Q2 - Once classified as an SDF, can a company appeal or challenge that designation?

Answer

Yes.

• A company designated as an SDF can appeal to the Appellate Tribunal if it believes the classification is unnecessary or unfair.
• The Tribunal can review whether the government applied the criteria appropriately.

Example

If a mid-sized fintech company with 100,000 customers is suddenly notified as an SDF, it may argue that its scale does not justify the additional compliance burden.

It can challenge the notification through the Tribunal process.