Introduction
Ghana is experiencing technological growth and has one of the fastest-growing financial technology (Fintech) ecosystems in Africa. The interconnected nature of today’s world is changing how we conduct commercial and recreational activities.
In Ghana, Fintech startups are growing with significant opportunities. The increasing use of mobile and smartphones provides a platform to promote financial inclusion for people without access to traditional financial services.
Regulation of Fintechs in Ghana
The financial technology ecosystem in Ghana is regulated by the Bank of Ghana. The key legislation is the Payment Systems and Services Act, 2019 (Act 987), which requires companies intending to carry out payment service business or issue electronic money to be duly licensed.
Licensing Requirements
i. Company Profile
- Companies must be incorporated under the laws of Ghana (Registrar General’s Department).
- Overview of the company, incorporation documents, and summary of services must be submitted to the regulator.
ii. Governance
- Provide information about shareholders, their ownership percentages, and nationality.
- Include profiles of Directors and key management personnel.
- A minimum of three (3) directors is required for Payment Service Providers under the Payment Systems and Services Act, 2019.
iii. Business Plan
- Submit a detailed business plan, including:
- Business overview
- Market analysis
- Product and service offerings
- Onboarding process
- Proposed fees
- Five-year business projections
iv. Systems and Technology
- Employ robust ICT systems, including:
- ICT policy framework
- Security and control measures (e.g., fraud monitoring, two-factor authentication)
- Business continuity program
- Data Protection Certificate
- ISO 27001 and PCI DSS compliance (if applicable)
- Vulnerability assessments and risk mitigation measures
v. Enterprise Risk Management
- Submit risk and mitigation measures for:
- Operational risks
- Market liquidity
- Fraud, legal, credit, and funding risks
- Business Impact Assessment (BIA)
- Anti-Money Laundering (AML) and Combating the Financing of Terrorism (CFT) policies
vi. Consumer Protection Policy
- Submit a consumer protection policy guided by the Consumer Recourse Mechanism Guideline for Financial Service Providers Act 2017.
License Categories and Permissible Activities
Detailed categories and permissible activities for payment service providers and fintechs in Ghana include:
- Electronic Money Issuer
- Payment Service Provider (PSP) – Scheme
- Payment Service Provider (PSP) – Enhanced License
- Payment Service Provider (PSP) – Medium License
- Payment Service Provider (PSP) – Standard License
- Payment and Financial Technology Service Provider (PFTSP)