- When MoMo Becomes Banking: Is Ghana’s Regulatory System Ready?
Ghana’s mobile money revolution, long celebrated as one of Africa’s most successful financial inclusion stories, is entering a more difficult phase: the point at which a tool built to serve the unbanked begins to look systemically important enough to test the country’s financial stability framework.
A new paper by banking and finance expert Dr Richmond Atuahene argues that Ghana’s mobile money ecosystem has delivered undeniable benefits, giving millions of previously unbanked people access to payments, savings, credit and insurance through simple mobile devices. But the same system, he warns, now faces complex regulatory, technological and economic risks that cannot be managed with yesterday’s light-touch supervisory assumptions.
The warning is timely. Mobile money is no longer a peripheral payment channel used mainly for small transfers. It is now one of the principal arteries of Ghana’s consumer economy. Bank of Ghana data show that mobile money transaction value reached GH¢493.20 billion in April 2026, involving 967.00 million transactions. Registered mobile money accounts rose to 83.00 million, while active accounts stood at 26.00 million, with active agents rising to 534,000.
At that scale, the question is no longer whether mobile money promotes inclusion. It clearly does. The more urgent question is whether Ghana’s regulatory architecture has kept pace with the power, complexity and concentration of the ecosystem it helped create.
Dr Atuahene’s central concern is regulatory arbitrage. Traditional banks operate under tight prudential regulation, including capital adequacy rules, liquidity requirements, deposit insurance obligations, licensing processes and extensive reporting duties. Mobile money operators, by contrast, are generally regulated as payment service providers rather than deposit-taking institutions, often facing lighter capital requirements and less intensive supervision.
This gap made sense during the early years of mobile money. Heavy bank-style regulation could have strangled innovation, raised compliance costs and slowed financial inclusion. But the success of mobile money has altered the risk equation. What was once a small, low-value digital convenience has become a mass-market financial infrastructure.
Ghana’s model also creates blurred accountability. Under the bank-led partnership framework described by Dr Atuahene, mobile network operators partner with licensed banks to offer mobile money services. The bank manages the float and holds the licence-related financial responsibility, while the mobile operator brings the brand, customer base, technology and agent network.
That layered structure creates a governance problem. When something goes wrong, who is truly responsible: the bank that holds the float, the mobile network operator that controls the customer relationship, the agent who executes the cash transaction, or the regulator whose mandate sits across banking, payments and telecommunications?
The answer matters because mobile money is no longer only about convenience. It is about trust. And trust can evaporate quickly in a digital system where millions of users may not understand the legal distinction between a bank deposit, an electronic wallet balance and a telecom-enabled payment service.
Dr Atuahene argues that lighter regulation has helped mobile money expand access, particularly among rural populations and women, but has also introduced vulnerabilities around consumer protection, data privacy and systemic stability.
Those vulnerabilities are already visible in fraud data. The Bank of Ghana’s 2025 Fraud Report showed that reported fraud cases across banks, specialised deposit-taking institutions and payment service providers increased by 48.00% to 24,778 cases in 2025, from 16,733 in 2024. Total value at risk rose from GH¢99.00 million to GH¢101.00 million, with the rise driven largely by payment service providers and digital payment platforms.
Separate cybersecurity data cited in the paper show that between January and September 2025, Ghana recorded more than 2,000 cybercrime incidents, many linked to mobile money fraud, with losses exceeding GH¢19.00 million for individuals and businesses.
The policy dilemma is uncomfortable. The same low-friction access that made mobile money powerful also makes it attractive to fraudsters. Strict Know Your Customer rules help prevent money laundering and financial crime, but heavy identification requirements can exclude vulnerable users, especially those in rural areas or informal work. Dr Atuahene notes that regulators must balance inclusion with security, fraud prevention, cybersecurity, liquidity management and consumer complaints resolution without stifling innovation.
This is where Ghana must resist two extremes. One extreme is to leave mobile money largely as it is, assuming that its inclusion benefits outweigh the risks. The other is to regulate it exactly like banking, regardless of its distinct structure and lower-value transaction model. Both approaches would be wrong.
The better path is proportional regulation: tougher rules where risk is high, lighter rules where risk is low, and equal treatment where different institutions perform the same financial function.
Dr Atuahene recommends that Ghana adopt an activity-based regulatory framework, under which the same rules apply to the same financial activity regardless of whether it is provided by a bank, mobile network operator or fintech. The principle is simple: “same activity, same regulation.”
