Vague Revocation Standards Create Business Uncertainty

The Agency can suspend or revoke licenses based on the discretionary standard of being "satisfied that" a provider has "failed or ceased to meet any of the requirements" without defining objective criteria for this determination. Combined with 30's 24-hour surrender requirement and criminal penalties for directors (up to 2 years imprisonment), this creates severe operational risk. Businesses face potential immediate shutdown based on subjective Agency interpretations, with insufficient time to manage contractual obligations or transition services, making compliance planning impossible and discouraging investment in authentication services.