UK OSA Section 12(4)-(6) - Highly effective age verification or age estimation for primary priority content (regulated user…
Use highly effective age assurance technology to determine whether users are children, considering proportionality and Ofcom guidance
Where this comes from
Provision: Section 12(4)-(6) - Highly effective age verification or age estimation for primary priority content (regulated user-to-user services)
Instrument: UK Online Safety Act 2023
Citation: Online Safety Act 2023, c. 50, s 12(4)-(6) read with s 12(3)(a) and s 61; s 12(5) (terms-of-service exception); s 13(5)-(6) (parts of a service children can access); s 37 (likely to be accessed by children)
Text version: Online Safety Act 2023 c. 50, revised text as displayed on legislation.gov.uk on 2026-09-21 ('up to date with all changes known to be in force on or before 21 September 2026'), including the amendments made by the Crime and Policing Act 2026 in force from 29 June 2026 (S.I. 2026/689) and s 66 in force from 7 April 2026 (S.I. 2026/262). The as-enacted text is superseded.
Who it applies to
It applies when all of these are true:
- Service is likely to be accessed by children under 18
- Service requires/offers account registration
- Youngest user age is Under 13, 13-15 or 16-17
What engineering work it implies
- Age Gate with Self-DeclarationCovers part of it
Simple age verification using date of birth entry with validation and session storage.
- Parental Consent and ControlsCovers it fully
Implement verifiable parental consent for users under threshold age with ongoing parental controls.
Sample acceptance criteria Landfall generates for this obligation:
- Age gate appears before accessing age-restricted content/features
- DOB input uses dropdowns (not free text) to reduce typos
- System calculates age from DOB, not from user-entered age
- Age is stored and doesn't need to be re-entered on each visit
- Age verification cannot be bypassed by direct URL access
Questions people ask
- Does UK OSA Section 12(4)-(6) - Highly effective age verification or age estimatio… apply to my service?
- It applies when Service is likely to be accessed by children under 18; Service requires/offers account registration; Youngest user age is Under 13, 13-15 or 16-17.
- From when does this apply?
- UK OSA Section 12(4)-(6) - Highly effective age verification or age estimatio… applies from 10 January 2024. Its current status is: in force.
- What engineering work does this imply?
- Typically: Age Gate with Self-Declaration, Parental Consent and Controls.
Find out whether this one lands on you
Landfall's pre-scan answers the applicability question above for your product in minutes, then turns every obligation that applies into traceable engineering tickets with a citation chain your auditors can follow.
Not legal advice. Landfall maps regulatory obligations to engineering work for planning purposes. Its verdicts are not legal advice and create no attorney-client relationship — verify with qualified counsel before relying on them.