Yes. Some of these requirements—any changes to consent and anything that requires changes to a system—can have a very long runway, particularly in larger, complex organizations. Even printing out new consent forms and ordering paper can be very time-consuming, as well as getting access to legal experts to make sure you understand the requirements, particularly if there are differences between federal and provincial requirements—and technology resources as well. There are scarce resources that need to be shared among all organizations to be able to understand requirements to comply.
On October 31st, 2023. See this statement in context.