Ghana: A FinTech Legal Overview
Introduction
Fintech in Ghana has grown from basic digital banking services like automated teller machines (ATMs), card payments and simple online platforms to a varied and innovative ecosystem that now includes mobile money, digital payments, lending, insurance and investment solutions. The rise in mobile device usage, shifting consumer expectations and collaboration among banks, telecom companies, technology firms and start-ups have sped up this change. Today, fintech is essential for improving financial access, modernising service delivery and shaping the future of Ghana’s digital economy.
Regulatory Framework Shaping Fintech
Ghana’s fintech ecosystem is regulated by a network of entities with interconnected roles. The Bank of Ghana (BoG) is the lead authority, overseeing digital payments, electronic money and digital credit, and currently regulating virtual asset service providers (VASPs). The Securities and Exchange Commission (SEC) manages capital market innovations, with a changing mandate that overlaps with the BoG in areas like crowdfunding and some virtual asset investment activities. The National Insurance Commission (NIC) monitors insurtech, while other institutions such as the Data Protection Commission, National Communications Authority and Financial Intelligence Centre oversee data governance, digital infrastructure and financial integrity.
Key Developments and Market Trends
Tightening of payment space
In recent years, the BoG has increasingly tightened its control over the payments sector through strategic regulatory measures. Revised inward remittance guidelines issued in August 2025 set stricter settlement and compliance obligations for fintechs and their money transfer partners. In July 2025, the BoG also released Corporate Governance Guidelines for payment service providers (PSPs) and dedicated electronic money issuers (DEMIs), which enhance expectations regarding board structure, independent directors, executive responsibilities and disclosure standards, promoting discipline and accountability in the payments ecosystem.
Sandboxes (BoG, NIC and SEC)
Regulatory sandboxes have been established across key supervisory bodies. The BoG’s sandbox, launched in 2022, is the most active. It allows for controlled testing of innovative payment solutions, including outward remittance use cases that are otherwise restricted under current regulations. The NIC sandbox, created in 2024, supports trials in digital insurance and has five participants. The SEC has also set up a sandbox framework for capital market innovation, although updates on public participation are limited.
New digital credit service provider licence category
The BoG, in 2025, introduced a new digital credit service provider licence to organise and formalise activities in the digital lending market. This licence allows the provision of low-value, short-term credit through digital channels. All existing operators must apply by 30 June 2026, while already-licensed BoG institutions wanting to enter this space must create separate entities for digital credit operations.
Shift in regulatory stance on crypto
At first, the BoG took a cautious approach, banning licensed financial institutions from facilitating crypto-related transactions, a stance shared by the SEC. In 2024, the Bank published an exposure draft outlining the guiding principles for future regulation. It has announced plans to regulate the sector through a parliamentary Act, leading to the development of the VASP Bill, which is expected to be passed in 2026. The Bank has also formed a specific Virtual Assets Regulatory Office.
Fintech passporting memorandum of understanding (MoU) with Rwanda
In February 2025, the BoG announced a MoU with the National Bank of Rwanda designed to allow licensed fintech operators in both areas to expand their services with fewer regulatory hurdles. The Bank has yet to release the detailed operational framework for this passporting arrangement, and no entity has been confirmed as having used a National Bank of Rwanda licence as of now.
Potential Hurdles for Fintech Entrants and Mitigation Considerations
Ghana Investment Promotion Centre (GIPC) minimum capital requirements
The Ghana Investment Promotion Centre (GIPC) Act, 2013 (Act 865) sets minimum capital thresholds for foreign investors: USD500,000 for wholly foreign-owned companies and USD200,000 for joint ventures. These requirements can be difficult for early-stage fintechs with limited initial funding. Careful structuring can lessen this burden by securing adequate investor commitments and exploring local partnerships. Importantly, the GIPC Act is under review, with proposals to eliminate the minimum capital requirement currently being considered.
Local participation and residency rules
Several fintech regulatory frameworks impose residency obligations, local equity participation requirements and, in some cases, restrictions on foreign ownership. While these rules aim to strengthen oversight and encourage local involvement, they can pose challenges for foreign entrants trying to navigate market entry. Early evaluation of sector-specific participation obligations, coupled with strategic local partnerships and hiring locally resident key staff, is crucial for compliance and operational success.
Low financial and digital literacy
Limited financial and digital literacy, especially in rural and underserved areas, still affects the adoption of fintech products. Providers can tackle this challenge through targeted consumer education, simplified user interfaces and solutions that work in low-connectivity environments, promoting broader adoption across various customer segments.
The Road Ahead
Ghana is entering a new stage of regulatory change, with various policy and legislative initiatives set to guide the next decade of fintech growth. These developments show a commitment to balancing innovation with stronger supervisory standards.
Introduction of a VASP regime
The BoG, in collaboration with the SEC and the Financial Intelligence Centre, is developing a legal framework specifically for VASPs. Expected to take effect in 2026, the upcoming VASP Act will establish licensing, registration and compliance requirements for exchanges, wallet providers, custodians, investment platforms and related service providers. This framework will set standards for anti-money laundering, counter-financing of terrorism, counter-proliferation financing, cybersecurity, data protection, consumer safeguards and reporting – creating structure in this emerging financial market sector.
Draft technology bills
The Ministry of Communication, Digital Technology and Innovations is conducting a thorough legislative review to modernise Ghana’s digital governance framework. Proposed changes to the Cybersecurity Act, 2020 (Act 1038) and the Data Protection Act, 2012 (Act 843) aim to bolster compliance expectations for fintechs and digital service providers. New draft legislation, including the Emerging Technologies Bill and the Innovation and Startup Bill, focuses on cutting-edge technologies, promotes responsible use of artificial intelligence and blockchain, and seeks to lower regulatory barriers for start-ups, including potential relief from capital requirements under the GIPC framework.
Digital banking framework
The BoG has also indicated plans to introduce a formal regulatory framework for digital and neo-banks. This would define clear licensing requirements and operational standards for institutions offering banking services exclusively through digital channels, further broadening the competitive landscape for Ghana’s financial services sector.
Ghana’s e-Cedi
Progress on e-Cedi, Ghana’s central bank digital currency, is advancing steadily. Following targeted pilots, including offline functionality in rural areas and international recognition, the initiative aims to enhance financial inclusion, boost transaction reliability and strengthen trust in the national currency. A broader rollout is planned as the project develops.