Bank of Ghana names three systemically important payment players

Bank of Ghana names three systemically important payment players

5 November 2026: The Bank of Ghana has issued a framework for identifying and supervising systemically important payment systems and service providers, and designated its first three: the Ghana Interbank Settlement (GIS) System, Ghana Interbank Payment and Settlement Systems (GhIPSS) and MobileMoney Fintech Ltd. The framework also lets the bank name software, platform, cloud and data-centre vendors as critical infrastructure service providers, though none has been named yet.

Not yet independently verified. The page title and file name for Notice 41 on the bank's site say Regulatory Framework for Dedicated Electronic Money Issuers, but the PDF carries the notice on designating systemically important payment systems, which we have used. The framework states no effective date or compliance deadline, and no critical infrastructure service provider is named in it. We will update this when it can be confirmed, and remove this note.

The three entities on the first list

Notice BG/GOV/SEC/2026/41, signed by Aimee Vyda Quashie as Secretary of the Bank, is addressed to banks, specialised deposit-taking institutions, dedicated electronic money issuers, payment service providers and other critical service providers. It rests on the Payment Systems and Services Act, 2019 (Act 987).

GIS, the real-time gross settlement platform the bank itself operates for high-value and time-critical payments, is designated a Systemically Important Payment System. GhIPSS and MobileMoney Fintech Ltd are each designated a Systemically Important Payment Service Provider. The bank says it will review the designations at least once every two years, looking at systemic importance, risk profile, market developments and compliance. The framework adds that the bank will publish and update a list of designated entities.

Who falls inside the scope

Section 4 of the framework covers large-value and retail payment systems, payment service providers and payment and financial technology service providers. It also reaches entities that provide critical infrastructure support and technology services to the financial industry, and it names platform-as-a-service providers, software-as-a-service providers, data centres, cloud service providers and customer due diligence platforms.

Being in scope is not the same as being designated. The framework sets three categories: the payment system (SIPS), the payment service provider (SIPSP) and the critical infrastructure service provider (CISP). For the third category it says classification and designation are limited to payment and financial technology service providers. A cloud or SaaS vendor that serves banks is described as in scope, yet the designation language points at the payment and fintech firms. The annexure defines a CISP as a non-financial provider, such as cloud, cyber or data services, whose operations are essential to designated systems and whose failure could pose systemic risk.

How the bank decides

The tests differ by category. A payment system qualifies if it handles at least one-third of national payment transactions by value or volume, or is the only infrastructure in the country for a type of transaction. A payment service provider can qualify with a market share above half of retail payments by value or three-quarters by volume, as the framework words it, or on operational criticality and difficulty of substitution.

A third-party provider is judged on seven points:

• dependence of payment systems on its infrastructure
• the systemic risk if it fails or is compromised
• how many designated providers it serves
• whether alternatives exist in the short term
• time-sensitive or high-value services
• links with other critical sectors
• exposure of sensitive financial data to cyber risk

The bank collects data, may consult the entity, evaluates it against the criteria and then issues a formal designation notice to the operator.

What designation demands

Designated entities face enhanced oversight in line with the CPMI-IOSCO Principles for Financial Market Infrastructures. Section 9 lists the duties: governance and risk management to international standards, legal certainty of settlement, real-time or same-day settlement with finality, strong know-your-customer and due diligence checks by payment providers, clear participation rules, crisis management plans and monitoring of links to other systems. Designated entities must publish information on governance, risk policies and performance, and must seek the bank's approval for significant operational, infrastructure or pricing changes. The bank evaluates them annually or as needed, using self-assessment reports they submit.

The gaps in the text

Neither the notice nor the framework states an effective date or a compliance deadline, and the framework cover reads September 2026, two months before the notice. No critical infrastructure service provider has been designated, so vendors cannot yet tell whether any of them will be. Questions go to the bank's Payment Systems Department.

Sources

• Bank of Ghana: Notice BG/GOV/SEC/2026/41, Designation of Systemically Important Payment Systems and Payment Service Providers in Ghana (PDF), 5 November 2026, 5 November 2026
• Bank of Ghana: Framework for Systematically Important Payment Systems and Service Providers in Ghana (PDF, cover dated September 2026), posted 5 November 2026, 5 November 2026