The regulator and the licensing regime
The Bank of Ghana (BoG) is Ghana’s central bank and the regulator of its payment systems. It also plays a second role that other markets assign to a separate body: it owns the infrastructure operator. GhIPSS, the Ghana Interbank Payment and Settlement Systems Limited, incorporated in May 2007, is its wholly owned subsidiary. Negotiating access to Ghana’s rails therefore ultimately means negotiating with the central bank itself. Combining regulation and operation is what allowed the country to mandate interoperability by regulatory decision, without waiting for an industry-wide agreement.
The regulatory turning point came on July 6, 2015, when the BoG issued the Guidelines for E-Money Issuers, replacing the 2008 Branchless Banking Guidelines. The guidelines address the legal structure of e-money issuance. A mobile network operator could now get an e-money issuing subsidiary licensed instead of relying on a partner bank. The same central bank publication documents how the base grew in the years before the reform. Between 2012 and 2014, e-money accounts rose from 3.78 million to 7.17 million, and annual volumes grew from 18.0 million to 113.18 million transactions (Bank of Ghana, The Evolution of Bank of Ghana Policies on the Ghanaian Payment System, 2022).
The Payment Systems and Services Act, 2019 (Act 987) codified this regime. It creates a tiered licensing ladder based on activity and risk, with a minimum capital requirement for each tier. Each tier also carries an ownership condition, ranging from full access for foreign investors to eligibility for Ghanaian owners only. A license therefore determines both the capital a provider must hold and the nationality of its shareholders.
| License | Minimum capital | Permitted activities | Ownership |
|---|---|---|---|
| DEMI (Dedicated Electronic Money Issuer) | GH¢20 million | E-money issuance, wallets, agent networks: the license held by the mobile money subsidiaries of mobile network operators | Open |
| PSP Scheme | GH¢8 million | Switching and routing between payment infrastructures | Open |
| PSP Enhanced | GH¢2 million | Merchant acquiring, aggregation, processing, payment gateways, inbound international remittances, EMV card personalization, POS terminal deployment | At least 30% local ownership |
| PSP Medium | GH¢0.8 million | Merchant and biller aggregation, POS terminal deployment, mobile payment apps | At least 30% local ownership |
| PSP Standard | No capital requirement | Mobile payment apps and limited ancillary services | Reserved for 100% Ghanaian-owned entities |
The scope of supervision widened at the end of 2025. Parliament passed the Virtual Asset Service Providers Act on December 19, 2025, and it was signed into law on December 22 as Act 1154. The act makes the Bank of Ghana, together with the Securities and Exchange Commission and the Financial Intelligence Centre, responsible for registering and supervising virtual asset service providers. The BoG has set up a dedicated unit, the Virtual Assets Regulatory Office. The governor since February 3, 2025, is Johnson Pandit Asiama.
- Payment Systems and Services Act, 2019 (Act 987): the PSP and EMI licensing regime, the foundation for any payment business in Ghana.
- Guidelines for E-Money Issuers, July 6, 2015: allow a mobile network operator to set up an EMI subsidiary; the founding text of Ghanaian mobile money.
- Licensing Requirements for DEMI and PSP, July 2020: minimum capital, technical requirements (PCI DSS, ISO 27001 depending on the category), ownership rules.
- Virtual Asset Service Providers Act, 2025 (Act 1154): virtual asset supervision shared by the BoG, SEC, and FIC.
- Banks and Specialised Deposit-Taking Institutions Act, 2016 (Act 930): governs the banks and specialized deposit-taking institutions that PSPs connect to.
GhIPSS: one public infrastructure, 10 services
GhIPSS runs 10 payment systems, from truncated check clearing to instant transfers. They fall into three families: real-time payments, bulk clearing, and cards. An acquirer that connects once reaches banks, mobile wallets, and domestic cards, without negotiating a bilateral integration with each.
