Arbitrary License Revocation Threatens Registrars

The Registry can suspend or revoke registrar licenses on vague grounds like "misconduct which harms consumers or the public interest" or "failure to meet ongoing requirements prescribed by the Minister"—without requiring notice, hearing, written reasons, or appeal rights. This creates severe regulatory uncertainty for registrars as businesses: they cannot clearly understand what conduct triggers license loss, cannot defend themselves before revocation, and face undefined compliance obligations that can change at ministerial discretion. Combined with 19's mandatory .gh domain requirement, this gives the Registry unchecked power to exclude businesses from the domain registration market without basic procedural safeguards standard in OECD regulatory frameworks.