Investigation Alone Blocks License Renewal

The Authority can refuse to renew licenses based on ten grounds, including merely "an offence...being investigated" without conviction or charges (ground h). This violates the presumption of innocence and creates extreme business uncertainty for innovators. Combined with vague grounds like "poses a risk to public...security" and "fails to comply with a directive" (grounds f, j), the provision grants broad discretionary power without objective criteria. The lack of specified notice, hearing, or proportionality requirements before refusal, coupled with 40's severe criminal penalties for unauthorized transfer, traps businesses in an unpredictable licensing regime where they cannot easily restructure or exit—fundamentally undermining the flexibility essential for digital innovation and startup growth.