Ministerial Pre-Approval Delays Innovation

The Minister can unilaterally designate data processing activities as requiring 28-day regulatory pre-approval before launch, with no clear limits on scope or parliamentary oversight. This creates unpredictable compliance barriers for digital startups and innovative technologies—a founder cannot know whether their new AI feature, personalization engine, or analytics tool will require weeks of regulatory review until the Minister issues an Executive Instrument. Combined with criminal penalties up to 5 years imprisonment for proceeding without approval, this provision creates personal risk for innovators that discourages experimentation and redirects digital innovation toward jurisdictions with more predictable frameworks.