- Investor Money, Not Profits, to Fund SEC’s New Levy Regime
Ghana’s capital market regulator is facing mounting industry resistance over a steep increase in market levies for 2026, after operators warned that the new regime forces fund managers and intermediaries to pass regulatory costs directly to investors, regardless of whether their investments make profits or suffer losses.
A NorvanReports investigation into the Securities and Exchange Commission’s Guidelines on Market Levies for 2026, together with comments by industry players, shows growing concern that the regulator’s new levy framework does not merely raise the cost of doing business for licensed operators. It places ordinary investors’ money at the centre of the funding model.
The issue is no longer a narrow dispute between the SEC and regulated institutions. It is now a question for the investing public: should a regulator charged with “Ensuring Investor Protection” be allowed to impose levies that can be charged against the assets of investors, even when those assets have not generated positive returns?
The SEC guidelines state that they were issued pursuant to section 15 of the Securities Industry Act, 2016, Act 929, as amended by Act 1062, “for the payment of market levies.” The same document says the guidelines apply to market operators for the 2026 financial year.
But it is the scale, structure and enforcement tone of the levies that have triggered alarm across sections of the market. A comparative schedule reviewed by NorvanReports shows that almost every major category of regulated market operator has been hit with a 400% increase between 2025 and 2026.
Stock exchanges and securities depositories, which were paying GH¢50,000.00 in 2025, are now required to pay GH¢250,000.00. Issuing houses, custodians and primary dealers have moved from GH¢20,000.00 to GH¢100,000.00. Fund managers have moved from GH¢7,500.00 to GH¢37,500.00. Broker dealers, investment advisers and registrars have moved from GH¢5,000.00 to GH¢25,000.00.
The SEC’s own 2026 schedule confirms the new amounts. It sets the market operator levy at GH¢250,000.00 for a stock exchange, GH¢250,000.00 for a securities depository, GH¢100,000.00 for a primary dealer, GH¢100,000.00 for a custodian, GH¢100,000.00 for an issuing house, GH¢37,500.00 for a fund manager, and GH¢25,000.00 each for a broker dealer, investment adviser and registrar.
For large institutions, the fixed levy may be absorbed as another regulatory cost. For smaller and mid-sized operators, however, the increase changes the economics of compliance. It raises the minimum cost of staying licensed in a market where activity is still recovering from macroeconomic shocks, debt restructuring, weak confidence and thin secondary-market liquidity.
Industry players who reviewed the guidelines describe the move as disproportionate, warning that the SEC is layering fixed annual levies on top of existing transaction levies, issuance fees and admission levies. In their view, the regulator is not merely funding supervision; it is participating repeatedly in the same economic activity at different points in the investment chain.
Their concern is strongest in the asset-management space, where the guidelines explicitly make the levy a charge linked to funds under management. The SEC states that market levies are based on the Net Asset Value of funds under the management of a fund manager, excluding pension funds. It then sets the applicable 2026 levy rate at 0.225%.
The formula is even clearer. For the 2026 financial year, the amount on which the levy is based is the Net Asset Value of total funds under management, other than pension funds. The guideline says the levy shall be computed as 0.225% per annum multiplied by the NAV of non-pension funds under management, and calculated on the daily closing NAV.
That means the levy is not charged on profit. It is not charged only when a fund delivers positive returns. It is charged on the asset base itself.
This is the central investor-protection concern. If an investor puts money into a fund and the value of that investment declines because of market conditions, the levy is still calculated on the NAV. If yields are weak, the levy still applies. If returns are negative, the levy still applies. If the fund only breaks even, the levy still applies.
In practical terms, an investor can lose money and still have regulatory levies taken from the value of the investment. Over time, particularly in low-return or loss-making periods, repeated deductions can quietly erode capital.
The SEC guidelines also show how the money may be collected. Under the section titled “Method of collecting levies on FUM from clients,” the regulator says the fund manager must ensure that clients have enough funds in the trust account to meet the levy. The guidelines add that this may be done by keeping part of interest earned on investments in cash for the levy, or by the fund manager paying on behalf of the client and arranging reimbursement.
That provision is critical. It shows that the levy is not merely an institutional fee paid from the pocket of fund managers. The guideline contemplates the client’s trust account as the source of payment, or reimbursement from the client after the fund manager pays.
For investors, the meaning is direct: your money is the base. Your account is the collection point. Your yield can be withheld. Your capital can be affected.
This is why market participants are angry. They argue that the SEC is presenting the levy as a market-operator obligation while structuring part of the regime in a way that ultimately reaches into investors’ funds. Some fund managers say clients have already warned them not to remit “a cent” of their investment money to the SEC, threatening legal action if deductions are made without clear consent.
The regulator’s framework also creates enforcement pressure on fund managers. Market levies for the month are payable at the end of the month, and payment advice must be submitted to the Commission together with the funds-under-management report not later than 15 days after month-end.
