Bank of Ghana designates GIS, GhIPSS and MMFL as systemically important

The Bank of Ghana designated the Ghana Interbank Settlement (GIS) System as a systemically important payment system (SIPS), and Ghana Interbank Payment and Settlement Systems (GhIPSS) and MobileMoney Fintech LTD (MMFL) as systemically important payment service providers (SIPSPs), in a notice dated 5 November 2026. The notice, signed by Bank secretary Aimee Vyda Quashie, applies the Bank's Regulatory Framework for Systemically Important Payment Systems and Payment Service Providers under the Payment Systems and Services Act, 2019 (Act 987).

The designation places the three operations within the Bank's enhanced supervisory regime for payment infrastructure whose failure could affect the safety, resilience and continuity of Ghana's payment ecosystem.

What the designation changes

The framework establishes the criteria and procedures for identifying, designating and supervising systems and providers considered systemically important. It also creates "enhanced regulatory expectations and supervisory obligations" for designated entities and systems, aimed at mitigating systemic risk and protecting the continuity of critical payment services.

The notice distinguishes between the infrastructure and the provider:

- GIS is designated as a SIPS.
- GhIPSS is designated as a SIPSP.
- MMFL is designated as a SIPSP.

That distinction matters for control ownership. GIS is the payment system designation, while GhIPSS and MMFL are provider designations. The notice directs the industry to read the designation with the framework.

The Bank will review the designations at least once every two years. It will consider each entity's or system's continuing systemic importance, risk profile, market developments and compliance with applicable regulatory requirements.

For the designated firms, compliance teams should now establish which framework obligations apply to the relevant legal entity, system and critical services, and preserve evidence of how those obligations are being met. In Atlas's view, the designation also makes resilience dependencies a matter for firms connected to GIS, GhIPSS or MMFL: banks, payment service providers and other critical service providers should map reliance on them in business-continuity, outsourcing and incident-escalation assessments. That is a supervisory implication of the designation, not a new duty expressly imposed on every connected firm by the notice.

Part of a wider safeguarding focus

On 6 November, it issued Notice No. 43, requiring payment service providers to keep merchant collection funds in designated settlement accounts, segregated from operational accounts. Settlement banks must prevent those funds from being used for operational, financing or investment purposes unrelated to merchant settlement.

Notice No. 43 also requires settlement in line with the service-level agreement between the provider and merchant, allows only agreed fees and charges to move to the provider's operational account during settlement, and requires records, controls and audit trails. The Bank said non-compliance may attract regulatory, supervisory and enforcement action.

Taken together, the measures point to closer attention to both the institutions supporting payment continuity and the treatment of funds moving through them. The next stated supervisory event for GIS, GhIPSS and MMFL is the Bank's review of their designations at least once every two years.