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The Bank of Ghana (BoG) has introduced new regulatory requirements for major payment operators, requiring designated firms to obtain approval before making significant changes to their pricing, operations or infrastructure.
The measures form part of a new framework for supervising systemically important payment systems and service providers whose disruption or failure could have wider consequences for Ghana’s financial system.
Issued under the Payment Systems and Services Act, 2019 (Act 987), the Regulatory Framework for Systemically Important Payment Systems and Service Providers establishes specific thresholds for identifying payment companies whose market position or role in national financial infrastructure makes them critical to the stability of the payments ecosystem.
BoG defines thresholds for systemically important operators
Under the framework, a payment system will be classified as systemically important if it processes at least one-third of total national payment transactions by value or volume. A system may also receive the designation if it is the only platform in the country supporting a particular category of transactions.
For payment service providers, the criteria include controlling more than 50 per cent of the retail payments market by transaction value or 75 per cent by transaction volume.
The BoG also retains the authority to designate a provider based on its importance to national payment infrastructure, regardless of its market share.
These thresholds introduce a more defined approach to identifying payment operators whose activities warrant enhanced regulatory oversight.
Once the central bank formally designates an operator, the firm will be required to obtain BoG approval before implementing significant changes to its operations, infrastructure or pricing arrangements. This means that major fee adjustments by designated providers will no longer be solely commercial decisions.
Mobile money dominance places major operators under scrutiny
The new thresholds have particular relevance for Ghana’s mobile money market, given the channel’s growing dominance in the country’s payment ecosystem.
In August, mobile money users conducted 1,046 million transactions valued at GH¢518.8 billion. This was significantly higher than the GH¢95.1 billion recorded by GhIPSS Instant Pay, the second-largest payment channel.
By transaction volume, mobile money processed 51 times as many payments as Instant Pay during the period.
Within the mobile money segment, MTN’s MoMo business, which now operates as a separate company, remains the dominant provider. Its transaction value increased by 44.4 per cent year-on-year in the first half of 2026.
Although the framework does not identify specific companies for designation, its market-share thresholds suggest that only a limited number of operators are likely to meet the criteria, particularly the 50 per cent transaction-value and 75 per cent transaction-volume requirements.
Designated firms face stronger governance and risk controls
The framework extends beyond pricing and operational changes, introducing enhanced requirements covering corporate governance, risk management, operational resilience and business continuity.
Designated payment systems and service providers will be expected to maintain robust Know Your Customer (KYC) and Customer Due Diligence (CDD) procedures to reduce disputes and strengthen confidence in payment transactions.
They must also ensure that settlement is final and irrevocable, with payment systems providing real-time or same-day settlement arrangements.
Additional obligations include publishing information about governance structures, risk management policies and operational performance. Designated firms must also maintain crisis management plans and monitor their connections with other payment systems to limit the transmission of operational or financial risks.
The framework requires all designated entities to comply with the Principles for Financial Market Infrastructures developed by the Committee on Payments and Market Infrastructures (CPMI) and the International Organization of Securities Commissions (IOSCO).
These requirements are intended to strengthen the reliability of critical payment infrastructure and reduce the possibility that disruptions at individual operators could affect the wider financial system.
Technology providers brought under regulatory oversight
A significant feature of the framework is the introduction of a third category known as Critical Infrastructure Service Providers.
This classification covers technology companies whose services support the operation of payment systems and whose failure or cybersecurity compromise could disrupt national payment infrastructure.
The scope includes cloud service providers, data centres, software and platform providers, as well as customer due diligence platforms. For now, designation under this category is limited to licensed Payment and Financial Technology Service Providers.
The inclusion of technology providers reflects the growing dependence of financial institutions and payment operators on interconnected digital infrastructure.
Ghana recorded 2,008 cyber incidents in the first half of 2025, representing a 52 per cent increase compared with the corresponding period in the previous year.
The BoG warned that the increasing digitisation and integration of financial services could allow disruptions affecting individual operators to spread across institutions and markets.
The framework states that “localized disruptions can transmit shocks across financial institutions and markets”, highlighting the need to extend resilience requirements beyond payment companies to critical technology providers.
BoG establishes designation and monitoring process
The central bank will follow a structured process to identify and designate systemically important payment systems, service providers and critical infrastructure operators.
The process will involve collecting information on transaction values and volumes, user numbers, market share and interconnections with other payment systems. The BoG will assess the information against the established criteria before issuing formal designation notices.
Once designated, firms will be required to submit periodic self-assessment reports and undergo annual evaluations or additional assessments when necessary.
The classification will not necessarily remain permanent, as the central bank may review and reclassify operators when changes in market share, transaction activity or systemic importance warrant it.
The BoG has also committed to publishing and periodically updating a list of designated payment systems and service providers. This will provide greater public visibility into the institutions and platforms the regulator considers critical to Ghana’s financial infrastructure.
Implementation gaps remain under the new framework
Despite the introduction of the new requirements, some implementation details remain unclear.
The framework does not specify an effective date, a timeline for the first designations or the sanctions that may apply when designated operators fail to comply with their obligations.
There is also an apparent drafting inconsistency in the transaction-volume threshold. The document describes the requirement as “two-thirds (75%)”, although two-thirds is approximately 67 per cent.
These outstanding issues may require further clarification as the BoG moves towards implementing the framework and identifying the institutions covered by its provisions.
The new rules represent a significant development in Ghana’s payment system regulation, particularly as mobile money and digital payment channels continue to expand in scale and economic importance.
By introducing market-share thresholds, stronger operational requirements and oversight of critical technology providers, the BoG is seeking to ensure that the failure or disruption of a major payment operator does not undermine the stability of the wider financial system.
With mobile money transactions reaching GH¢518.8 billion in August, the framework signals a shift towards more intensive supervision of payment infrastructure that has become essential to everyday financial activity and the country’s digital economy.
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