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High Severity

Catch-All Licensing Stifles Innovation

The provision establishes seven mandatory license categories for ICT businesses, including a catch-all "any other categories" provision (36.1(g)) that the Authority can expand unilaterally through regulations (36.3). This creates regulatory uncertainty about what activities require licensing, as innovators cannot predict whether new products or services will trigger licensing requirements. Combined with 34's criminal penalties (imprisonment for unlicensed operation), this framework creates severe risk for innovators testing new technologies. The citizenship-only requirement (36.4) further restricts innovation by excluding foreign entrepreneurs and investors entirely from Ghana's ICT sector.