Both countries want to keep children away from porn. The UK asks whether your age check is “highly effective”. Germany asks whether your content sits inside a closed user group. Side by side, here is what each test looks at, and what a site serving both can build.
In the UK, according to Ofcom (checked 19 October 2026), services that publish their own pornographic content have had to use “highly effective” age assurance under Part 5 of the Online Safety Act since 17 January 2025, and user-to-user and search services that allow porn fall under the Part 3 children’s safety duties, which apply since 25 July 2025. Ofcom’s test is about the check: does it actually establish that this visitor is an adult, and does it come before anything explicit?
In Germany, the Interstate Treaty on the Protection of Minors in the Media (JMStV) says porn may only be offered online inside a closed user group, a geschlossene Benutzergruppe, that ensures only adults get in. The test is about the group: is the person identified, and is it the same person every time they come back? The Commission for the Protection of Minors in the Media (KJM) publishes the criteria it uses for such systems.
Ofcom’s guidance looks at each visit: for example, a visitor passes a facial age estimate and gets in. The model the KJM describes usually has two stages: identify the person once, reliably, then authenticate them on every later visit, typically with a login. A one-off check without a lasting, personal access is not what the KJM describes as a closed user group.
Ofcom names kinds of method that can be highly effective: open banking, photo-ID matching, facial age estimation, mobile-network checks, credit-card checks, email-based age estimation and digital identity services. It also names what it says can’t: self-declaration, a tick box, a date-of-birth field without evidence, or an 18+ line in your terms. Ofcom says the service stays responsible even when a provider runs the check.
Germany doesn’t publish a list of methods in the same way. The KJM assesses age-verification systems and publishes its criteria and the systems it has looked at. Many sites therefore choose a provider whose product the KJM has assessed, and ask which assessment covers it. The KJM’s criteria describe identification plus authentication on later visits, which a facial estimate alone doesn’t provide.
Some points are the same in both countries, and they are the ones our scanner looks at most:
If people from both countries visit your site, one common setup follows the German two-stage model:
The German model also puts the check before any content, which is what Ofcom’s placement guidance looks at. The reverse is different: a one-off facial estimate with no account is among the methods Ofcom lists as capable of being highly effective, while the KJM describes a closed user group as identification plus authentication on every visit.
In the UK, Ofcom enforces the Online Safety Act, including against sites based abroad that UK users can reach. In Germany, the state media authorities enforce the JMStV, with the KJM as their central body for these questions. Both look at what a visitor from their country actually meets.
Open your site in a private window and ask two questions. Did anything explicit load before you proved your age, including thumbnails, a trailer or a preview image? And when you come back tomorrow in a new private window, does the site know who you are, or does it just ask again? The first question is what Ofcom’s placement guidance looks at. The second is roughly where the KJM’s criteria start.
From a UK or German connection we load your site like a first-time visitor, record what kind of check appears, what loads before it and whether files open around it. For the UK, the gate-type judgement follows Ofcom’s method list. For Germany, our report says plainly that we don’t check the two-stage closed user group yet: a result without findings is not a confirmation that your site meets German law. Whether a specific system meets the KJM’s criteria is a question for the KJM’s assessments and your lawyer.
Not legal advice. This page summarises and links to primary sources; it does not tell you what the law requires of your specific site. Related: Age checks in the UK · Age checks in Germany · Is a “Yes, I’m 18” button enough?
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