Mandatory Annual Audits Burden Startups

This provision requires all internet intermediaries and media houses with online locations to conduct annual human rights due diligence audits of their algorithmic systems and content moderation practices, without differentiation by company size or capacity. Unlike comparable frameworks in OECD democracies (such as the EU's Digital Services Act), this applies uniformly to small startups and large platforms alike, creating substantial compliance costs that disproportionately burden smaller entities. The provision lacks clear standards for what constitutes adequate compliance, creating uncertainty, while penalties of 500 penalty units plus 100 per day of continued non-compliance create significant financial exposure that could be existential for startups and small platforms.