Actually, the dub-con in this fic is because Draco's lost all his memories, he doesn't remember who he is, he doesn't know who Harry is either in the sense that he doesn't remember their history. All he knows is that Harry saved him and now makes him feel safe. There's no forceful action or coercion, because time and again it's Draco who initiates intimacy, but, you know, him not having memories and Harry do knowing, can be taken as dub-con.
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Actually, the dub-con in this fic is because Draco's lost all his memories, he doesn't remember who he is, he doesn't know who Harry is either in the sense that he doesn't remember their history. All he knows is that Harry saved him and now makes him feel safe. There's no forceful action or coercion, because time and again it's Draco who initiates intimacy, but, you know, him not having memories and Harry do knowing, can be taken as dub-con.