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High Severity

Unpredictable Regulatory Compliance Requirements

The Agency can "determine the nature, process and undertakings necessary" for its functions and make determinations "as the Agency finds just and equitable" without defined criteria or standards. This creates regulatory unpredictability that prevents businesses from conducting meaningful compliance planning or risk assessment. Companies cannot budget for compliance costs, assess market entry viability, or predict what obligations will be imposed when the Agency exercises broad discretion based on undefined "just and equitable" standards. This uncertainty deters investment and creates barriers to market participation, particularly for startups and SMEs lacking resources to navigate unpredictable regulatory requirements.