Guidelines for E-Money Issuers in Ghana

The Bank of Ghana's Guidelines for E-Money Issuers in Ghana, which came into effect on 6 July 2015, established the regulatory framework that opened Ghana's mobile money market to non-bank issuers and is widely credited with driving the country's rapid growth in digital financial inclusion. They replaced the earlier 2008 Guidelines for Branchless Banking, moving Ghana from a bank-led model to one in which dedicated, non-bank e-money issuers could operate. The guidelines apply to both banks and non-banks offering electronic money services and introduced the status of Dedicated Electronic Money Issuer (DEMI), under which a qualifying institution could be licensed to issue e-money alongside licensed financial institutions. They set the core prudential and operational rules for e-money: issuers must hold the full value of e-money issued in a pooled trust account (or accounts) with banks, keeping customer funds segregated and protected, and must ensure e-money is redeemable at par on demand. The guidelines famously required that interest earned on the float be passed to a structure benefiting e-money customers rather than retained by the issuer. They prescribe permissible transactions and tiered transaction and balance limits aligned to KYC levels, agent appointment and management rules, technology and security standards, AML/CFT compliance, consumer-protection and disclosure obligations, and reporting to the BoG. The 2015 guidelines were later given statutory backing and elaboration by the Payment Systems and Services Act 2019 (Act 987), which carried the DEMI concept into primary legislation; the guidelines therefore now operate alongside and subject to Act 987 and the BoG's updated licensing requirements. As the instrument that built Ghana's mobile money market, they remain a foundational reference for e-money regulation in the country.

1. 1Opened e-money issuance to non-banks via the Dedicated Electronic Money Issuer (DEMI) status; replaced 2008 branchless-banking guidelines
2. 2Full e-money value held in pooled trust accounts with banks; customer funds segregated, protected and redeemable at par
3. 3Interest on the float to benefit e-money customers, not retained by the issuer
4. 4Tiered KYC-based transaction/balance limits; agent appointment and management rules
5. 5Technology/security standards, AML/CFT, consumer protection and BoG reporting
6. 6Now read subject to and elaborated by the Payment Systems and Services Act 2019 (Act 987)