Citizenship Requirement Blocks Foreign Investment

Section 36.4 restricts all ICT business licenses to Ghanaian citizens or wholly citizen-owned entities, categorically excluding foreign investors, joint ventures with foreign partners, and international ICT companies from Ghana's digital economy. This protectionist barrier contradicts ECOWAS free movement principles and potentially violates WTO commitments, isolating Ghana's ICT sector from global capital, expertise, and technology transfer. Combined with the catch-all licensing category (36.1(g)) and the Authority's unilateral power to create new license categories through regulations (36.3), this creates both a citizenship wall and regulatory uncertainty about what activities require citizen-only licensing—deterring both domestic and foreign investment in Ghana's digital sector.