When to add age verification

This isn’t legal advice

Rather, this is a playbook on where to enable our age verification tools on your site.

Unfortunately, the law here is new and still being tested, and Ofcom’s guidance isn’t clear about where the line sits between what’s OK and what isn’t.

We’d love to give you firmer answers, but we can’t be more certain than the regulator is on their own rules.

For certainty about your own site, speak to a lawyer who advises on age verification and the Online Safety Act.

The rule in a nutshell

If your site shows pornographic images or video to UK visitors, you must put it behind “highly effective” age verification. This comes from Part 5 of the Online Safety Act 2023, and it applies to individuals running their own site and big platforms alike.

• Pornographic means content it’s reasonable to assume was made solely or principally for sexual arousal. Nudity isn’t required: posing, framing and what a photo implies all count.
• Text on its own is excluded. Text with emojis or non-pornographic GIFs is also excluded. Adding an image to a text block may bring it into scope. As such, judge the entire block as a whole, and consider re-organising your site if needed.
• “Highly effective” means the check has to be technically accurate, robust, reliable and fair. Ticking “I’m over 18”, debit card checks and warnings don’t count.
• You also need records. Keep a written record of how you age-verify, and publish a short statement summarising it. We provide a feature in your Privacy setting to help - this includes links to our provider AgeVerif (our built-in age assurance provider).

What’s OK

These can usually sit on your site without age verification.

Content	Why it’s OK
Your intro, bio and personality text	Text only, even if flirty or suggestive
Descriptions of services, experiences and kinks in words	Text only is out of scope, however explicit
Rates, booking info, travel, deposits and cancellation policy	Practical information
Reviews and testimonials, as text	Text only
Blog posts in words	Text only, as long as the images in them are also OK
Face portraits and fully clothed photos	Not made principally to arouse
Everyday outfits, going-out looks, swimwear in an ordinary setting	Not made principally to arouse
Booking form, contact form, WhatsApp button	No explicit content

You can still choose to gate text if you so wish.

Borderline

These depend on the individual photo.

Content	Leans OK when…	Leans “gate it” when…
Lingerie photos	Face and upper body, relaxed or smiling pose	The crop centres on your bum, breasts or crotch
Posed boudoir shots	Soft, editorial feel, you’re the subject	Posed to display your body to the viewer
Rear or over-the-shoulder shots	Shows your outfit and hair	Focuses on your bum, or you’re bent over
Cleavage	A glimpse in a portrait	The main subject of the shot
Implied nudity (covered with hands, sheets)	Artistic, not sexualised	Framed to tease
Point-of-view angles	Ordinary selfie angles	Shot from above while you kneel, or anything suggesting a sex act
Text blocks with an image inside	The image is OK on its own	The image is borderline: the whole block comes into scope
Your hero or banner image	A blurred version of a safe photo	Any borderline photo, even blurred

Note

Ofcom’s rules state a fully clothed photo can still be porn if it clearly implies a sex act - for example someone’s hand in your hair while you kneel. We don’t agree with this, but please judge what the photo suggests, not just what it shows.

Age verify!

Always turn on age verification for blocks showing any of these.

Content	Notes
Nudity: breasts, genitals or a bare bum	Includes partial and see-through clothing
Sexual acts, real or simulated	Includes solo content
Photos implying a sex act	Even if you’re fully clothed
Close crops of intimate areas	Even through clothing or lingerie
Explicit video or GIFs	Any length, including short clips and previews
Galleries or carousels mixing safe and explicit photos	The block is only as safe as its spiciest photo. Split them into separate collections instead - you can do this from your Collections manager.
Explicit audio	Voice notes and clips made to arouse

Never publish

Never publish anything showing:

• someone under 18
• anyone who hasn’t consented
• strangulation or suffocation
• incest, real or pretend.

Age verification doesn’t make these legal. They’re criminal offences to possess, let alone publish. Such material will lead to your site being terminated, and we will report to the relevant authorities. We take a zero tolerance policy here.

A few tips on organising your site with age verification in mind

The easiest way to approach this problem is that if you are in doubt, add age verification on the whole site.

If you’d prefer not to do this, we have a few tips:

• Put unverified blocks above verified ones. This ensures visitors can read your intro, see a safe photo and find your rates before reaching anything gated. This makes verification a chance to see more, rather than a hard wall.
• Keep a safe teaser collection. Split your photos into a public collection that’s clearly OK and a separate gated one. Point your carousels and previews at the safe one only.
• Use a safe photo for your hero. It’s the first thing every visitor sees, so pick something unarguably OK, even if you blur it.
• Write friendly locked-content text. Say what’s behind the gate and that verifying is quick, rather than just “18+ only”.

And - a few notes on our platform’s specifics:

• Accounts you create yourself skip online verification, once you’ve recorded how you checked them.
  • Only create a client account after you’ve checked their photo ID in person. When you create or edit the account under Users, answer How was this user checked if they were over 18? by picking Had session or Checked ID, or Other to write your own note. Don’t keep a copy of the ID.
  • Until you answer it, the account is flagged Age check not recorded in your Users list and still has to verify online.
• Don’t worry about SEO. We ensure that search engines can still index the text in age-verified blocks, so gating text won’t hide you from Google.
  • This doesn’t apply to AI assistants (which are increasingly used for search).
• Visitors only verify once. Verification is saved to a cookie, or to the visitor’s account if they’re signed in, so they won’t be asked again on every page.
• Private galleries are covered. Visitors need an account to see them, and accounts that sign themselves up must verify their age. You can assume everyone viewing a private gallery is verified.
• SophieBot can help reorganise your collections and site, but please verify its work like any AI tool.

Turning on age verification

1. In your admin panel, go to Site content → Age & login and paste your AgeVerif public key. Leaving it blank turns age verification off.
2. On the same page you can edit the Locked content heading and Locked content text visitors see on gated blocks.
3. To gate everything, set Whole site requires age verification to On. Visitors who haven’t verified or logged in then see only the age verification message on every page (your privacy notice stays open), and every photo is blurred for them. Search engines can still index your pages.
4. To gate individual blocks instead, open a block in the Page editor and tick Requires age verification. The block is blurred until visitors verify (or log in), and shows an 18+ badge in the editor. Use Message position (Middle or Top) to choose where the message sits over the blurred block. It stays on screen as visitors scroll, and neighbouring locked blocks share one message.
5. Under Settings → Privacy, your generated privacy notice covers age verification automatically once it’s turned on.

Checklist before you publish

• Every block with nudity, explicit or sexually implied images has age verification on
• No gallery or carousel mixes safe and explicit photos
• Your hero image is a safe photo
• Unverified blocks sit above verified ones, so the page makes sense before verifying
• Any image inside a text block is OK on its own, or the block is gated
• Client accounts you create are only for people whose ID you’ve checked in person
• You’ve written down how you age-verify, and published a short statement about it

Sources

• Online Safety Act 2023, Part 5
• Ofcom: guidance on highly effective age assurance
• Ofcom: overview of regulated services
• decoded.legal: the OSA’s porn provisions

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A final note from us

We heavily disagree with how Ofcom have gone about the implementation of the OSA. Ofcom do not provide us with an assured list of providers, and there isn’t an easy way to verify the user of a device is over 18.

This has made age verification into a weapon that works to advantage big platforms over independent workers - given a large platform only has to perform age verification once.

We believe this doesn’t work to make children safer, rather it creates a system that entraps workers like yourself into making content and advertising your services on exploitative platforms rather than your spaces, which you control.

We hope some day reason is found in the walls of Riverside House.