Undefined Licensing Criteria Create Business Uncertainty
The provision requires written applications with "prescribed form," "supporting documentation," and "prescribed fee" but delegates all substantive approval criteria to the Authority's discretion through unspecified guidelines. Combined with 79's prohibition on unlicensed service provision (penalties up to 50,000 penalty units), this creates a mandatory licensing regime where businesses cannot predict what qualifications, documentation, or costs will be required for approval. This regulatory uncertainty makes market entry planning impossible, increases compliance costs, and creates discretionary gatekeeping that could favor established players over new entrants in the data protection services market.