GHANA · BANKING · REGULATION
Ghana’s central bank has reminded payment companies that they may not touch the money they collect for shops and online sellers, and has warned that breaches may bring enforcement action. The Bank of Ghana set out the obligations in Notice No. 43, listed on 6 November 2026, issued under Section 101 of the Payment Systems and Services Act, 2019 (Act 987), the law that governs payment firms in Ghana.
For merchants, and for foreign companies that sell through Ghanaian processors, the notice answers a basic question: whose money is it while a payment is in transit? The central bank says it belongs to the merchant until settlement is complete.
Key Facts
- Who Payment firms that process shop payments (PSPs), and the banks holding their settlement accounts.
- Rule Merchant collections must sit in designated settlement accounts, apart from the provider’s own accounts.
- Ban Providers may not withdraw, pledge or deduct from merchant funds, except to pay merchants and take earned fees.
- Penalty Breaches may bring enforcement action; no fine amount is stated and no company is named.
What the Notice Requires of Payment Firms
A payment service provider (PSP) is a licensed company that facilitates payments for merchants and collects the money on their behalf. The Bank of Ghana says PSPs are not deposit-taking institutions, so they may not hold, use, pledge or otherwise treat merchant money as their own.
All such money must be credited to a designated settlement account, a separate account held at an approved bank, and kept apart from the PSP’s operating and business accounts. It stays the merchant’s property until it is paid out under the settlement terms in the contract between the PSP and the merchant.
The notice bars a PSP from withdrawing, transferring, pledging, placing a lien (a legal claim) on or setting off a debt against merchant funds in that account. The only exceptions are paying the merchant and moving fees and charges the PSP has earned.
Any fee or commission may leave the settlement account only as part of the settlement itself, and only as agreed with the merchant. The notice also refers to settlement in line with the periods agreed in those contracts.
What It Asks of Settlement Banks
A settlement bank is the bank that holds the account where merchant payments land before they reach the shop. The Bank of Ghana says these banks must run such accounts solely for settlement, and must not let a PSP use the money for operating costs, financing, investment or any other purpose unrelated to merchant settlement.
Banks and PSPs must keep records, controls and audit trails that prove they safeguard, separate and settle merchant funds on time. The central bank may also require settlement banks to send it statements for these accounts, at intervals it decides.
What the Central Bank Says Happens Next
The notice says failure to comply is a breach of the regulatory framework and may attract regulatory, supervisory and enforcement action. It tells all PSPs and settlement banks to take immediate steps to comply, and to review their contracts and internal controls.
It sets no penalty amount and no compliance date beyond the call for immediate action. For background on the regulator’s recent action against unlicensed lenders, see our report on 20 unlicensed loan apps.
What It Means for You
If you sell to customers in Ghana through a local payment processor, check your contract’s settlement terms, because the notice ties payouts to them. In our assessment, US and other foreign businesses that rely on Ghanaian processors, and Ghanaians who run small online shops, are the readers most directly affected.
In our assessment, shoppers should see no change at the till, since the rule governs what happens to the money after a payment is made. Our explainer on the end of Ghana’s International Monetary Fund programme covers the wider economy, and the Ghana hub has more.
What Is Not Known
The notice does not say why it was issued now, or whether any provider has already been found holding merchant money. It also does not say whether the central bank will inspect settlement accounts or publish the results.
Frequently Asked Questions
What did the Bank of Ghana order?
Payment firms must keep money collected for merchants in separate settlement accounts and may not use it. Settlement banks must make sure the accounts are used only for settlement.
Which law is the notice based on?
It is issued under Section 101 of the Payment Systems and Services Act, 2019 (Act 987). That Act regulates payment firms and payment systems in Ghana.
What happens to firms that break the rule?
The notice says a breach may attract regulatory, supervisory and enforcement action. It gives no fine amount or deadline.
Sources: Bank of Ghana, Notice No. 43, Management of Merchant Collection Funds by Settlement Banks and Payment Service Providers, 6 November 2026 (bog.gov.gh); Payment Systems and Services Act, 2019 (Act 987), Section 101.
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