Mandatory Pre-Registration Blocks Digital Startups

This provision requires all data controllers to register before processing any personal data, creating a licensing barrier that departs from international best practices (GDPR uses accountability frameworks, not mandatory pre-registration). For digital startups, this means navigating registration bureaucracy before launching services, slowing time-to-market and imposing fixed compliance costs that disproportionately burden resource-constrained innovators versus established enterprises. Combined with 76's requirement for Authority approval of high-risk processing, this creates a dual gatekeeping system where the Authority can effectively block market entry through registration denial or delay, without clear approval standards or timelines.