I disagree, because the modernized act removed the due diligence defence, a legal standard for recognizing litigants' efforts to comply. This is quite exceptional.
In criminal law, there is a principle that if a company or a litigant, who is not necessarily a company, makes every reasonable effort to avoid breaking the law, a penalty will not apply, because the reasonableness of the effort has been demonstrated.
This defence has been removed from the act, which is quite exceptional because, on the one hand, the number of institutions subject to this section is limited as much as possible, and, on the other, their defence is also limited, whereas all other companies and institutions have no obligations or penalties.