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High Severity

Mandatory Security Infrastructure Costs

This provision requires all data providers to implement comprehensive security infrastructure including encryption systems, disaster recovery measures, business continuity planning, and incident response procedures. While these requirements align with international best practices, they impose substantial compliance costs that create barriers to entry for small and medium-sized enterprises, startups, and NGOs. The mandatory nature of participation (per 4) combined with the technical requirements in 7 and 9 creates a cumulative compliance burden that may exclude smaller organizations from the data ecosystem, limiting competition and innovation.