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High Severity

Strict Liability for Honest Mistakes

This provision prohibits misinformation (false information "regardless of the intention to mislead") and disinformation (false information intended to mislead). The critical problem is the strict liability standard for misinformation - people can be held liable for unintentional falsehoods even when they genuinely believed the information was true. This deviates from international democratic norms where liability for false speech typically requires at least negligence or recklessness. Combined with broad definitions of "false or inaccurate information" and "prejudicial to public interest," this creates a chilling effect on legitimate speech - journalists reporting on developing stories, academics presenting preliminary findings, citizens sharing information they reasonably believed accurate, and whistleblowers disclosing information they believe reveals wrongdoing all face potential liability for honest mistakes. While 23 provides a defense if due diligence "could not have revealed" the falsehood, this creates a practical burden to conduct verification or face liability.