Adult website lawyers
If you run an adult website, or you are setting one up, the single most important legal change in years is this: since 2025 the law has required you to check that every user is over 18 before they can see any pornographic content, and Ofcom, the regulator, is fining sites that have not done it. This article explains what that means in practice, then covers the contracts, policies and other legal documents an adult website needs. We have supported dozens of clients with their journey to set up adult websites and adults-only platforms, and we help existing sites get compliant when Ofcom writes.
Age checks under the Online Safety Act: what adult websites have to do now
Why choose Cohen Davis for legal advice and support in starting up an adult-only website
What legal documents are needed for an adult website
What other advice our lawyers give for setting up an adult website platform
Age checks under the Online Safety Act: what adult websites have to do now
If your website shows pornography and people in the UK can reach it, you have to check that each user is over 18 before they see it, and the check has to be one that actually works. That has been the law since 17 January 2025 for sites that publish their own content, and since 25 July 2025 for sites where users upload it, under the Online Safety Act 2023. It applies wherever your company is based. Most of the sites Ofcom has fined so far are run by companies outside the UK.
A tick box that says "I am over 18" does not count. Nor does an ordinary card payment, because people under 18 can pay for things online. Ofcom's list of checks that can count includes photo ID matching, facial age estimation, open banking, a check with the user's mobile network, a credit card check, a digital identity service and email-based age estimation. You do not have to use all of them. You have to use one that works properly, use it before any pornographic content can be seen, including previews and thumbnails, and keep a written record of what you use and why. Our guide to age verification for adult websites covers the duty, the records and Ofcom's fines in more detail.
Ofcom is not waiting to see who complies. It opened an enforcement programme in January 2025, wrote to hundreds of sites, and has been fining the ones that did nothing: £1 million against AVS Group in December 2025, £1.35 million against the company behind four sites in February 2026, and fines of £600,000 to £800,000 against others through 2026, with extra penalties on top for not answering Ofcom's questions properly. The maximum is £18 million or 10 per cent of worldwide revenue, whichever is greater, and Ofcom can ask a court to cut a site off from its payment providers and from UK internet providers. In September 2026 it opened an investigation into Pornhub's own age checks.
If Ofcom writes to you, do not ignore the letter. The first letter is usually a request for information with a deadline, and failing to answer it properly is a breach in its own right, which Ofcom has fined. We help sites work out whether the Act applies to them, choose an age check that fits the business, put the policy and the records in place, and deal with Ofcom when it writes. Most of this is straightforward once someone who knows the rules has looked at your site.
A tick box is not an age check. Ofcom has fined sites over £1 million for treating it as one.
Why choose Cohen Davis for legal advice and support in starting up an adult-only website
Our law firm is dedicated to helping clients develop adult websites that operate in an ethical manner because we believe that businesses in this industry, like any other, should be guided by responsible practices and legal compliance. By assisting our clients in creating ethical adult websites, we achieve several key objectives:
- Legal Compliance: Ensuring that your adult website adheres to all applicable laws and regulations is crucial to its success and sustainability. By helping our clients develop their adult-only businesses ethically, we help them avoid potential legal issues, fines, and penalties that could arise from non-compliance.
- Reputation Management: Having provided legal support for clients in the adult industry for nearly 20 years, we are convinced that an adult website which operates ethically can significantly enhance its reputation and credibility in the industry. This not only helps our clients attract a wider user base but also establishes trust and confidence among performers, models, partners, and other stakeholders.
- Performer and Model Protection: Ethical adult websites prioritise the well-being and fair treatment of performers and models. By guiding our clients in establishing policies that safeguard the rights and interests of these individuals, we contribute to creating a more responsible and humane work environment in the industry.
- User Privacy and Security: Ethical adult websites are committed to protecting the privacy and security of their users. By assisting our clients in developing robust data protection measures and policies, we help ensure that user information is handled responsibly and securely.
