- Protecting the Digital Commons: Why the BoG’s Pause on the 0.75% MoMo Fee Must Spark a Fairer Retail Banking Directive
Authored by: Nana Agyei Opoku-Agyemang
The views expressed are personal and do not reflect the official position or policies of any organization, board, or institution with which the author is affiliated.
The Bank of Ghana’s (BoG) recent directive to Mobile Money Fintech Limited (MMFL)—MTN Ghana’s standalone fintech subsidiary that operates the MTN Mobile Money service to suspend its proposed 0.75% wallet-to-bank transfer fee is a highly commendable regulatory intervention. Scheduled to take effect on June 1, 2026, the fee was swiftly frozen by the central bank to allow for “broader stakeholder consultation.”
Predictably, the announcement triggered immediate political finger-pointing. However, viewing this through a strictly partisan lens misses the structural realities of Ghana’s digital financial architecture. As independent analysts, we must strip away the political noise and look at the hard numbers, the misaligned definitions, and the fundamental unfairness embedded in our retail banking framework.
Setting the Record Straight: A Commercial Fee, Not a Tax
First, let us correct the common misconception: this proposed 0.75% charge is not a reincarnation of the electronic transfer levy (E-levy). The e-levy was a tax. It was created by an Act of Parliament (the Electronic Transfer Levy Act, 2022, Act 1075), administered by the Ghana Revenue Authority, and its proceeds flowed to the state. It launched at 1.5% in May 2022 (down from an originally proposed 1.75%), was reduced to 1% in 2023, and was repealed by Act 1128 with effect from 2 April 2025. It carried no upper ceiling on a GHS 100 million electronic transfer, you would have paid GHS 1 million and it reached well beyond mobile money to cover bank transfers and merchant payments too.
The Proposed 0.75% Fee is a commercial tariff proposed by a private business entity to generate revenue, subject to a flat cap of GHS 5 per transaction. While structurally distinct from a state tax, the commercial nature of this fee does not absolve it from systemic scrutiny.
The Scale of Impact: MoMo is Ghana’s True Financial Infrastructure
The argument that this fee would only impact a minor segment of transactions ignores the profound democratization of mobile money in Ghana. A GHS 5 cap sounds harmless until you remember who it touches. MTN Ghana reported 19.3 million active Mobile Money users at the end of 2025. To put that in perspective, Ghana’s entire adult population (18 and above) was 17.9 million at the 2021 Census and is ~19–20 million today. The active user base of MMFL/MTN MoMo is roughly equal to every adult in the country.
Because many citizens operate multiple wallets or utilize MoMo as their main conduit for business and personal livelihood, a wallet-to-bank fee does not just affect “tech users” it shifts the cost of basic financial liquidity for virtually every working-class Ghanaian and micro-enterprise in the country.
Double Standard: Why Are Banks Allowed to Charge “Self-Transfers”?
While the BoG is right to hold MMFL accountable, the central bank must apply this exact standard of consumer protection across the entire financial ecosystem.
For years, commercial banks in Ghana have quietly penalized consumers for moving money from their traditional bank accounts to their own mobile money wallets. This raises a critical question regarding global best practices and foundational fairness: Why does a transaction involving the exact same beneficiary attract a commercial levy?
In advanced financial systems, moving money between accounts held by the exact same verified individual (e.g., from a checking account to a savings account, or to a linked digital wallet) is globally recognized as an internal liquidity transfer. Under international consumer protection principles, charging a client to access their own money across platforms managed by the same or interconnected clearinghouses is considered an unfair friction that discourages formal financial inclusion. This is not radical. It is where the rest of the world is heading. Brazil’s Pix and India’s UPI the two largest instant-payment systems on earth, both cited by the World Bank as engines of financial inclusion are free for individuals by deliberate design, precisely because friction on everyday transfers is friction on the cashless economy itself. Ghana’s own experience proved the same point in reverse: when the e-levy raised the cost of moving money, people moved less of it electronically and reached for cash instead.
We say we want a cash-lite economy. We cannot tax and levy our way there. A directive that protects own-account transfers, applied even-handedly to banks and telcos/fintechs alike, would do more for financial inclusion than any number of suspended fees. Let that sink in. The E-levy, a tax the public openly resented, did not charge you for paying yourself. Unfortunately the banks have been charging for self-transfers/own-account transfers, and a private fee was about to until the BoG pulled the breaks.
Banks frequently argue that these levies fund the maintenance of their digital bridges and Application Programming Interfaces (APIs). But that defense falls flat under scrutiny:
- Double-Dipping on Fees: Banks already charge monthly account maintenance fees, SMS alert tokens, and periodic platform ledger fees simply for holding a user’s account active.
- Standard Transaction Monetization: Banks already monetize transactional velocity by charging outward fees whenever a user transfers funds to other distinct beneficiaries.
- The Float Advantage: Commercial banks benefit immensely from the mobile money ecosystem. They hold the massive cash “float” (the cash backing the digital money) in escrow, using these low-cost deposits to fund their own balance sheets, overnight lending, and money market investments earning yield on customer funds while simultaneously charging those same customers a fee to access them.
Allowing banks to charge customers for shifting their own money into a MoMo wallet gives traditional financial institutions an unfair, asymmetric advantage over both consumers and telcos/fintechs. The result is an uneven field. Banks have been permitted to charge customers for moving money to their own accounts, and to draw value from the very mobile money ecosystem they now compete with. Asking only MMFL to pause, while the banks’ identical practice goes unchecked, would treat the symptom and ignore the disease.
The Path Forward: A Universal Directive for “Self-Transfers”
If the Bank of Ghana truly wants to protect consumer well-being and drive the nation toward a sustainable, cash-lite economy, its final directive must be comprehensive and structural, not piecemeal. The standard expected from a fair and forward-thinking regulator is clear:
Zero-Rated Self-Transfers: All electronic transfers where the sender and the receiver are the exact same individual whether moving from Bank to MoMo or MoMo to Bank must be completely free of commercial charges and regulatory levies.
Validation via the Ghana Card: Verifying account ownership is no longer a technical hurdle. Just as it was implemented during the national SIM registration and E-levy eras, a customer’s unique Ghana Card identity can seamlessly validate and link bank accounts to mobile wallets. If the identity matches, the transaction cost should be zero.
Commercial Pricing for Third-Party Services: Fintechs/Telcos and banks should absolutely remain free to price and monetize commercial value-added services, peer-to-peer (P2P) transfers to other individuals, and merchant payments.
Conclusion
The Bank of Ghana’s intervention was a necessary action, but it must now evolve into a structural blueprint. Penalizing citizens for moving their own hard-earned money between their own accounts is a regressive friction. True regulatory equity means ensuring that a Ghanaian’s money remains entirely theirs to move, whichever wallet they choose to keep it in.
