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High Severity

Mandatory Licensing Blocks Market Entry

This provision requires all ICT businesses to obtain licenses before operating—covering everything from software development to infrastructure installation—and imposes criminal imprisonment (6 months to 2 years) for operating without a license. This creates disproportionate barriers to market entry that exceed norms in OECD democracies, where general ICT activities are typically unregulated. The Authority's discretionary power to "determine the mode of operations" creates operational uncertainty—businesses cannot know compliance requirements in advance, violating legal certainty principles essential for business planning and investment.