Ghana (GH)

Licensing, Authorisation & Market Access

Ghana's payments licensing perimeter is anchored by the Payment Systems and Services Act, 2019 (Act 987), the primary governing instrument administered by the Bank of Ghana as overall supervisor. The statute establishes a tiered non-bank PSP regime spanning Standard, Medium and Enhanced categories, a Dedicated Electronic Money Issuer (DEMI) licence for non-bank e-money, and a bank/SDI route under Act 930. A body corporate not already regulated under Act 930 may not operate a payment system or provide a payment service without a BoG licence. The bank-PSP versus non-bank-PI/EMI distinction is structural here: the DEMI route is how telcos own e-money, and the Enhanced PSP route hosts the major fintech aggregators, while banks and specialised deposit-taking institutions enter via Act 930.

Calibration of the tiered regime is operationalised by BoG Notice BG/GOV/SEC/2019/16, which sets minimum capital, permissible activities and fees across all PSP categories and fintech companies, scaled to firm size and nature. Together these instruments define the market-access perimeter for any operator entering Ghana, with the bank-partnership exemption available as a route to market without a standalone licence.

Outlook

The licensing spine is established and confirmed; the forward question is how the perimeter interacts with the new VASP regime under Act 1154, which introduces a separate BoG/SEC licensing track for virtual asset firms not yet operational at baseline. No change to the Act 987 tiered structure itself is signalled this cycle.

Stablecoins & Digital Money

Ghana operates a dual digital-money regime. The in-force layer is cedi e-money under Act 987: electronic money accounts and transactions must be denominated in Ghana Cedis, engaging in e-money business without a BoG licence is a criminal offence, and the cedi remains sole legal tender. The new layer is the Virtual Asset Service Providers Act, 2025 (Act 1154), which establishes registration, licensing and supervision of VASPs covering cryptocurrencies, tokens, stablecoins and blockchain instruments. The Act passed on 19 December 2025 and was assented late December 2025, with BoG as primary licensing authority and SEC and FIC coordinating.

The operational status is transitional and confidence is accordingly High rather than Confirmed: the full licensing window is not yet operational as of baseline, the opening date has not been published by a Tier 1 source, and a 12-month SEC sandbox announced in March 2026 precedes licensing. This opens a regulated crypto and stablecoin market in a jurisdiction recording over $10 billion in annual crypto flows by November 2025 (up from roughly $6 billion the prior year), with existing VASPs continuing under transitional arrangements. The regime is non-bank-PI/EMI in character on the crypto side; the cedi e-money framework binds both bank and non-bank issuers.

Outlook

The stablecoin-frameworks trajectory is establishing. The licensing-window opening date — plausibly 2026-H2 after the sandbox — is the gating commercial variable for exchanges, custodians and stablecoin issuers and the single highest-value forward signal in the jurisdiction.

Correspondent Banking, Settlement & Access

The analytical spine of this module is the bank versus non-bank access asymmetry in settlement. GhIPSS, established May 2007 as a wholly owned subsidiary of the Bank of Ghana, runs the national RTGS-linked switch, GACH, e-zwich and instant rails. Both banks and non-bank FIs — savings & loans, fintechs and mobile-money platforms — access PAPSS through the GhIPSS platform, which settles between central banks in hard currency via Afreximbank. Non-bank PSP access to settlement through GhIPSS is the methodology-relevant access point.

PAPSS reduces dependency on US/Europe-based international payment infrastructure amid de-risking that has locked individuals, local banks and whole countries out of the international system. Nineteen Ghanaian banks are live on PAPSS, and the system can cut implicit cross-border fees for Ghanaian importers from around 15% (two sets of correspondent fees) to around 6% — a roughly nine percentage-point reduction that materially improves intra-African trade settlement economics. Banks still require paper affidavits for non-resident foreign accounts, and de-risking and FX-access remain structural constraints for cross-currency flows; this layer is bank-PSP in character.

Outlook

The settlement trajectory is improving. PAPSS adoption is the de-risking mitigant; residual FX-access and affidavit friction, plus the bank/non-bank access gap, remain the structural constraints to monitor.

