Member

The question of resources also applies to the high bar for eligibility and the consequent administrative burden. Despite some reductions in assessment periods, the administrative burden on smaller organisations remains significant. Concerns persist that the eligibility requirements, particularly those around demonstrating expertise and governance arrangements, could still exclude smaller, newer or less well-resourced organisations, even if they have valid concerns and fresh perspectives on emerging online harms. There is a real risk of organisations investing time and resources only to be rejected on eligibility grounds. DSIT expects fewer than 100 organisations to meet the criteria, which is a higher number of potential complainants than in other super-complaint regimes—such as the police super-complaint system, which has only 16 eligible organisations. This further highlights the potential work- load for Ofcom.