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High Severity

Unpredictable Audit Authority Deters Innovation

The Minister has unconstrained discretion to direct audits of critical database operators without specified triggers, standards, or timelines, creating regulatory uncertainty that deters database innovation and investment. Businesses cannot reliably plan for compliance costs or operational disruptions, and the lack of appeal mechanisms or independent oversight means operators have limited recourse if audits are conducted arbitrarily. This creates barriers to market entry and scaling, particularly for startups and smaller operators who lack resources to respond to unpredictable audit demands.