BP, The article clearly shows the application process is free. "The pass is free, and will be easy and straightforward to obtain."
I would expect those that breach the rule to pay the full costs of their breach, no issues with me there.
An interesting, for me anyway, position was one I found myself in some years back. On two stakeholder groups for consultation of rules. One rule wanted to minimize and control the use toxic paints (antifouling). The other wanted to increase controls on fouling of vessel hulls. This was over 10 years ago and not connected with current requirements how