No Business Protection During Appeals

The appeal framework provides inadequate protection for digital businesses facing Division enforcement actions. While judicial review is available, Division decisions are immediately binding and enforceable (59), meaning license suspensions or revocations can destroy a media business before appeals are heard. The restrictive appeal grounds exclude proportionality review and errors of law, and there is no automatic stay of coercive actions pending appeal (except for technical impossibility). For startups and small media outlets with limited legal resources, the 30-day appeal deadline and lack of interim relief create a "comply or die" dynamic that undermines business viability and chills market entry.