Comment by pembrook

No, not at all. You need to consider your service's risks against those seventeen categories once, and then review your assessment at least every year.

From the linked document above: "You need to keep a record of each illegal content risk assessment you carry out", "service providers may fully review their risk assessment (for example, as a matter of course every year)"

And links to a guidance document on reviewing the risk assessment[1] which says: "As a minimum, we consider that service providers should undertake a compliance review once a year".

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

> You just have to make individual value judgements every day on thousands of pieces of content

That's simply not true.

If you read that guidance, it wants you to have a moderation policy for 17 specific priority areas. You need prove you can demonstrate that you have thought about it. You need to have a paper trail that says you have a policy and that its a policy. You _could_ be issued with a "information notice", which you have to comply with. Now, you could get that already, with the RIPA, as a communications provider.

this is similar to running a cricket club, or scout club

For running a scout association each lesson could technically require an individual risk assessment for every piece of equipment, and lesson. The hall needs to be safe, and you need to prove that it's safe. Also GDPR, and safeguarding, background checks, money laundering.

> hold up to legal scrutiny from an activist court official

Its not the USA. activist court officials require a functioning court system. Plus common law has the concept of reasonable. A moderated forum will be of a much higher standard of moderation than facebook/twitter/tiktok.

Any competent forum operator is already doing all of this (and more) just without the government-imposed framework. Would the OP allow CSAM to be posted on their website? No. Would the OP contact the authorities if they caught someone distributing CSAM on their website? Yes. Forum administrators are famous (to the point of being a meme) for their love of rules and policies and procedures.