Narrow Exemption Criteria Exclude Legitimate Businesses

The exemption requires entities to meet all three conditions simultaneously: exclusive hosting outside Ghana, no targeting of Ghanaian users, AND multinational status with foreign digital jurisdiction. This excludes many legitimate business scenarios—regional African businesses serving multiple countries, diaspora enterprises with Ghanaian customers, and foreign companies with Ghanaian subsidiaries all fail to qualify. Combined with discretionary approval ("may grant") and vague criteria like "does not target Ghanaian users," businesses face uncertainty about whether they qualify. When paired with severe penalties in 21 (annual fines up to 10,000 penalty units, license revocation, and public procurement exclusion), this narrow exemption framework creates substantial barriers to foreign investment and regional business integration.