Most of those don't seem like they would actually be much problem.

First, #2, #4, #5, #6, #9, and #10 only apply to sites that have more than 7 000 000 monthly active UK users or are "multi-risk". Multi-risk means being at medium to high risk in at least two different categories of illegal/harmful content.

If the site has been operating a long time and has not had a problem with illegal/harmful content it is probably going to be low risk. There's a publication about risk levels here [1].

For the sake of argument though let's assume it is multi-risk.

#1 means having someone who has to explain and justify to top management what the site is doing to comply. It sounds like in the present case the person who would be handling compliance is also the person who is top management, so not really much to do here.

#2 means written statements saying which senior managers are responsible for the various things needed for compliance. For a site without a lot of different people working on it this means writing maybe a few sentences.

#3 is not applicable. It only applies to services that are large (more than 7 000 000 active monthly UK users) and are multi-risk.

#4 means keeping track of evidence of new or increasing illegal content and informing top management. Evidence can come from your normal processing, like dealing with complaints, moderation, and referrals from law enforcement.

Basically, keep some logs and stats and look for trends, and if any are spotted bring it up with top management. This doesn't sound hard.

#5 You have to have something that sets the standards and expectations for the people who will dealing with all this. This shouldn't be difficult to produce.

#6 When you hire people to work on or run your service you need to train them to do it in accord with your approach to complying with the law. This does not apply to people who are volunteers.

#7 and #8 These cover what you should do when you become aware of suspected illegal content. For the most part I'd expect sites could handle it like the handle legal content that violates the site's rules (e.g., spam or off-topic posts).

#9 You need a policy that states what is allowed on the service and what is not. This does not seem to be a difficult requirement.

#10 You have to give volunteer moderators access to materials that let them actually do the job.

#11 This only applies to (1) services with more than 7 000 000 monthly active UK users that have at least a medium risk of image-based CSAM, or (2) services with a high risk of image-based CSAM that either have at least 700 000 monthly active UK users or are a "file-storage and file-sharing service".

A "file-storage and file-sharing service" is:

> A service whose primary functionalities
involve enabling users to:

> a) store digital content, including images
and videos, on the cloud or dedicated
server(s); and

> b) share access to that content through
the provision of links (such as unique
URLs or hyperlinks) that lead directly
to the content for the purpose of
enabling other users to encounter or
interact with the content.

#12 Similar to #11, but without the "file-storage and file-sharing service" part, so only applicable if you have at least 700 000 monthly active UK users and are at a high risk of CSAM URLs or have at least 7 000 000 montly active UK users and at least a medium risk of SCAN URLs.

[1] https://www.ofcom.org.uk/siteassets/resources/documents/onli...