That idea is powerful because digital finance is unbundling banking. A company may not be a bank, but it may perform one banking-like function: payments, savings, lending, merchant acquiring, remittances or wallet-based credit. If regulation focuses only on institutional labels, risks migrate to the weakest perimeter. If regulation follows the activity, the loophole narrows.
But activity-based regulation must be designed carefully. Dr Atuahene cautions that activities must be defined precisely, otherwise regulatory arbitrage can persist. Overly prescriptive rules may also struggle to capture rapidly changing fintech models and may unintentionally constrain innovation.
His second major recommendation is risk-based regulation. This would direct supervisory resources toward firms, activities and market structures that pose the greatest potential harm to consumers, financial stability and policy objectives. It would also allow regulators to reduce unnecessary burdens on low-risk operators.
For Ghana, the case for risk-based oversight is reinforced by market concentration. The National Communications Authority’s February 2026 data show that MTN Ghana held 81.29% of mobile network data subscriptions, compared with 14.50% for Telecel and 4.21% for AT. While data-market share is not the same as mobile money market share, it speaks to the broader network dominance that underpins digital distribution power.
Dr Atuahene’s paper argues that concentration risk is one of the defining concerns in mobile money markets, particularly where one dominant provider becomes deeply embedded in retail payments and the wider banking system. It notes that a severe operational disruption or loss of confidence in the leading provider could have widespread effects on retail payments and financial access.
This is Ghana’s “too big to fail” question in new clothing. It is no longer only a bank with a weak balance sheet that can threaten stability. A mobile money outage, cyberattack, float mismanagement failure or fraud contagion could disrupt payments for households, traders, transport operators, churches, schools, farmers and small businesses across the country.
The float is particularly important. Mobile money operators hold large pools of customer funds in trust accounts at commercial banks. Regulators must ensure these funds are protected, liquid and available for customer redemption. Dr Atuahene warns that mismanagement of liquidity between pooled trust accounts and agent networks could, in a stress scenario, prevent customers from accessing funds and trigger a loss of confidence.
The interconnectedness between mobile money and banks adds another layer of risk. Banks hold float accounts, support agent liquidity and increasingly partner with mobile money operators on integrated products. Stress in one side of the ecosystem can therefore transmit to the other.
This does not mean Ghana should weaken mobile money. It means the country must protect it from its own success.
The Bank of Ghana has already signalled that digital payments require closer oversight. Its 2024 Payment Systems Oversight Annual Report said Ghana’s payment landscape remained buoyant and robust as adoption increased, but noted that the Bank focused on effective oversight of players in the space to keep digital payment risks at a minimum.
That approach must now deepen. Ghana needs stronger cross-sector intelligence sharing between the Bank of Ghana, the National Communications Authority, the Cyber Security Authority, law enforcement, telecom operators, banks and fintechs. Fraud networks do not respect regulatory silos; neither should supervision.
The country also needs faster complaint resolution, clearer liability rules for unauthorised transactions, stronger agent supervision, tougher penalties for SIM-related fraud, mandatory incident reporting, real-time fraud intelligence, stronger e-float disclosure and stress testing of dominant payment platforms.
There is also a tax lesson. The paper notes that taxation and pricing disputes remain regulatory challenges because taxes on digital transactions can discourage usage, while unfair transaction fees can burden everyday consumers.
Ghana’s experience with the electronic transfer levy showed how quickly policy can affect digital payment behaviour. A mobile money system built for inclusion cannot be treated only as a revenue base. It is public financial infrastructure, and tax policy must be calibrated carefully to avoid pushing users back to cash.
The larger point in Dr Atuahene’s analysis is that mobile money has moved beyond the innovation phase. It is now infrastructure. And infrastructure requires resilience, not just adoption.
For policymakers, the task is delicate. Ghana must not punish mobile money for succeeding. The country must not regulate away the very inclusion gains that brought millions into the formal financial system. But it must also stop pretending that a platform moving nearly GH¢500.00 billion in a month can be supervised like a small payment experiment.
The regulatory perimeter must move with the risk.
If Ghana gets this right, it can build a digital finance system that is inclusive, competitive, safe and trusted. If it gets it wrong, the next financial stability shock may not begin in a bank branch. It may begin on a mobile phone.