| Service | Since | Type | Use cases |
|---|---|---|---|
| e-zwich | 2008 | Chip card with biometric authentication | Government payments: public sector salaries, social programs, national service allowances. Works offline and without an existing bank account. |
| gh-link | 2012 | National switch and domestic card brand | Interbank switching for ATM, POS, and online transactions; calculation of settlement positions at the Bank of Ghana. The domestic alternative to the international card networks. |
| GhIPSS Instant Pay (GIP) | 2016 | Real-time account-to-account transfer | Interbank credit transfers 24/7, capped at GH¢50,000 per transaction. |
| Mobile Money Interoperability (MMI) | 2018 | Wallet interoperability | Wallet-to-wallet, wallet-to-bank account, and wallet-to-e-zwich card transfers. |
| GhQR | 2020 | Universal QR standard | Merchant acceptance from any funding source: wallet, card, bank account. |
| GhanaPay | 2022 | Shared bank wallet | The answer of banks and deposit-taking institutions to mobile money, on its own turf. |
| ACH Direct Credit / Direct Debit | – | Bulk clearing | Salaries, pensions, suppliers; recurring direct debits under a mandate. |
| Cheque Codeline Clearing (CCC) | – | Truncation-based clearing | Business checks: the image and codeline move between banks, while the paper stays with the presenting bank. |
| Proxy Pay | – | Alias directory | Pay an account or wallet using an alias, without knowing the account number. |
| Request to Pay | – | Payment request | Payee-initiated collection, approved by the payer; built on GIP. |
Interbank transactions pass through gh-link, which calculates net positions that settle in central bank money at the Bank of Ghana. In Ghana, the ranking of rails by volume differs from that of banked markets. GIP matters less than MMI in everyday use, because the country built its payments around the mobile wallet rather than the bank account. An integration designed around interbank transfers therefore connects to the market’s secondary rail first.
Mobile money: where the money is
Mobile money refers to e-money accounts held with licensed issuers and served by a network of physical agents. These accounts carry the largest share of Ghana’s retail payments. The annual value of mobile money transactions is more than double the total exchanged on GhIPSS’s interbank platforms. In 2024, the Bank of Ghana recorded GH¢3,010 billion in mobile money transactions across 8.1 billion payments. The monthly figures the central bank has published since then show continued growth.
A registered account is one opened on an issuer’s books. An active account is one used for at least one transaction during the reference period. Three factors explain the gap between 83 million registered and 26 million active accounts: multiple SIM cards, dormant wallets, and accounts opened with several issuers. Together they inflate the reported base well beyond Ghana’s population. The agent network shows the same gap, with just over half of the 992,000 registered agents actually working.
| Wallet | Issuer | Parent telecom | Case |
|---|---|---|---|
| MTN Mobile Money (MoMo) | Mobile Money Limited (MML) | MTN Ghana | The dominant operator, run as a subsidiary under an EMI license separate from the telecom business, a separation model required by the Bank of Ghana and copied elsewhere. |
| Telecel Cash | Telecel Ghana | Telecel Ghana (formerly Vodafone Ghana) | Telecel Group acquired 70% of Vodafone Ghana in February 2023; the Telecel brand has been rolled out since late February 2024. |
| AT Money | AT Ghana | AT (formerly AirtelTigo) | The Ghanaian government took over AirtelTigo in November 2021; the operator was renamed AT in 2023. |
The accounts published by MTN Ghana show how concentrated the market is. For fiscal 2025, reported on March 2, 2026, MoMo revenue grew 35.7% to GH¢6.0 billion, with 19.3 million active users (+12.3%). The local group’s service revenue reached GH¢24.4 billion, up 36.2%. MTN Ghana explicitly credits two factors for the acceleration: the removal of the e-levy and the growth of so-called advanced services, which include merchant payments, lending, and insurance. With 19.3 million active users, MoMo remains the largest source of funds available to a merchant accepting payments in Ghana.
Mandated interoperability and what it changed
Interoperability means that one issuer’s customer can send money directly to another issuer’s customer. On May 10, 2018, Vice President Mahamudu Bawumia launched the Mobile Money Interoperability platform built by GhIPSS. Until then, an MTN customer could not send money directly to a customer on another network. Ghana became the first African country to make wallets interoperable with one another and with bank accounts, nationwide and under a regulatory mandate. Two data points show the early uptake. The first five days saw 23,000 transactions worth GH¢1.8 million (Oxford Business Group, 2018). Four months later, cross-network transfers accounted for 12% of GhIPSS services.
The scheme reaches beyond person-to-person transfers. MMI also links wallets to bank accounts and e-zwich cards, so a wallet balance can move to a bank account without a cash withdrawal. Governor Ernest Addison launched phase II with this wider scope. Tanzania and Rwanda drew on the model.
- One technical integration: a PSP connected to GhIPSS reaches all three issuers, without a bilateral agreement with each mobile network operator.
