This is a masterclass in “pick your one thing in life and focus on that.”
I’m highly pessimistic that the spirit of this legislation, which I wholly support, can ever be enshrined in law with enough specificity that it works the way we want it to in the cases where we need it to, without becoming a truly undue burden on small developers or forcing all publishers to just work around it in some way: like taking everything to a subscription model going forward.