Overly Broad Software Definitions

The provision defines "Application" so broadly that it captures virtually any software that uses telecommunications infrastructure or "complements or augments" core services—potentially extending licensing requirements to general software development, AI services, and digital platforms. The definition of "Application services" is incomplete (ends with "means" without completion), creating legal uncertainty about regulatory scope. Combined with 27's prelicensing requirement for "telecom-related services involving personal data," these definitions could require software developers to obtain joint NCA-DPC approval before launching products—a barrier to innovation that doesn't exist in most democracies and would significantly slow digital product development cycles.