Restrictive Licensing Blocks Market Entry

This provision establishes a mandatory licensing regime that creates substantial barriers to entry for authentication service providers. The non-transferability requirement [37(3)] prevents normal business transactions like mergers or sales without Agency approval, reducing business value and investor exit opportunities. The corporate-only restriction [37(1)] excludes individual entrepreneurs, while minimum capital requirements [37(5)(o)]—combined with the GHS 10 million insurance requirement in 38—create financial barriers that exclude smaller operators. These restrictions go beyond standard OECD practice for authentication services and will concentrate the market among large, well-capitalized players while deterring new entrants.