Permanent Platform Bans Stifle Innovation

The Authority can impose permanent bans prohibiting organizations from ever reapplying to the National Data Exchange Platform (subsection 3), creating irreversible market exclusion for digital businesses whose operations depend on data access. Combined with vague standards for what triggers a ban versus temporary revocation, this provision creates existential compliance risk that disproportionately affects startups and innovators lacking extensive compliance infrastructure. The lack of clear criteria distinguishing between remediable technical violations and conduct warranting permanent exclusion, coupled with no rehabilitation pathway, chills digital innovation by making platform participation an all-or-nothing proposition where a single compliance failure can permanently destroy a business.