I am concerned that, without rapid, targeted intervention at legislative level, the OSA will have a unwarranted and detrimental effect on the plurality of sites and services available to people in the UK, and impede and put at risk people running sites and services in the UK, for no material impact on the safety of people in the UK.
[…]
The OSA has an adverse unwarranted impact on a plethora of providers of small, low-risk services.

We are talking here of bloggers with comments sections, a small hill-walking forum or runners club, a discussion board for a scout troup or local gardening society, of people running a small fediverse service or code forge, or even a family’s shared calendar or photo-sharing tool.

These services are often run by volunteers, in their spare time. Many services have run for years without a problem.

These providers - primarily but not exclusively in the UK, since that is where the OSA’s risk and burden is felt most strongly - are subject to obligations to carry out multiple risk assessments, to adopt or amend terms of service, and to have in place OSA-specific policies and processes.

Worse, the OSA is not written in an accessible, intelligible way.

It is as if the OSA overlooked entirely people who run their own services for friends or family, or who have created small community services.
[…]
There is a simple solution to this unnecessary complexity and regulatory burden:

• Exclude from the scope of Part 3 small (e.g. 15,000 monthly users or fewer, with clarity needed around “user”) services, where the provider has a reasonable belief that the service is of no or low risk; and

• Simultaneously giving Ofcom the power to impose a positive obligation on a provider, by notice to the provider, to engage with some or all of the OSA if, acting on evidence, Ofcom considers that the service poses more than low risk and imposing an obligation to engage is necessary and proportionate to that risk.