Universal Registration Requirement Burdens Market Entry

This provision mandates that all data controllers must register with the Authority before processing any personal data, creating a compliance barrier for market entry that affects startups, SMEs, and new businesses disproportionately. When combined with the extensive application requirements in 66—including business details, data categories, purposes, recipients, transfer destinations, and security measures—this creates significant administrative burden and compliance costs before businesses can commence operations. The lack of proportionality (no exemptions for small-scale or low-risk processing) means even minimal data handling triggers registration obligations, potentially slowing innovation and market participation, particularly for resource-constrained entities.