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High Severity

Vague Paid Content Compliance Burden

This provision requires digital advertising intermediaries, influencers, and content creators to take "reasonable steps" to ensure paid content complies with the entire Act—including provisions on misinformation, hate speech, and private facts—but provides no clear guidance on what constitutes "reasonable steps." The penalty structure (100 penalty units initially, plus 100 per day of continued default) creates severe financial exposure that accumulates rapidly, particularly problematic for startups and smaller platforms. This vague compliance obligation combined with escalating daily penalties creates significant barriers to market entry, discourages innovation in advertising technology and creator monetization, and could chill the digital creator economy by making brand partnerships and sponsored content legally risky.