Vague Licensing Refusal Criteria

The Authority can refuse ICT business licenses based on undefined grounds including "public interest," "public safety," or "public security"—highly discretionary terms that could be applied arbitrarily to reject innovative business models or new market entrants. Combined with the bill's requirement that all ICT businesses must obtain licenses (34), this creates significant uncertainty for startups and innovators who cannot predict whether their business will be approved. The provision also allows refusal for "failure to comply with a directive of the Authority"—a circular ground that could be used to reject applications without clear standards, effectively giving the Authority gatekeeping power over digital innovation in Ghana.