They’re not directly equivalent because Lemmy is a service (like HTTP, phpBB, or e-mail protocols), not a singular service provider (like Reddit or Gmail). The law would likely have to be enforced on individual instances.

In a practical sense, it would probably be easier to have the compliance mechanism built into the Lemmy project itself… but what do I know, I’m not a lawyer, and lawyers generally know/care fuck all about the technicalities of emerging technologies.