Universal Registration Requirement Burdens All Businesses

This provision requires every entity processing personal data to register with the Authority before commencing operations, transforming data protection from a compliance framework into a licensing regime. Unlike GDPR and most international jurisdictions that rely on accountability principles, Ghana mandates ex-ante registration for all data controllers regardless of business size, processing scale, or risk level—a small shop collecting customer phone numbers faces the same registration obligation as a large-scale data processor. The provision imposes administrative penalties of 2,000-100,000 penalty units (potentially GHS 200,000-1,000,000+) for registration failures, with subsection (1) containing a drafting ambiguity that creates uncertainty about maximum exposure. Combined with 76's additional approval requirements for high-risk processing, this creates substantial barriers to market entry, ongoing compliance costs, and operational delays that disproportionately burden startups, SMEs, informal sector businesses, and foreign companies testing the Ghanaian market.