- Mobile Money: Ghana’s Financial Inclusion Miracle Now Posing a Financial Stability Threat
Ghana’s mobile money revolution has brought millions of people into the financial system, changed how households pay for goods, strengthened informal commerce and reduced dependence on cash. But the same system that has become one of the country’s most visible financial inclusion successes may now be creating a new and underappreciated threat to financial stability.
That is the central warning from Dr Richmond Atuahene, a banking and finance expert, in a new analytical paper titled Mobile Money: A Threat to Ghana’s Financial Stability. His argument is not that mobile money has failed Ghana. It is that mobile money has become too important to be treated merely as a convenient payments product. In his view, the scale, dominance, interconnectedness and risk profile of Ghana’s mobile money ecosystem now require a deeper regulatory rethink.
The paper points to National Communications Authority figures showing that MTN Ghana controlled 81.29% of the country’s mobile data subscriptions as of February 2026, compared with 14.50% for Telecel and 4.21% for AT Ghana. It further notes that MTN Mobile Money has more than 19.3 million active users, placing the platform at the centre of Ghana’s digital finance and telecom ecosystem.
Those figures matter because financial stability risk often begins where convenience becomes dependence. A payments platform used by a few people is a service. A payments platform used by millions for daily commerce, utility payments, remittances, savings-like balances, merchant transactions and access to credit begins to resemble national infrastructure. If that infrastructure fails, the shock does not remain with one company. It travels through households, traders, banks, agents, merchants and the wider economy.
Dr Atuahene describes this as a “too big to fail” concern. The concept is familiar in banking: when an institution becomes so large and interconnected that its collapse could damage the whole economy, regulators are forced to treat it differently from smaller firms. His argument is that Ghana must now ask whether dominant mobile money operators, especially MTN Mobile Money, have reached that threshold.
The paper explains the risk in simple terms. Ghana’s financial system is like a web. Banks, mobile money operators, telecom networks, agents, merchants, customers and government payments are linked. If one major node fails, the entire web shakes. A technical outage, cyberattack, fraud event, liquidity shortfall or collapse of confidence at a major mobile money provider could freeze transactions for millions of people and disrupt small businesses that depend on instant payments.
That concern is not theoretical. Mobile money has become the cash register of the informal economy. It is the wallet for traders, the payment rail for transport operators, the settlement system for small shops, the remittance channel for families and the financial entry point for people who may never open a traditional bank account. If it stops working, the impact is not limited to digital finance. It can affect food markets, transport, retail trade, utility payments and household consumption.
The deeper issue is that mobile money now performs bank-like functions without being regulated exactly like a bank. Dr Atuahene argues that telecom-led mobile money operators hold large pools of customer wallet balances, often referred to as float, through trust accounts with commercial banks. Although these funds are expected to be backed and safeguarded, the customer relationship, operational control and liquidity flows remain heavily influenced by the mobile money operator.
In Dr Atuahene’s view, that creates a form of shadow banking. Shadow banking refers to financial activities that perform bank-like functions outside the full prudential framework applied to banks. The paper argues that mobile money operators provide access to payments, savings-like balances and credit-linked services, while not facing the same capital adequacy, liquidity, deposit insurance, reporting and supervisory intensity required of commercial banks.
This is where the regulatory dilemma begins. Ghana wants innovation. Ghana wants financial inclusion. Ghana wants more digital payments and less cash. But the country also needs to ensure that firms holding or controlling financial value at scale cannot create systemic risk in the name of innovation.
Dr Atuahene’s argument is that the old regulatory distinction between banks and payment service providers is becoming less useful. If a mobile money operator behaves like part of the financial system, holds value like part of the financial system, supports payments like part of the financial system and can transmit shocks like part of the financial system, then it must be regulated according to the risk it creates.
That leads to one of the most important ideas in the paper: activity-based regulation. The principle is straightforward. Regulators should not focus only on the legal identity of the institution. They should focus on what the institution actually does. If a bank, telecom operator or fintech offers a product that creates similar financial risks, similar rules should apply. A savings-like product should not escape core safeguards simply because it sits on a phone rather than inside a bank branch.
This does not mean every small fintech should be regulated like a large bank. Dr Atuahene argues for proportionate regulation. Small, low-risk payment providers should not be crushed by heavy compliance costs. But large, systemically important mobile money operators should face stronger capital buffers, liquidity requirements, corporate governance standards, recovery planning, cyber-security obligations and oversight.