- Social Responsibility: Our law firm believes that businesses should contribute positively to society, and this includes the adult entertainment industry. By promoting ethical practices in adult website development, we contribute to fostering a more responsible and transparent industry that respects the rights and interests of all parties involved.
- Long-term Success: Ethical adult websites are more likely to achieve long-term success and stability. By prioritising legal compliance, user trust, and fair treatment of performers and models, our clients can build a sustainable business model that is better equipped to adapt to industry changes and evolving legal requirements.
In summary, our law firm's commitment to helping clients develop ethical adult websites stems from our belief in the importance of responsible business practices, legal compliance, and social responsibility. By guiding our clients in this direction, we contribute to the growth and sustainability of their businesses while fostering a more transparent and accountable adult entertainment industry.
What legal documents are needed for an adult website
Depending on the nature of the adult website or platform that you are intending to create, all of some of the legal documents below would be relevant: Setting up an adult website involves navigating various legal, ethical, and compliance requirements to ensure the protection of all parties involved and to provide a secure and transparent user experience. Here is a breakdown of why you would need each of the following documents when setting up an adult website:
Model Agreement:
This contract outlines the terms and conditions between the website owner and the models who provide content for the site. It specifies the rights and responsibilities of both parties, including payment terms, content ownership, confidentiality clauses, and release of liability. A clear model agreement helps ensure that models are aware of their obligations and that the website owner has the necessary permissions to use the content legally.
Agent Agreement:
If you plan to work with agents who represent models or help source talent for your website, an agent agreement is essential. This document sets forth the terms of the collaboration, including commission rates, payment terms, and the responsibilities of both the agent and the website owner. It helps to establish a clear working relationship and prevent misunderstandings or disputes.
Terms of Use of Website:
The Terms of Use define the rules and guidelines that users must follow when accessing and using your adult website. They outline user rights and responsibilities, limitations of liability, and any applicable restrictions, such as age requirements. Having a comprehensive Terms of Use webpage in place helps protect the website owner from potential legal disputes and sets clear expectations for users.
Privacy Policy:
A Privacy Policy is a legal requirement for websites that collect, store, or process personal information from users. It informs users about the types of data collected, the purpose of the data collection, how the data is used, and any third-party sharing. A transparent Privacy Policy not only ensures compliance with privacy laws but also helps build trust with users who value their privacy.
Data Protection and Data Requests Processes:
This document outlines the procedures for handling data protection issues, including data breaches, data subject access requests, and data erasure requests. It helps ensure that your adult website follows best practices for data protection and complies with applicable laws.
Website Acceptable Use Policy:
This policy sets guidelines for acceptable behaviour on your adult website. It may include rules regarding prohibited content, user interactions, and any legal restrictions. The policy helps maintain a safe and respectful environment on your site, while also protecting the website owner from potential liability due to user misconduct.
Cookies Policy:
A Cookies Policy is required for websites that use cookies or similar technologies to track user behaviour, preferences, or other data. This policy informs users about the use of cookies, the types of cookies used, and how they can manage their cookie preferences. Compliance with cookie regulations is crucial to avoid potential fines or penalties.
Models Rules of Conduct:
This document outlines the expected behaviour and professional standards for models working on your adult website. It may include guidelines regarding punctuality, communication, attire, and interactions with other models and staff members. Establishing clear rules of conduct helps create a professional and respectful working environment and sets the tone for the level of professionalism expected from all parties involved.
Identification and Age Verification Policy:
Adult websites that UK users can reach have to use a highly effective age check under the Online Safety Act 2023, as explained above. This policy records which check you use, how it is applied before any pornographic content is shown, and how you keep the evidence Ofcom can ask for. It is the document Ofcom will want to see first.
Intellectual Property Rights Statements and Agreements:
Intellectual property rights agreements clarify the ownership and usage rights of content created for your adult website. They protect your website from copyright infringement claims and ensure that you have the necessary permissions to use the content legally.
Health and Safety and Ethical Policies:
Establishing health and safety guidelines and ethical policies for your adult website helps ensure the well-being of performers, models, and staff members. These policies demonstrate your commitment to maintaining a safe and responsible work environment and can help protect you from potential legal issues or reputational damage.
