The absence of a coherent conceptual framework for online cultural crimes and the fragmentation of regulations within the Iranian legal system have resulted in ambiguity concerning the boundaries of criminal liability for users, managers, and technical hosts of platforms. This ambiguity leads to post-hoc criminal reactions and poses a threat to freedom of expression. Utilizing a descriptive-analytical method and a comparative approach, this research aims to redesign the model of platform liability based on risk management by comparing Iranian regulations with those of the European Union. The findings indicate that in the Iranian legal system, the liability of managers fundamentally relies on establishing mens rea (mental element) and effective intervention. In contrast, the European model, by transitioning from reactive to process-oriented liability, emphasizes transparency, complaint handling, and systematic risk assessment. Consequently, the results suggest that Iran requires a selective localization of the European model through the legal distinction of roles and the implementation of tiered administrative sanctions. Therefore, it is recommended that the legislator, by establishing an independent regulatory body and mandating periodic risk assessments for virtual platforms, shifts criminal policy from a punishment-oriented approach toward social and systemic prevention.