The logic is hard to dismiss. A small rural payments provider does not carry the same risk as a platform used by nearly 20 million people. Regulation must therefore scale with size, complexity and systemic importance. If mobile money is now critical financial infrastructure, then Ghana must stop supervising it as though it were still an experimental add-on to telecom services.
The paper also raises a monetary policy concern. Central banks influence inflation, credit and liquidity partly through the banking system. When money sits in bank deposits, it is visible to the central bank and affected by reserve requirements, liquidity rules and interest rate transmission. But if large volumes of transactional money move through mobile wallets and telecom-controlled ecosystems, the transmission of monetary policy may become weaker.
Dr Atuahene argues that the massive volume of digital currency circulating through mobile wallets can reduce the effectiveness of traditional monetary policy tools. His concern is that if households and businesses increasingly use mobile money instead of banks to store and move money, then the Bank of Ghana may have less direct control over liquidity conditions in the economy.
This issue matters in a country where inflation management remains politically and economically sensitive. Ghana has spent years trying to restore macroeconomic stability after a painful period of high inflation, currency pressure and fiscal stress. If the structure of money circulation is changing, then monetary policy frameworks must also evolve.
The banking sector implications are equally important. Mobile money has expanded access, but it has also shifted customer behaviour away from traditional banks. Many people now store short-term funds in wallets, receive payments through wallets and conduct daily transactions without entering a banking hall. This can reduce deposits available to banks, affect credit-to-deposit ratios and weaken banks’ capacity to extend loans to businesses.
That does not mean mobile money is bad for banks in every case. Banks also benefit from partnerships, float accounts, settlement services and digital integration. But Dr Atuahene’s concern is that the balance may be shifting too far. If mobile money captures the customer relationship and the transactional liquidity while banks carry heavier regulatory burdens, the result could be unfair competition and weaker bank profitability.
This is the regulatory arbitrage problem. Banks must meet strict prudential standards, including capital, liquidity and reporting requirements. Mobile money operators, though regulated, are often treated more lightly because they are classified as payment service providers rather than deposit-taking institutions. That gap can give mobile money operators a cost advantage while creating supervisory blind spots.
The paper warns that such gaps can become dangerous during stress. Bank deposits are protected within a formal banking safety architecture. Mobile money funds are safeguarded through trust arrangements, but the public may not fully understand the difference. If a major mobile money operator fails or experiences a severe liquidity gap, millions of users could suffer loss of access to funds, even if the legal structure of the float is technically separate.
Recent regulatory actions by the Bank of Ghana make this debate even more urgent. The central bank has shown that failures around e-money backing are not abstract. If any issuer creates electronic value without sufficient backing, the risk goes directly to consumers, agents, merchants and confidence in the payments system. In that context, Dr Atuahene’s call for stronger float management and bank-level safeguards for major operators becomes more than a theoretical proposal.
Fraud is another central pillar of the paper. Dr Atuahene identifies phishing, fake calls, SIM swap fraud, malware-assisted credential theft, business email compromise and social engineering as major threats. He cites the Bank of Ghana’s 2025 fraud report, noting that fraud incidents reported by payment service providers rose by 54.00% to 24,124 cases in 2025 from 15,673 in 2024, while value at risk increased by 95.00% from GH¢19.00 million to GH¢37.00 million.
These figures show that fraud is migrating to where the money is moving. As transactions shift from bank counters to mobile wallets and digital platforms, fraudsters follow. They do not need to break into a bank vault if they can trick a customer into revealing a PIN, approving a transfer, clicking a malicious link or surrendering control of a SIM card.
This is why digital trust is now a financial stability asset. A payments system depends on confidence. If users believe mobile money is unsafe, they may withdraw from digital channels, return to cash or reduce formal transactions. That would weaken financial inclusion and damage Ghana’s broader digital economy agenda.
The problem is more severe because mobile money fraud often affects low-income users. A salaried worker with access to a bank may recover more easily from a small loss. A market trader who loses working capital from a mobile wallet may lose the ability to trade the next day. Fraud therefore becomes not only a consumer protection issue but also a livelihood issue.
Dr Atuahene also warns about illegal and unauthorised mobile loan applications. These lenders, he argues, impose opaque and excessive interest rates, misuse personal data and engage in coercive debt collection. The danger is that digital credit, if unregulated, can push vulnerable users into over-indebtedness.
