Vague Licensing Criteria Deter Market Entry

This provision requires mandatory registration for all OTT service providers and grants the Authority discretionary power to impose licensing requirements based on undefined criteria like "significant public interest implications" and "relies heavily on national infrastructure." These vague standards create legal uncertainty that makes it impossible for businesses to predict their regulatory obligations. Combined with data localization requirements that force international platforms to establish costly local infrastructure, this provision creates substantial barriers to market entry that go beyond standard regulatory practice in OECD democracies. The broad regulatory-making power allows the Authority to impose additional obligations without clear limits, further increasing compliance costs and deterring international digital service providers from entering the Ghanaian market.