Discretionary License Revocation Chills Innovation

The Agency can suspend or revoke authentication service licenses based on the vague standard of being "satisfied" that requirements were not met, without clear objective criteria for what constitutes non-compliance. Combined with immediate suspension authority for up to 90 days and the following provision's 24-hour surrender requirement with criminal penalties for directors, this creates severe regulatory uncertainty that discourages market entry and investment in authentication services—foundational infrastructure for Ghana's digital economy.