Me saying they don't need to do what pembrook claims, and aimazon saying they already do it, are not conflicting assertions. I didn't assert that competent forum operators are doing everything the new law requires. If you're asking me to "take a stab" at convincing you that forum operators are doing the hyperbolic FUD that pembrook posted, I won't. Take a stab at convincing you that they are already doing some large sub-set of what the law actually calls for, okay; I suspect internet forum operators already don't want their forums to become crime cesspits, or be taken overy by bots or moderators running amok, and that will cover quite a lot of it.

For comparison imagine there was a new law against SQL Injection. Competent forum operators are already guarding against SQL Injection because they don't want to be owned by hackers. But they likely are not writing down a document explaining how they guard against it. If they were required to make a document which writes down "all SQL data updates are handled by Django's ORM" they might then think "would OfCom think this was enough? Maybe we should add that we keep Django up to date ... actually we're running an 18 months old version, let's sign up to Django's release mailing list, decide to stay within 3-6 months of stable version, and add a git commit hook which greps for imports of SQL libraries so we can check that we don't update data any other way". They are already acting against SQL injection but this imaginary law requires them to make it a proper formal procedure not an ad-hoc thing.

> "What does good forum op record keeping look like?"

Good forum operators already don't want their forums to become crime cesspits because that will ruin the experience for the target users and will add work and risk for themselves. So they will already have guards against bot signups, guards against free open image hosting, guards against leaking user private and personal information. They will have guards against bad behaviour such as passive moderation where users can flag and report objectionable content, or active moderation where mods read along and intervene. If they want to guard against moderators power tripping, they will have logs of moderation activities such as editing post content, banning accounts. There will be web server logs, CMS / admin tool logs, which will show signups, views, edits. They will likely have activity graphs and alerts if something suddenly becomes highly popular or spikes bandwidth use so they can look what's going on. If they contact the authorities there may be email or call logs of that contact, there will be mod messages records from users, likely not all in one place. If a forum is for people dealing with debt and bankruptcy they might have guards against financial scams targetting users of their service such as a sticky post warning users, a banned words list for common scam terms - second hand sales site https://www.gumtree.com has a box of 'safety tips' prominently on the right warning about common scams.

Larger competent forums with multiple paid (or volunteer) employees would likely already have some of this formalised and centralised just to make it possible to work with as a team, and for employment purposes (training, firing, guarding against rogue employees, complying with existing privacy and safety regulations).

Yes I think the new law will require forum operators to do more. I don't think it's unreasonable to require forum operators once a year to consider "is your forum at particular risk of people grooming children, inciting terrorism, scamming users, etc? If your site is a risk, what are you doing to lower the chance of it happening, and increase the chance of it being detected? And can you show OfCom that you actually are considering these things and putting relevant guards in place?".

(Whether the potiential fines and the vagueness/clarity are appropriate is a separate thing).