Approval Gatekeeping Blocks Market Entry

This provision requires Authority approval before any database exposure through the platform (subsection 5), creating a government gatekeeping mechanism that could delay market participation and innovation. Organizations must develop APIs, implement "robust internal policies," and undergo testing and approval—all without relief mechanisms for disproportionate effort (unlike the preceding provision 6). The penalty structure combines criminal fines of 500-50,000 penalty units (subsection 6) with administrative penalties up to 10,000 penalty units (subsections 4, 7) for API-related failures, regardless of organization size or actual harm. For smaller businesses and startups, these compliance costs and approval delays create substantial market entry barriers that exceed typical regulatory approaches in OECD democracies for technical infrastructure requirements.