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High Severity

Sanctions Stacking Threatens Platform Viability

The provision permits imposing multiple simultaneous sanctions (correction orders, content removal, access blocking, license suspension, administrative penalties, criminal penalties) without clear proportionality limits or graduated penalty structure. Platforms could face existential sanctions like license revocation or access blocking combined with other penalties for a single violation, even after voluntarily removing content. When combined with 63's strict liability standard (sanctions "even if the person does not know" information is false), this creates unpredictable liability exposure that will drive excessive compliance costs, over-moderation, and market exit by smaller platforms and startups.