This risk is growing because mobile money is no longer just a payments platform. It is increasingly a gateway to credit, insurance, savings products, merchant finance and cross-border remittances. Once a wallet becomes a financial identity, the risk profile changes. Regulators must then worry about credit risk, data privacy, consumer abuse, loan pricing, debt collection practices and systemic exposure.
Money laundering is another concern. Mobile money accounts can be used for legitimate micro-transactions, but that same feature can be exploited to break illicit funds into smaller transfers. If onboarding, monitoring and enforcement are weak, criminal networks can use wallets to move money across accounts and regions under the cover of ordinary transactions. Dr Atuahene therefore calls for stronger know-your-customer systems, enhanced transaction monitoring and closer anti-money laundering supervision.
The paper draws lessons from international experience, including Kenya’s M-Pesa. Kenya’s experience shows both the promise and the regulatory complexity of mobile money. M-Pesa transformed financial inclusion, but it also raised questions about market dominance, fund ownership, cross-sector regulation, reversals, competition and systemic importance. Ghana, Dr Atuahene suggests, should learn from these lessons before a crisis forces reform.
His proposed regulatory direction rests on five broad pillars.
The first is activity-based regulation: same risk, same rule. If mobile money performs deposit-like, credit-like or payment-system-critical functions, the rules should reflect those functions. The second is proportionate bank-level regulation for systemically important operators. Large mobile money companies should maintain 100.00% customer float in secure trust accounts at prudentially regulated banks, meet capital and liquidity requirements, adopt strong corporate governance, connect fairly to national payment infrastructure and meet enhanced cyber-security and data protection standards.
The third is the use of regulatory sandboxes. These allow fintechs to test new products under controlled supervision without granting permanent exemptions that can become loopholes. The fourth is enhanced supervisory coordination among the Bank of Ghana, National Communications Authority, Cyber Security Authority, competition regulators and data protection authorities. The fifth is risk-based regulation, where supervisory effort is focused on the institutions and activities that pose the greatest threat.
This is a practical agenda. It does not kill innovation. It recognises that innovation without safeguards can eventually destroy the trust that allowed innovation to grow.
The ordinary Ghanaian may ask: why should this matter if MoMo works every day? The answer is that financial stability risks often remain invisible until they become visible all at once. Before a bank run, depositors trust the bank. Before a cyberattack, customers trust the platform. Before a liquidity shortfall, users assume their balances are safe. Stability is built by preparing before panic begins.
That is why the timing of Dr Atuahene’s warning is important. Ghana’s mobile money ecosystem is already too large to ignore. It is embedded in commerce, remittances, banking partnerships, public payments and informal-sector survival. The country cannot wait until a major outage, fraud scandal or liquidity event occurs before deciding whether the current regulatory structure is adequate.
The article’s most thought-provoking implication is this: Ghana may have built a second financial system on top of the first one. The first is visible: banks, branches, regulators, capital requirements and deposit protection. The second is digital: wallets, agents, telecom networks, APIs, mobile loans, remittances and instant transfers. The second system is faster, more inclusive and more convenient. But it may also be more concentrated, more exposed to cyber fraud and less fully integrated into traditional financial stability oversight.
The answer is not to slow mobile money. That would be economically harmful and socially regressive. The answer is to regulate it according to what it has become.
Mobile money is no longer a side product. It is national financial infrastructure. That infrastructure must be protected with the seriousness given to banks, payment switches, settlement systems and critical telecom networks.
Dr Atuahene’s warning should therefore be read not as an attack on MTN, fintechs or digital finance, but as a call for Ghana to update its regulatory imagination. The country must preserve the gains of financial inclusion while reducing the risks of concentration, shadow banking, fraud, money laundering, weak monetary transmission and regulatory arbitrage.
The Bank of Ghana, Financial Stability Council, Ministry of Finance, National Communications Authority, Cyber Security Authority and telecom operators all have roles to play. No single regulator can manage a system that crosses telecoms, banking, payments, data, competition and cyber-security. This requires coordinated supervision, shared data, joint stress testing and clear accountability.
Ghana’s financial future will be digital. That is no longer in doubt. The question is whether it will also be safe.
If Ghana gets the balance right, mobile money can continue to support inclusion, trade, remittances, small businesses and digital growth. If it gets the balance wrong, the very platform that brought millions into the financial system could become the channel through which the next financial stability shock travels.
Mobile money has changed Ghana. Regulation must now catch up before convenience becomes vulnerability.
