@networkstring @Fonant
I think that Anthony's got it right.
s11 - the duty to do a children's risk assessment - applies only to
Chapter 4 sets out when a service is "likely to be accessed by children".
https://www.legislation.gov.uk/ukpga/2023/50/part/3/chapter/4
It requires a provider to do a "children's access assessment".
If the site has highly-effective age assurance, then the provider may conclude that the site cannot be accessed by children.
If the site can be accessed by children (as Anthony acknowledges), the question is whether it is "likely" to be accessed by children.
That's the second limb of the children's access assessment, the "child user condition".
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