Ghana orders payment firms to ring-fence merchant money

Ghana orders payment firms to ring-fence merchant money

6 November 2026: Payment service providers in Ghana may not hold, use, pledge or otherwise treat as their own the money they collect for merchants, the Bank of Ghana said in Notice BG/GOV/SEC/2026/43. That money must sit in designated settlement accounts at approved settlement banks, separate from the provider's operating accounts, and reach merchants within the periods their service agreements set.

Not yet independently verified. The notice tells providers to take immediate steps and names no effective date, grace period, fine amount or sanction. We read the notice PDF and the bank's notice page; the notice does not say what prompted it. We will update this when it can be confirmed, and remove this note.

Whose money it is until settlement

The notice, issued under Section 101 of the Payment Systems and Services Act, 2019 (Act 987) and signed by the Secretary of the Bank, Aimee Vyda Quashie, reminds providers of a basic point: they are licensed to facilitate payments and collect funds for merchants, but they are not deposit-taking institutions. Funds collected for a merchant stay the merchant's property until settlement is made under the terms and timelines of the service level agreement between the provider and that merchant.

Seven obligations for providers and banks

The notice lists seven requirements:

1. Collected funds go into the designated settlement account and are not commingled with the provider's operational funds.
2. Providers settle into the merchant's designated bank account strictly within the agreed settlement period.
3. Providers may not withdraw, transfer, pledge, place a lien on, set off against or otherwise encumber the money, except to settle to the merchant and to take fees and charges they have earned.
4. Settlement banks must run these accounts solely for settlement and must not let a provider use the money for operations, financing, investment or anything unrelated to merchant settlement.
5. The provider's fees and commissions can move to its operating account only as part of the settlement process and in line with the commercial terms agreed with the merchant.
6. Providers and settlement banks must keep adequate records, controls and audit trails showing safeguarding, segregation and timely settlement.
7. The bank may require settlement banks to submit statements of these accounts, at intervals and in a manner it decides.

Timing and consequences

The notice sets no grace period. It tells providers and settlement banks to take immediate steps to ensure full compliance and to review their operational arrangements, agreements and internal controls. Failure to comply is described as a breach of the applicable regulatory framework that may attract regulatory, supervisory and enforcement action. It names no fine, licence sanction or amount.

Where the rules meet payment software

The text regulates money flows, but the controls it asks for would live in software. A payment gateway, aggregator or merchant platform that sits on a provider's settlement flow would need to show that collected funds are tracked apart from the provider's own balances, that fees are deducted inside the settlement run rather than separately, and that settlement dates in the ledger match the periods in each merchant contract. Records, controls and audit trails are named duties, so the logs and reconciliation reports these systems produce are the natural evidence a provider could show the bank.

For merchants the notice states the position plainly: the money is theirs until it is settled under the service level agreement, and the provider may touch it only to settle to the merchant and to take fees it has earned.

The notice lists the FinTech and Innovation Department of the Bank of Ghana, at 42 Castle Road in Accra, as the contact for further information.

Sources

• Bank of Ghana: Notice BG/GOV/SEC/2026/43, Management of Merchant Collection Funds by Settlement Banks and Payment Service Providers (PDF), 6 November 2026, 6 November 2026
• Bank of Ghana: Notice No.43 page (read 11 November 2026), 11 November 2026