Commercial Intelligence (M&A, Investment & Product)

The commercial-events cohort is led by Zeepay. Zeepay raised a $22m Series B led by Visa (with the MTN Mobile Money Innovation Fund and Launch Africa Ventures) in September 2025 — a completed investment whose Visa strategic lead signals scheme positioning in West African account-to-account remittance flows. Separately, Zeepay secured an $18m debt facility (with Verdant Capital) in May 2025 to bolster remittance liquidity across Africa and the Caribbean. Both are non-bank-PI/EMI events.

Market entry intensified competition: enza (Abu Dhabi-HQ, Ghana operations) raised a $6.75m seed round co-led by Algebra Ventures and Quona Capital in March 2025 and secured a Ghana licence, intensifying competition in payment processing. The structural deal is the government-backed Telecel-AirtelTigo merger, announced September 2025 with integration targeted for end-2025 and a proposed $600m four-year investment plan, aiming to create an entity with around 26% market share to challenge MTN. As of the 27 June 2026 baseline the end-2025 completion target is past and final completion status is not independently confirmed this cycle; the merger is in a pending_regulatory state. All deal values above are publicly disclosed.

Outlook

The commercial-intelligence trajectory is active, with around $120-127m raised across roughly 38 deals in 2025. The Telecel-AirtelTigo completion status is the highest-value open item, as it is the only structural challenger to MTN MoMo dominance and its timing materially shapes the competitive landscape.

Industry Structure & Commercial Dynamics

The Ghana payments market is structurally mobile-money-led and highly concentrated. MTN Mobile Money holds around 73% of Ghana's mobile-money customers (roughly 19-20m users) versus Telecel Cash at about 23% and AT Money at about 3%; registered mobile-money accounts reached around 74.1m by 2025; and MTN MoMo financial-services revenue rose 35.7% in 2025, creating ecosystem lock-in. This is a non-bank-PI/EMI-dominated structure.

Under Act 987, MTN Ghana was required to restructure MoMo operations for minimum 30% Ghanaian ownership by 13 June 2025, planning to transfer MobileMoney Limited's assets and staff to a newly incorporated entity. As of the 27 June 2026 baseline that deadline has elapsed; current post-deadline compliance status is not independently confirmed this cycle, though MTN corporate communications confirm the restructuring was underway in 2025. The local-ownership mandate restructures the dominant operator's corporate shape, with non-compliance risking regulatory sanction including potential shutdown.

Outlook

The structural trajectory is concentrated. Verification of the local-ownership restructuring outcome is the key open item; the Telecel-AirtelTigo merger (carried in W13) is the principal structural challenger to MTN dominance.

Conduct, Safeguarding & Financial Promotions

Conduct and safeguarding obligations are escalating. The BoG Corporate Governance Guidelines for PSPs (June 2025), issued under s.101(2)(j) of Act 987 and applicable to all licence categories, require boards of at least three members, a majority non-executive, with at least two resident in Ghana, against a compliance deadline of 31 December 2025. As of the 27 June 2026 baseline that deadline has elapsed, and current post-deadline compliance status is not independently verified by a Tier 1 source this cycle; the caveat is carried.

Safeguarding of non-bank customer funds is governed by the BoG E-Money Issuer Guidelines, which define the e-money float as the total outstanding e-money liabilities to customers and bind all issuers to CDD/KYC tiers, transaction-limit controls and outsourcing/SLA/audit obligations. The float is held against outstanding customer e-money liabilities on a cedi-denominated basis per Act 987 and the EMI Guidelines, the customer-fund protection mechanism for non-bank e-money. The precise fund-protection vehicle remains under-specified relative to the EU/UK safeguarding lens.

Financial-promotions enforcement made its first visible appearance under the new regime when the Bank of Ghana and SEC ordered all virtual asset service providers to halt mass marketing within 48 hours on 20 February 2026, citing Act 1154's classification of crypto advocacy as a regulated activity. This signals that regulators will police VASP conduct and promotions ahead of the full licensing window opening, raising the compliance bar for crypto operators marketing in Ghana.

Outlook

The trajectory is escalating: governance compliance verification, the safeguarding-detail gap, and further financial-promotions enforcement are the items to watch as the VASP licensing window approaches.

Operational Resilience & Critical Infrastructure

Ghana's operational-resilience spine is the BoG Cyber & Information Security Directive (CISD, October 2018), issued under s.92(1) of Act 930. The roughly 131-page, 20-section directive applies to banks, SDIs, payment systems and fintechs, requiring ISMS/ISO 27001 certification, PCI DSS compliance, incident response, business continuity and cyber-incident reporting to BoG. It functions as Ghana's DORA-analogue, with BoG acting as the Sectoral CERT for finance and FICSOC monitoring threats. The directive binds both bank and non-bank entities.