- Alias addressing: Proxy Pay spares the payer from knowing an account number. It is the directory layer that was needed to make interoperability usable for customers.
- KYC stays with the issuer: customer identification is handled by the DEMI or the bank, not by the interoperability platform.
- Don’t confuse MMI with GhQR: MMI is a transfer rail, GhQR a merchant acceptance standard. They are two separate GhIPSS services.
- No public breakdown by service: MMI volumes are rolled into the GhIPSS total, so no open source can be used to estimate a market share.
The e-levy: the tax, its measured effects, and its repeal
The Electronic Transfer Levy Act, 2022 (Act 1075), signed into law on March 31, 2022, imposed a 1.50% levy on electronic transfers. Collection began on May 1, 2022. The second schedule of the act defines its scope. Four categories cover wallets: transfers within the same issuer, transfers between issuers, transfers from a bank account to a wallet, and the reverse. A fifth covers instant transfers sent by an individual from a bank account above a threshold set by the minister. The entities required to collect the levy include e-money issuers, PSPs, banks, and specialized deposit-taking institutions.
- GH¢100 per person per day, cumulative, exempt as a daily allowance; the provision that did most to change transaction-splitting behavior.
- Transfers between accounts held by the same person, out of scope.
- Payments of taxes, duties, and fees through the Ghana.Gov platform or any other system designated by the government, out of scope.
- Specified merchant payments, made to a merchant registered with the Ghana Revenue Authority for income tax or VAT.
- Transfers between principal, agent, and master-agent accounts, out of scope, which preserved the liquidity mechanics of the agent network.
- Electronic check clearing, out of scope.
| Date | Legal basis | Content |
|---|---|---|
| March 31, 2022 | Electronic Transfer Levy Act, 2022 (Act 1075) | 1.50% levy on electronic transfers; GH¢100 daily exemption per person; collected by the Ghana Revenue Authority from May 1, 2022. |
| December 29, 2022 | Electronic Transfer Levy (Amendment) Act, 2022 (Act 1089) | Rate cut to 1%; mandatory filing of returns; levy collected must be remitted to the Commissioner-General within 24 hours. |
| March 26, 2025 | Parliamentary vote | Repeal bill, introduced with the 2025 budget, is passed. |
| April 2, 2025 | Signed into law | President John Dramani Mahama signs the law repealing Act 1075 and Act 1089, along with the betting tax and the Emissions Levy (Act 1112). |
Actual 2022 revenue came in at less than a tenth of the original forecast, and two mechanisms explain the shortfall. Users shifted to cash and to exempt channels. They also split amounts below the GH¢100 daily exemption to stay outside the levy’s scope. The rebound after the repeal confirms how price-sensitive usage is. MTN Ghana reported a 35.7% increase in MoMo revenue for 2025, which it attributes to the removal of the levy and the growth of advanced services.
Ghana shows how a tax levied on payment flows, at the moment of payment, behaves in practice. A charge that customers can see shifts usage before it raises the expected revenue, an effect the country measured over three budget years. Volume series from before April 2025 reflect this dampening effect of the tax. Projections built on them therefore underestimate the market as it has worked since the repeal.
Accepting payments in store: GhQR, GhanaPay, and the acceptance blind spot
GhQR, launched in 2020 by GhIPSS with technology provider HPS, is the country’s universal QR standard. A single code displayed at the checkout accepts a mobile wallet, a card, or a bank account, whatever the payer’s bank or issuer. The standard runs on the GhIPSS interbank rail and covers every domestic source of funds. Merchant adoption has nonetheless lagged behind the volumes that this coverage made possible.
| Year | Transactions | Value |
|---|---|---|
| 2020 | 904 | GH¢98,336 |
| 2021 | 26 443 | GH¢14.7 million |
| 2022 | 958 774 | GH¢638.6 million |
| 2024 | not broken out | GH¢7.16 billion |
| 2025 | not broken out | GH¢12.92 billion (+80.56%) |
About 130,000 merchants had activated GhQR, according to GhIPSS data reported in 2025. One mobile network claims millions on its proprietary system alone. The e-levy held back the QR rollout during its three years in force, when the cost difference worked against small electronic payments. Growth of more than 80% in value in 2025 is consistent with that constraint being lifted.
