Criminal Penalties Chill Innovation Experimentation

This provision requires mandatory licensing before any ICT business activity and imposes criminal imprisonment (6 months to 2 years) plus fines for operating without a license. This creates a severe barrier for digital innovators, particularly startups and student entrepreneurs who typically experiment and iterate rapidly. Unlike OECD democracies where software developers and digital service providers operate without general business licenses, this provision criminalizes innovation experimentation unless licensing is obtained first. The discretionary "mode of operations" language creates legal uncertainty about compliance requirements, and the criminal penalties are grossly disproportionate to the low public risk posed by digital innovation activities. This contradicts the bill's regulatory sandbox (56) by requiring licensing before the sandbox can provide regulatory relief.