Ofcom’s Year 1 review of Online Safety Act risk assessments identified recurring weaknesses in submissions from platforms and online services that extended beyond missing documentation. Across more than 100 submissions spanning over 10,000 pages of records, the regulator found organizations that often struggled to explain:
- how risk conclusions were reached
- what evidence supported those conclusions
- how controls reduced specific harms
- how assessments were maintained as services evolved
As organizations prepare for Year 2 submissions this summer, those findings provide a practical benchmark. With Ofcom moving from initial implementation into ongoing supervision and enforcement, providers should expect closer examination of how risk decisions are documented, supported, and maintained.
Resolver and Illuminate Tech have jointly developed a free assessment tool to give legal, compliance, governance, product, and Trust & Safety teams a practical way to benchmark their readiness against Ofcom’s Year 1 findings. Complete the short form to access the full assessment scoring document and start identifying gaps before your Year 2 submission immediately.
Assess five capabilities that support OSA Year 2 readiness
Use our free download to measure your online safety regulatory readiness across five capability areas. Each reflects Ofcom’s published findings and guidance shared during Resolver and Illuminate Tech’s Regulatory Readiness webinar: The Risk Assessment Standard: Maturing Your Approach for OSA Year 2 Submissions.
- Evidence for risk ratings: Are risk conclusions supported by documented evidence rather than assumptions?
- Harm-by-harm analysis: Are harms assessed individually using Ofcom’s harm categories rather than grouped under internal taxonomies?
- Control effectiveness: Can you demonstrate how specific controls reduce identified harms and how their effectiveness is monitored?
- Governance and accountability: Are accountability, ownership, and governance responsibilities clearly assigned across your compliance function?
- Record keeping: Could you demonstrate how your assessment has been maintained, updated, and evidenced throughout the year if requested by a regulator?
Each area is scored on a simple 0–2 scale, providing an overall readiness score out of 10. The result helps identify where additional evidence, documentation, or review may be needed before submission.
Why complete an OSA Year 2 readiness assessment?
One of the clearest messages from Ofcom’s Year 1 reviews was that risk assessments should not become static compliance documents. Suitable risk assessments should reflect an ongoing process that evolves alongside products, user behavior, emerging harms, and operational change.
The regulator also highlighted recurring issues, including unsupported low-risk ratings, assessments that relied on internal harm taxonomies rather than Ofcom’s harm categories, limited evidence supporting conclusions, weak governance and accountability, and records that were not maintained well enough to demonstrate how decisions had been made over time.
For a detailed analysis of the regulator’s observations and their implications for Year 2, read What Ofcom’s Year 1 Reviews Reveal About Year 2 OSA Risk Assessments.
Developed by Resolver and Illuminate Tech
Preparing a strong Year 2 risk assessment requires more than understanding regulatory requirements. It requires connecting day-to-day Trust & Safety operations with the evidence, governance, and documentation regulators expect to see.
Together, Resolver and Illuminate Tech bring complementary expertise to Year 2 Online Safety Act readiness. Resolver brings more than 20 years of Trust & Safety expertise, helping platforms identify online harms, investigate risk, collect operational evidence, and support effective mitigation. Illuminate Tech complements that expertise with OSCAR, its online safety compliance platform, which helps organizations structure, score, review, and maintain risk assessments against evolving regulatory requirements across multiple jurisdictions.
Download our OSA Year 2 Preparedness Assessment Checklist now to benchmark your current approach across five regulatory capability areas, identify potential gaps before summer submission deadlines, and support conversations across legal, compliance, governance, product, and Trust & Safety teams.
