Skip to content
High Severity

Vague Criminal Standards for Businesses

The provision criminalizes "fail or neglect to comply with the terms and conditions of a licence" without defining which violations are criminal versus administrative or what constitutes criminal "neglect." Given the mandatory licensing regime applies to all ICT businesses, this creates unquantifiable legal risk—businesses cannot determine which compliance failures might result in criminal prosecution and imprisonment (6 months to 2 years) versus administrative penalties. The vagueness gives the Authority broad discretion to pursue criminal charges for routine regulatory violations, deterring market entry and investment as businesses cannot conduct meaningful risk assessments or implement adequate compliance programs.