As the Consultation Paper accompanying the Draft Regulations notes, the requirement in s 19 of the Copyright Regulations 2017 (the Regulations) for a service provider to designate “a person” to be its representative to send and receive notices may give rise to practical difficulties for service providers such as universities that administer multiple entities. This issue does not appear to arise with respect to Carriage Service Providers.
With the expansion of the safe harbours to include the new class of service providers there is a clear need for the Regulations to be sufficiently flexible to ensure that service providers that administer multiple entities can comply with the obligation in s 19.