Unconstrained Database Classification Power

The Minister can unilaterally declare any "classes of information" relating to broadly-defined "economic or social wellbeing" as critical electronic records, triggering mandatory registration and compliance obligations in 51 and subsequent provisions. With no statutory criteria, consultation requirements, or appeal mechanisms, businesses developing data-driven services cannot predict which databases will be designated critical, creating regulatory uncertainty that deters investment in digital innovation. The vague scope could encompass virtually any commercially valuable database—from e-commerce platforms to fintech services to AI training data—subjecting them to unpredictable compliance costs and operational restrictions without proportionality safeguards.