Bank of Ghana orders PSPs to segregate merchant funds from operating accounts

The Bank of Ghana issued Notice No. 43 on 6 November 2026, requiring all payment service providers (PSPs) and settlement banks to segregate merchant collection funds from PSP operational and business accounts. The notice is issued under section 101 of the Payment Systems and Services Act, 2019 (Act 987).

For compliance teams, the notice means PSPs must review their settlement account structures, merchant agreements and internal controls immediately. Merchant funds remain the property of the relevant merchant until settlement under the service-level agreement (SLA), and must be held in designated settlement accounts with approved settlement banks.

What Notice 43 requires

PSPs must ensure that collected funds are credited to designated settlement accounts and are not commingled with operational funds. They must settle the money into each merchant's designated bank account strictly within the period agreed in the applicable SLA.

A PSP may not withdraw, transfer, pledge, place a lien on, set off against or otherwise encumber merchant funds. The only exceptions are transfers needed to settle the merchant and the transfer of the PSP's duly earned fees and charges.

The notice permits the portion representing agreed fees, commissions or charges to move from the settlement account to the PSP's operational account only as part of the settlement process and in accordance with the commercial arrangements agreed with the merchant. It does not permit a PSP to use the wider balance for working capital, financing, investment or other business purposes.

Settlement banks must ensure that accounts holding merchant funds are operated solely for settlement. They must not allow a PSP to access or use those funds for operational, financing, investment or other purposes unrelated to merchant settlement.

Both PSPs and settlement banks must maintain adequate records, controls and audit trails demonstrating the safeguarding, segregation and timely settlement of merchant funds. The Bank of Ghana may also require settlement banks to submit statements for settlement accounts at intervals and in a manner it determines.

Immediate compliance required

The Bank of Ghana says non-compliance will constitute a breach of the applicable regulatory framework and may attract regulatory, supervisory and enforcement action. Notice 43 does not set a separate remediation deadline or specify a penalty.

It instead directs all PSPs and settlement banks to take “immediate steps” to achieve full compliance and to review their operational arrangements, agreements and internal controls.