Prelicensing Barrier for Digital Services

Section 33(c) requires all new telecom-related services involving personal data processing—including AI-powered customer service applications—to obtain prelicensing approval through joint evaluation by the NCA and Data Protection Commission before market entry. This creates a substantial barrier to digital innovation by requiring regulatory approval before launching services, rather than the notification/registration approach used in most OECD democracies. Combined with the extremely broad definition of "Application" in 28 (covering "any software-based mechanism, digital platform, or computer program"), this requirement could capture many routine digital services. The lack of specified approval timelines, clear criteria, or appeal mechanisms creates regulatory uncertainty that will deter startups, delay product launches, and reduce Ghana's competitiveness in the digital economy.