The forward change is the revised CISD 2026 directive (exposure draft 2025), which adds AI/ML governance, strict cloud rules and a data-localisation requirement that core systems and critical customer data remain in Ghana, aligned with the Data Protection Act 2012 and built around six strategic pillars. The data-localisation mandate forces global cloud-reliant PSPs to onshore core systems and critical data, materially affecting infrastructure cost and architecture decisions in Ghana.

Outlook

The DORA/resilience trajectory is tightening. The CISD 2026 revision is expected to move toward in-force status during 2026; firms using global cloud providers face the most material adjustment.

Scheme & Network Compliance

The BoG Guideline on Operations of Electronic Payment Channels structurally separates card schemes from acquiring and sets settlement discipline. A card scheme shall not engage in merchant acquiring; schemes or affiliates with 20%+ shareholding are barred from acquiring; collusion between schemes on issuing, acquiring, processing or switching is prohibited; PTSPs and acquirers must settle merchant transactions within T+1; EMV chip and magnetic-stripe specifications apply to POS; and certain card data must not be routed outside Ghana within transition periods.

On the domestic side, the gh-link card scheme is operated onshore by GhIPSS, with all processing done within Ghana, chip-and-PIN with 3DSecure for e-commerce, and lower transaction fees and faster chargeback resolution than international card schemes. This reduces dependence on international networks. Both elements apply across bank and non-bank participants.

Outlook

The scheme-compliance trajectory is stable. Ghana-specific intracountry interchange and fee detail for international schemes is under-indexed this cycle relative to the global rulebook summaries available, flagged for targeted collection.

Payment Corridor Dynamics

Ghana's principal cross-border rail is PAPSS, the Pan-African Payment and Settlement System, which enables intra-African local-currency settlement that bypasses external correspondent banks and is accessed in Ghana via GhIPSS. Ghana is an integrated central bank, and its first PAPSS transaction occurred in March 2023 — a GCB cedi-to-naira supplier payment to Nigeria. Local-currency settlement bypassing USD correspondents materially cuts cross-border cost for Ghanaian importers and de-risks the corridor.

The diaspora remittance channel is large: inward remittances reached $6.65 billion at end-2024 (up from $5.11bn in 2023), significantly exceeding $1.73bn of FDI, and are channelled through DEMIs and EPSPs partnering with money transfer operators under BoG's Updated Guidelines for Inward Remittance Services — a non-bank-PI/EMI-led channel. On market access, in February 2025 the central banks of Ghana and Rwanda signed an MoU establishing Africa's first framework for passporting fintech licences, letting regulated fintechs operate in both countries without obtaining new licences.

Outlook

The corridor trajectory is opening on both the GH-NG and GH-RW axes, with the diaspora-inward corridor growing. The Ghana-Rwanda passporting framework is an under-indexed market-access innovation worth tracking for replication elsewhere on the continent.

Legal & Litigation

The dispute-resolution and enforcement spine sits in Act 987. PSPs aggrieved by BoG licensing decisions petition BoG within 30 days, with onward appeal to the Chief Justice; consumer disputes use mandatory internal PSP procedures with appeal to BoG; and BoG may suspend or revoke a licence for false information, breach of conditions, or unsafe or unsound practices. This legal/dispute infrastructure applies to both bank and non-bank participants.

Enforcement is active. On 18 September 2025 BoG suspended the remittance partnerships of Flutterwave Inc. and Cellulant Ghana for one month for breaching the Updated Guidelines for Inward Remittance Services after conducting unauthorised MTO remittance activities, with firms required to reapply for approval. This is consistent with a prior Zeepay forex-licence suspension in November 2023.

Outlook

The legal trajectory is active. The Flutterwave/Cellulant episode confirms BoG's willingness to suspend non-bank remittance partnerships for guideline breaches; further enforcement in the remittance and VASP-promotions space is the pattern to track.

