Tribunal Lacks Business-Critical Independence

The Minister appoints all tribunal members without competitive process or parliamentary oversight, while the tribunal's staff are Agency employees and its budget comes from Agency income—creating financial and administrative dependence on the very body whose decisions it reviews. For businesses facing license denial, suspension, or revocation by the Agency, this structurally compromised appeal mechanism provides little meaningful protection. The lack of tenure protections, conflict-of-interest rules, or removal safeguards means tribunal members serve at ministerial pleasure, undermining the independent review necessary for business confidence in regulatory fairness.