Late payment attracts interest at the prevailing 182-day Treasury bill rate per annum at the beginning of the relevant quarter, calculated daily until the levy is fully paid. The guideline states that any interest on overdue levies shall be borne fully by the fund manager and must not be charged to funds under management.
That creates a second layer of pressure. The base levy may be drawn from client funds or reimbursed by clients. But if there is a delay, the penalty interest falls on the fund manager. This structure gives operators a strong incentive to pay promptly, even where clients object, because failure to comply can create additional cost exposure.
The sanctions provision adds further anxiety. The guidelines state that for non-payment of market levies, the Commission shall exercise its powers under section 209(4) of the Securities Industry Act, as amended.
Market operators who spoke to NorvanReports on condition of anonymity say the threat of sanctions has created a coercive atmosphere. Some allege that the SEC has refused meaningful engagement with the industry while warning institutions of possible regulatory consequences if they do not comply. The written guideline does not spell out in the levy document the specific sanction to be applied, but the invocation of statutory enforcement powers has intensified fears that licences could be put at risk.
For an industry that depends on regulatory goodwill, the threat is powerful. A broker dealer, fund manager, custodian or investment adviser cannot operate without SEC authorisation. Even where operators believe a levy is unfair, excessive or damaging to investors, few are willing to challenge the regulator openly.
This asymmetry is what some industry players describe as “virtual extortion” not necessarily because the SEC lacks statutory authority to impose levies, but because operators say they are being asked to pay sharp increases, with investors’ funds implicated, under the shadow of licence risk and without sufficient consultation.
The SEC may argue that levies are necessary to fund supervision, strengthen market integrity and protect investors. No serious market participant disputes the need for a well-funded regulator. Ghana’s capital market has suffered from weak supervision in the past, and investor protection requires resources, technology, enforcement capacity and skilled staff.
But the question is proportionality. Under the same guidelines, the SEC already receives transaction-based levies from market activity. The document states that the transaction levy shall be paid by purchasers and sellers of securities. For shares, 0.70% of the total transaction value is apportioned among the Ghana Stock Exchange, the Central Securities Depository, the SEC and the Market Development Fund, with the SEC receiving 0.15%.
For bonds, 0.01% of the value of trades is charged, with the SEC receiving 0.0025%. For repurchase transactions, both collateralised lending and Global Master Repurchase Agreement transactions are charged at 0.002% total fees payable by each party, with the SEC receiving 0.0006%.
This means the SEC earns from trading activity as it occurs. When investors buy and sell shares, the regulator receives a portion. When bonds trade, the regulator receives a portion. When repo transactions occur, the regulator receives a portion.
In their comments on the guidelines, industry players argue that broker dealers are already continuous contributors to SEC revenue because transaction levies are recurring, volume-linked and earned on both sides of market activity. They say the sharp increase in fixed broker-dealer levies adds a non-activity-linked charge to an already functioning activity-based revenue model.
The concern is not abstract. In an equity transaction, the SEC’s 0.15% share is taken from the value of the trade. In a bond trade, its 0.0025% share is tied to traded value. The more active the market becomes, the more the regulator earns.
That is a defensible structure when levies are activity-linked. It aligns regulatory revenue with market usage. But when fixed levies rise by 400.00% at the same time, the regulator earns both from the existence of the operator and from the transactions executed by that operator.
Issuing houses raise a related objection. Their work is episodic. A firm may spend months preparing a bond programme or equity offering, only for the transaction to be delayed, resized, withdrawn or cancelled because market conditions change. Yet regulatory processing fees and fixed annual levies can still apply.
Industry players who commented on the guidelines argue that SEC revenue from issuance activity is often front-loaded, while issuing houses carry commercial, execution and reputational risk. If a transaction fails after filings are made, the issuing house may earn no success fee, but the regulatory charges already paid may not be recoverable.
The guidelines also provide for an admission levy, previously known as an issuer fee. Fixed income securities issued by government, corporates and metropolitan or municipal assemblies attract an admission levy, with the SEC share stated at 0.003%.
In one illustration submitted by industry players, a GH¢1.00 billion bond programme with a GH¢300.00 million series could expose market participants to multiple SEC-related costs at the issuance point. Their example assumes a GH¢500,000.00 programme registration and application fee, a GH¢150,000.00 series registration fee, a GH¢9,000.00 SEC admission levy, a GH¢15,000.00 bond transaction levy on both sides, and GH¢125,000.00 in combined fixed annual levies for the issuing house and broker dealer.
On that illustration, total SEC participation at the issuance point reaches GH¢799,000.00 before any secondary-market turnover and irrespective of whether the issuing house ultimately earns a success-based fee.
In another example, industry players model a GH¢700.00 million standalone equity offering on the Ghana Stock Exchange, with a broker commission of 0.80%. The broker’s gross commission would be GH¢5.60 million before operating and compliance costs. The SEC’s 0.15% equity transaction levy would amount to GH¢1.05 million, or about 18.75% of the broker’s gross commission, before fixed annual levies and other filing costs.
