MISA-Zimbabwe’s submissions on the above-mentioned Bill are as follows: 1. Section 27 as read with section 3(d) restrict investments in Zimbabwe’s telecommunications sector to Zimbabwean citizens who are ordinarily resident in Zimbabwe. 1.1. Section 3(d) of the Bill limits investment in the Zimbabwean telecommunications sector to Zimbabwean citizens. Section 27(1) expands on this by stating that licences can only be granted to body corporates controlled by Zimbabwean citizens who are ordinarily resident in Zimbabwe. It is acknowledged that foreign entities can own telecommunications services in Zimbabwe with the written consent of the Minister of ICT and Cyber Security. 1.2. This is an unnecessary restriction on ownership of telecommunications service providers. More so when one considers the fact that globalisation, and technological developments have given rise to multi-national telecommunications service providers. The requirement that Zimbabwean citizens have a controlling stake in all telecommunications ventures operating in Zimbabwe is a revival of the recently scraped indigenous laws. 1.3. Section 29(3) states that radio stations can only employ Zimbabwean citizens. This is an unjustified restriction on radio stations. Such a restriction might make sense for state owned radio stations but not for privately owned radio stations. 1.4. Recommendations: Ownership of telecommunications services should be widened to include foreign nationals with the requisite experience and expertise in telecommunications, broadcasting and media. 1.5. The same goes for radio station employees. Private radio stations should have the discretion on who to employ.