025, was a long-awaited step towards tackling this danger. For the first time, online platforms have a legal duty to protect children from harmful and illegal content. This includes preventing access to pornography, removing harmful material such as suicide and self-harm content, and taking active steps to make their services safer.
Implementation and early signs of impact
Ofcom, the new regulator for online safety, is now enforcing the law. It has required all platforms that may be accessed by children to carry out formal risk assessments to identify where harm could occur and to take steps to address those risks. From 25 July 2025, platforms hosting pornography or other harmful material must have robust age checks in place, such as ID verification or other secure methods.
There are already signs that taking these steps can work. The Financial Times reports that visits to Pornhub from the UK dropped by almost half after age checks came in. This shows that strong regulation can have an immediate effect in limiting harmful exposure.
Where implementation is falling short
Despite this progress, the implementation so far has been uneven. Some platforms are still failing to meet the new requirements, and Ofcom has already launched enforcement investigations. Privacy groups have raised concerns that some forms of age verification could store unnecessary personal data, creating new risks for children and their families.
Smaller platforms, including those offering legitimate educational or community content, are struggling to comply and in some cases have chosen to block UK users entirely.
There is also a risk that the broad definition of “harm” in the Act could result in over-removal of legitimate resources, including content designed to help children understand and recover from abuse. The Guardian has reported that mental health support forums and peer discussion spaces may be wrongly targeted, leaving children without trusted sources of help.
What more needs to be done
If this law is to protect children in the way Parliament intended, implementation must be consistent, proportionate and genuinely child-focused. The following changes are needed:
- Clearer definitions of harm so that legitimate safeguarding, educational and mental health content is not wrongly restricted.
- Privacy-first age checks that prevent access to harmful material without creating unnecessary data risks.
- Increased enforcement resources for Ofcom so that platforms that fail to protect children are penalised quickly and meaningfully.
- Ongoing consultation with child protection experts, survivors, and families to ensure the law keeps pace with the tactics of offenders.
A call for political leadership
The Online Safety Act is an important foundation, but children remain at risk if enforcement is patchy or the focus shifts away from prevention. Politicians must hold platforms to account, ensure Ofcom has the resources it needs, and keep listening to those of us who see first-hand the devastating consequences of abuse.
Protecting children online is not a one-off task. It is an ongoing responsibility. The law is in place, but its success will be measured by how well it is implemented and by whether children are genuinely safer as a result.
This blog is part of our 2025/26 Manifesto for Injured People. At Bolt Burdon Kemp, we support injured people not only by winning their cases but by driving change. Guided by our clients’ experiences and partnerships with charities across the UK, we are raising awareness of the change we need to see to better support injured people. We will continue working with politicians from all parties to ensure injured people’s needs are not overlooked in Westminster or beyond. You can read our full manifesto here.