Merchant Acquiring & Risk

Ghana's merchant-acquiring market is structured around mobile-money acceptance via aggregators pricing below telco rates: Zeepay at 1%, ExpressPay at 1.5% MoMo / 2.5% card, and Hubtel at 1.2% API, against the roughly 1.75% telcos charge. GhIPSS interoperability means a single mobile-money integration reaches MTN MoMo, Telecel Cash, AirtelTigo and GhanaPay. Card penetration is structurally low, and PTSPs and acquirers are bound by SLAs, T+1 settlement and POS certification. The structure spans bank and non-bank acquirers.

On risk, the Ghana Card is increasingly used as the primary KYC document, reportedly cutting onboarding fraud by around 70%.

Outlook

The merchant-acquiring trajectory is stable, with aggregator-led sub-2% mobile-money acceptance and growing Ghana Card KYC adoption the defining features. Acquiring operations remain an under-indexed category for granular collection.

Product Innovation & Market Development

Ghana is an instant-payments and inclusion leader. GhIPSS Instant Pay (GIP, introduced 2015), full Mobile Money Interoperability (MMI), GhQR universal QR, the GhanaPay bank-led wallet and e-zwich operate 24/7 with instant settlement; GIP supports a GHS 50,000 per-transaction limit; and the architecture supports cross-border trade via PAPSS. These rails span bank and non-bank participants.

Two forward developments are live. BoG is piloting the retail eCedi CBDC (offline-capable), having run an online/offline pilot with around 2,750 users in 2022; a retail launch is contingent on enabling legislation, with offline functionality prioritised to reach communities lacking internet access. Separately, BoG is piloting an open-banking framework in proof-of-concept phase to enable consent-based data sharing between banks and fintechs under standards for consent, privacy and cybersecurity, with the eCedi pilot entering a next phase connecting banks, fintechs and telcos. A National Payment Systems Strategy 2025-2029 frames interoperability and open finance.

Outlook

The product-innovation trajectory is leading. The eCedi retail CBDC remains pre-launch pending legislation, while the open-banking framework is expected to move from proof-of-concept toward standards under the NPS Strategy 2025-2029 during 2026.

Consumer Protection & APP Fraud

Ghana's consumer-protection and redress regime is structured around BoG's Investigation and Consumer Reporting Office (ICRO), complaints procedures, the Consumer Recourse Mechanism Guideline (2017) and Disclosure/Transparency guidelines, with PSPs (DEMIs and EPSPs) serving as the first level of redress. There is no UK-style mandatory APP-fraud reimbursement regime — a structural contrast to the UK PSR approach that applies across bank and non-bank participants.

The fraud picture is deteriorating in the non-bank segment. The BoG 2024 Fraud Report records aggregate fraud cases across banks, SDIs and PSPs rising to 16,733 in 2024 (from 15,865 in 2023, +5%), with total value at risk around GHS99m (vs GHS88m in 2023) and a sharp jump in ATM/POS/card fraud; bank fraud cases fell 26% while PSP-sector fraud counts increased. Mobile-money social-engineering and SIM-swap fraud is prominent.

Outlook

The consumer-protection trajectory is escalating. The combination of rising PSP/mobile-money fraud and the absence of a mandatory reimbursement backstop is the structural tension to watch.

AML/CFT & Financial Crime (Sentinel-fed)

This module carries the Sentinel feed surface only; original illicit-finance analysis is routed to the Financial Integrity Monitor. Per Sentinel (fic.gov.gh), Ghana was placed on the FATF grey list following its second-round mutual evaluation and removed at the June 2021 Plenary after implementing its 2018-2020 action plan; it exited the EU high-risk list in January 2022; and as of February 2026 it is not on any FATF increased-monitoring list and is considered broadly compliant.

Per Sentinel (blog.voveid.com), the Anti-Money Laundering Act, 2020 (Act 1044) criminalises money laundering and requires CDD and STR filing for accountable institutions including banks, fintechs and crypto providers, under FIC supervision with goAML and Ghana Card KYC; under Act 1154, VASPs must implement FATF-consistent AML/CFT including the Travel Rule, overseen by the FIC. The Travel Rule applicability to VASPs is the payments-relevant carry. Galamsey gold and cocoa trade-based laundering are noted as priority risks for the Financial Integrity Monitor, not WPM conclusions.

Outlook

The AML/CFT surface is stable. The live payments-relevant item is the operationalisation of Travel Rule obligations as the VASP licensing window approaches; deeper illicit-finance analysis remains a Financial Integrity Monitor matter.