| Channel | Rail | Strengths | Where it falls short |
|---|---|---|---|
| MoMoPay (operator wallet) | Issuer’s proprietary network | Widest customer reach, familiar to users, dense agent network for cash-out | Dependence on a single issuer; reconciliation tied to the operator’s formats |
| GhQR | GhIPSS | One code for every source of funds; public standard, independent of any issuer | Small installed merchant base; low customer awareness compared with proprietary codes |
| GIP / Proxy Pay / Request to Pay | GhIPSS | Instant credit, GH¢50,000 limit, alias addressing, payment requests for billers | Rail designed for bank accounts, which play a smaller role in retail than wallets |
| Card (gh-link, international networks) | gh-link / card networks | Needed for travelers and cross-border e-commerce | Small cardholder base compared with wallets; less favorable acceptance economics on small tickets |
| e-zwich | GhIPSS | Biometric verification, offline operation, no bank account needed | Mainly used for government disbursements; of little relevance to everyday retail |
GhanaPay is a shared wallet launched in 2022 by GhIPSS with commercial banks, rural banks, and specialized deposit-taking institutions. By offering free transactions, it aimed to win back ground from MTN MoMo in its own market. Volumes did not follow. MTN MoMo had been established since 2009 and distributed its services through an agent network, while the banks behind GhanaPay relied on their branches. Free transactions could not make up for that gap in physical reach.
The eCedi: a central bank digital currency stuck in pilot
The eCedi is Ghana’s central bank digital currency (CBDC) project, announced by Governor Ernest Addison in June 2021. A CBDC is money issued by the central bank and held directly by the public, without an intermediary bank deposit. Developed with German technology company Giesecke+Devrient (G+D), the eCedi was presented at the time as Africa’s first general-purpose CBDC, with claimed offline payment capability. The pilot contract was signed in August 2021, and public trials took place in 2022. No general rollout has followed.
- Status: in pilot since 2021, with no general public rollout several years after launch.
- Stated positioning: retail payments, including offline, with a financial inclusion case for areas with patchy network coverage.
- Domestic competition: mobile money already carries the largest share of Ghana’s retail payments, through a network of more than half a million active agents.
- Takeaway for practitioners: no acceptance obligation, and no live rail to integrate today. The topic remains forward-looking.
The eCedi’s development has continued on the cross-border front rather than at home. Project DESFT, launched in June 2023 with the Monetary Authority of Singapore, targets the obstacles small exporters face. It identifies three: building trust with a foreign counterparty, accessing cross-border payments, and financing the supply chain. The second phase ended in April 2024 with a live commercial transaction between Ghana and Singapore, combining Universal Trusted Credentials, the Singapore dollar stablecoin xSGD, the eCedi infrastructure, and the Purpose Bound Money protocol.
Operating in Ghana: players, flows, and watch points
Payment acceptance projects in Ghana rarely connect directly to the public rails. The acquiring and aggregation layer, which collects payments on a merchant’s behalf and pays out the proceeds, is occupied by local and pan-African providers. Their licenses and footprint determine which services are actually available. There are only a few of them, and the same names come up in one Ghanaian tender after another.
International remittances are funds sent to Ghana by individuals abroad. Inflows reached nearly $7.8 billion in 2025, about 6% of GDP (Bank of Ghana figures cited by Governor Asiama, April 2026). They exceed foreign direct investment, and the US is their largest source. Direct payout into mobile wallets, Zeepay’s model, is capturing a growing share of these flows. E-money issuers therefore compete with traditional money transfer operators on the last mile: delivering the funds to the recipient.
- Choose the license before the architecture. Minimum capital ranges from zero (PSP Standard, reserved for wholly Ghanaian-owned entities) to GH¢20 million (DEMI). The target category determines ownership, technical requirements, and licensing time.
- Secure the 30% local ownership from the start, in every category open to foreign investors.
- Integrate the wallet before the bank account. MoMo is the market’s leading source of funds; GIP serves real but secondary retail use cases.
- Treat merchant acceptance as a commercial rollout, not an integration task. GhQR is available, but its installed base remains small compared with proprietary codes.
- Model in cedis and disclose the currency risk. Market statistics are published in GHS, while revenue from remittances and cross-border e-commerce comes in foreign currencies.
- Exclude data series from before April 2025 from any volume projection: they carry the dampening effect of the e-levy.
- Check the virtual asset scope if the offering involves stablecoins or crypto-assets: the 2025 Act 1154 requires these activities to register with the Bank of Ghana.