When a GH¢21,000.00 SEC admission levy and GH¢125,000.00 combined fixed annual levies are added, industry players estimate total SEC participation at the issuance point at GH¢1.196 million, excluding additional filing or review fees.
The figures may be illustrative, but they expose the industry’s deeper complaint: the regulator is not simply collecting a modest supervisory fee. It is extracting value at several stages of the same transaction chain from operator licensing, from investor trades, from issuance, from admission and from funds under management.
That cumulative effect could reshape behaviour across the market. Broker dealers may become less willing to intermediate low-margin trades. Issuing houses may reassess smaller mandates that carry high regulatory costs relative to fees. Fund managers may face client resistance if investors see deductions linked to SEC levies. Smaller firms may question whether remaining licensed is economically viable.
The risk is that regulation designed to protect the market could end up weakening it. Capital markets depend on depth, competition and trust. When the cost of compliance rises too sharply, smaller operators are squeezed out or forced to consolidate. When transaction costs are perceived as excessive, investors trade less. When issuers believe regulatory charges are too high, they avoid formal capital-market fundraising. When fund clients suspect their returns are being quietly reduced by levies, confidence weakens.
The outcome could be thinner liquidity, fewer transactions, fewer listings, fewer bond issuances and greater migration of activity away from regulated structures.
This would be a damaging result for Ghana. The country needs a deeper capital market, not a narrower one. It needs more corporate bond issuance, more equity listings, more institutional participation, more transparent collective investment schemes and stronger investor confidence. The state also needs a functioning domestic capital market to support long-term financing after the shock of debt restructuring.
A levy regime that burdens operators and investors simultaneously risks moving the market in the opposite direction.
There is also a predictability problem. The comparative data reviewed by NorvanReports shows that many levy categories were unchanged between 2023 and 2025, before jumping by 400.00% in 2026. In the absence of a published levy-setting methodology, objective criteria, transition period or explicit cap, operators say there is no assurance that another sharp increase will not occur in future.
That uncertainty matters. Financial institutions plan budgets, compliance costs, staffing and product pricing around regulatory assumptions. If the regulator can reset fixed levies by 400.00% without a transparent formula, regulated entities cannot reliably plan. Investors also cannot easily know how future regulatory costs may affect returns.
Regulatory predictability is not a favour to industry. It is a pillar of market confidence. The SEC’s mandate is investor protection. But investor protection is not achieved only through enforcement. It is also achieved through proportional regulation, fair charges, transparent consultation, predictable rules and trust between the regulator, operators and the investing public.
The most troubling part of the 2026 levy debate is that the investor may not fully understand that they are part of the payment structure. The levy is presented as a market levy. The obligation appears to sit with market operators. But in the FUM provisions, the SEC expressly links the levy to clients’ trust accounts, retained interest and reimbursement from clients.
That is not a technical detail. It is the heart of the matter. If a fund manager holds GH¢100.00 million in non-pension assets, a 0.225% annual levy implies GH¢225,000.00 in regulatory levy on that asset base. If the fund performs strongly, investors may barely notice the deduction. But if returns are weak, flat or negative, the levy becomes more visible. It reduces distributable return. It can deepen losses. It can, over time, contribute to capital erosion.
This is why investors must pay attention. The debate is not only about fund managers defending margins. It is about the net return on investor money.
To be fair, regulatory levies exist in many markets. Regulators require funding to supervise complex financial systems. The issue is not whether the SEC should be funded. The issue is whether the chosen method is proportionate, transparent and aligned with market development.
A better approach may be possible. Industry players have proposed moderating fixed annual levies, especially for broker dealers and issuing houses, in recognition of the SEC’s existing transaction-based and issuance-linked revenue. They also recommend relying more on activity-linked fees that rise with market usage and supervisory effort, rather than imposing uniform step increases on all operators.
They further propose tiered fixed levies based on firm size, transaction frequency or mandate activity, so that smaller firms are not forced to carry the same proportional burden as larger institutions. Finally, they want the SEC to publish a clear levy-setting framework to improve predictability and regulatory confidence.
Those proposals are not anti-regulation. They are pro-market. A regulator can be well funded without imposing a cost structure that discourages participation. Investor protection and market development should not be treated as competing objectives.
The SEC now faces a credibility test. It can insist on enforcement and push the industry into reluctant compliance. Or it can open a transparent consultation, explain the basis for the increases, publish its levy methodology, assess the impact on investors and consider a phased or tiered structure.
The latter path would better serve the market. Ghana’s capital market is still rebuilding trust after years of financial-sector turbulence. The SEC cannot protect investors by making investors feel that their own money is being used to fund unexplained regulatory increases. It cannot deepen the market by raising the cost of regulated intermediation beyond what many firms consider sustainable. It cannot strengthen confidence by appearing unwilling to engage the industry it supervises.
The Commission’s motto is “Ensuring Investor Protection.” The 2026 levy regime now raises a blunt question: protection at whose cost?
If the answer is the investor, then the investing public deserves to know before another deduction is made.
