The short answer to what appears to be the actual question is that in the united-states, the required effort provides a defense to complying with a subpoena when it is "unduly burdensome." Fed.R.Civ.P. 45(d)(3)(A)(iv).
This is a flexible standard that means different things in different contexts. Imagine, for instance
I have no knowledge of Telegram's setup, but let's just imagine that they came into court with credible evidence that complying with a subpoena would cost them $1 million. If you had sent the subpoena in connection with a small-claims lawsuit over a $200 bill from your plumber, the recipientTelegram would have a good case that it's unduly burdensome, because nonparties shouldn't have to take on substantial burdens to resolve relatively trivial disputes.
But if the subpoena came from the government as it sought to disrupt and prosecute a terrorist network on the verge of launching a domestic attack, that argument is going to be a lot weaker.