Bank of Ghana orders payment firms to ring-fence merchant funds

The Bank of Ghana has directed payment service providers (PSPs) and settlement banks to keep money collected for merchants in separate settlement accounts, preventing the funds from being used for business operations.

The instruction is contained in notice BG/GOV/SEC/2026/43, dated Friday, November 6, 2026 and published on Monday, November 9. It takes effect immediately and applies to both payment providers and settlement banks.

The directive was signed by the Bank of Ghana’s secretary, Aimee Vyda Quashie, under Section 101 of the Payment Systems and Services Act, 2019 (Act 987).

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As part of the immediate compliance requirements, payment providers and settlement banks must review their agreements and internal controls. The measure forms part of the central bank’s supervision of digital payments and fintech operations.

The Bank of Ghana said licensed PSPs are authorised to process transactions and collect payments for businesses, but are not deposit-taking institutions. They are therefore prohibited from holding, pledging, encumbering or exercising ownership rights over money collected for merchants.

“Such funds shall remain the property of the respective merchants until settlement is effected in accordance with the terms and timelines specified in the Service Level Agreement (SLA) executed between the PSP and the merchant,” the notice stated.

The rule applies to shops, online sellers and service businesses that accept digital payments through a gateway. In practical terms, money paid by customers remains legally owned by the merchant from the point at which the payment is made.

The funds must be held in a ring-fenced settlement account rather than in the payment company’s operating account. This means a provider cannot use merchant collections to pay its own expenses, finance investments or secure loans.

Payment firms are required to transfer the money collected to each merchant’s designated bank account within the settlement period set out in their contract.

While settlement is being completed, providers may transfer only earned fees, commissions or charges into their own business accounts.

The notice states that payment providers must not withdraw, transfer, pledge, place a lien on or set off against merchant funds held in a settlement account under any circumstances. Settlement banks are also prohibited from allowing payment companies to access those accounts for operational, financing or investment purposes.

Both groups must maintain full records and audit trails. The Bank of Ghana may also require settlement banks to provide account statements at intervals determined by the central bank.

The regulator, which has previously imposed strict sanctions for breaches of its rules, warned that failure to follow the directive would constitute a regulatory breach and lead to supervisory and enforcement action.

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