Not all these documents might be necessary for every type of adult website. We recommend that you book a consultation with one of our expert lawyers who will advise you on which legal documents your specific website may require.
What other advice our lawyers give for setting up an adult website platform
When setting up an adult website platform, consulting with us is likely to provide you with invaluable insights and guidance on a range of topics. In addition to advising on the legal documents and ethical considerations mentioned earlier, you can expect us to offer you hands-on advice to help you navigate various other aspects of establishing your start-up, such as:
- Business Structure: We will help you choose the most appropriate business structure for your adult website platform, taking into account factors such as liability protection, tax implications, and ease of management.
- Licensing and Permits: Depending on your jurisdiction, you may need specific licenses or permits to operate an adult website. We will help you identify and obtain any required licenses, ensuring your website complies with all relevant regulations.
- Content Compliance: Adult websites must adhere to strict content guidelines to avoid legal issues related to obscenity, exploitation, and copyright infringement. We will help you develop content policies and procedures that ensure compliance with these guidelines.
- International Regulations: If you plan to operate your adult website platform in multiple countries or regions, we will help you navigate the complex web of international laws and regulations governing adult content, privacy, and data protection.
- Advertising and Marketing: We will advise you on the legalities of advertising and marketing your adult website platform, ensuring your promotional efforts comply with relevant laws and do not infringe on the rights of third parties.
- Payment Processing: Adult websites often face challenges when it comes to securing reliable payment processing services. With our experience at hand, we will help you understand your options and assist in negotiating agreements with payment processors, ensuring your business can process transactions securely and efficiently.
- Record-Keeping Requirements: Depending on your jurisdiction and the nature of your adult website platform, you may be required to maintain specific records related to your adult website platforms, such as age verification documentation or model release forms. We will advise you on the necessary record-keeping practices to ensure compliance with these requirements.
- Ongoing Legal Support: As your adult website platform grows and evolves, you may encounter new legal challenges or require updates to your existing policies and agreements. We value our long-term relationship with our clients and you can be assured that we will provide you and your platform with ongoing support, ensuring your business remains compliant and adapts to changes in the industry and legal landscape.
Call us free on 0800 212 7211 to book a consultation.
Frequently asked questions
Does the Online Safety Act apply to my adult website if my company is not in the UK?
Yes, if the site has links with the UK. That means a significant number of UK users, or the UK being one of the markets the site aims at, under section 80 of the Act. Where the company is registered makes no difference. Most of the sites Ofcom has fined so far are run from outside the UK.
What counts as a highly effective age check?
Ofcom accepts photo ID matching, facial age estimation, open banking, a check with the user's mobile network, a credit card check, a digital identity service and email-based age estimation, provided the method is set up and used properly. A tick box, a date-of-birth field, or a payment that people under 18 can make do not count.
Do I have to check age before the home page, or only before videos?
Before any pornographic content can be seen. That includes previews, thumbnails and free samples on the landing page. The test in the Act is that children are not normally able to come across the content at all, so a site that shows explicit thumbnails before the check has not met it.
What happens if my site has no age check?
Ofcom can fine you up to £18 million or 10 per cent of your worldwide revenue, whichever is greater, and it has been doing so: fines in 2025 and 2026 have ranged from £50,000 to £1.35 million, with extra penalties for not answering Ofcom's questions. It can also ask a court to order payment providers and UK internet providers to stop serving the site.
Ofcom has written to my site asking for information. What should I do?
Answer it, fully and by the deadline. Failing to respond properly to an information request is a separate breach, and Ofcom has added penalties of up to £100,000 for it on top of the main fine. We help sites reply, and where a site is not yet compliant we set out a plan to Ofcom for getting there, which is a far better position than silence.
What records do I need to keep?
A written record of the age check you use and why it is highly effective, and, for sites where users upload content, a children's access assessment that is repeated at least once a year. Ofcom can ask for these at any time, so they need to exist before the letter arrives.
