Ghana is naming unlicensed lenders. What it means if your business offers credit.

On 6 October 2026 the Bank of Ghana published Notice No. BG/GOV/SEC/2026/36, naming twenty mobile loan applications operating without a licence. It advises the public not to engage with them, and cautions banks, specialised deposit-taking institutions and payment service providers against facilitating or processing transactions on their behalf.

Read as a consumer story, this is a crackdown on loan apps. Read as a business story, it is more useful: the state has priced an activity, and has chosen the payment rail to police it. The question for most Ghanaian businesses that let customers pay later is narrower: does this reach us? The answer sits in four definitions, and for most it is no — but “no” is not the same as “unregulated”.

What is happening?

Ghana now licenses digital lending. The Directive for Digital Credit Services Providers in Ghana was issued in September 2025 under the Non-bank Financial Institutions Act, 2008 (Act 774), and took effect on 1 November 2025. Notice 2025/35 of 31 October 2025 opened applications from 3 November 2025 and required existing providers to regularise by 30 June 2026. Notice 2026/22 of 20 July 2026 confirmed the deadline had elapsed, warned of regulatory action, and said a list of licensed providers would follow in due course. Notice 2026/36 came on 6 October 2026 with the twenty names.

The price of being inside the perimeter is published: minimum capital of GH¢2,000,000, a gearing ratio of 8, a transaction limit of GH¢10,000, GH¢10,000 to process an application and GH¢20,000 for the licence, renewable every two years. Section 2.4 makes carrying out digital credit services without a licence an offence liable to prosecution.

One thing is not established. As at 29 October 2026 we could not find a published register of licensed providers on the Bank’s website; the FinTech & Innovation “Approved Institutions” page lists payment service providers, a different licence. A business cannot yet check a prospective credit partner against an official Ghanaian list.

Why it matters economically

The notable thing about Notice 2026/36 is the lever. A fine is a cost, and a business with a working model absorbs costs; an instruction to banks and payment service providers is a threat to distribution. A digital lender’s whole operation is disbursement and collection, and both run on accounts and rails held by regulated third parties. Close those and there is no model to fine.

For a business weighing a credit offer, the published numbers turn a strategic debate into arithmetic. GH¢2,000,000 of minimum capital is not an expense; it is capital withdrawn from the operating business and held. A gearing ratio of 8 caps the debt that capital can carry, which in turn bounds the loan book, and a GH¢10,000 transaction limit caps the ticket. Our reading is that the licence fixes not just the right to lend but the size of the business built on it.

Our view is that this reframes the decision. Against the margin a pay-later option adds sit locked capital, a funding cost, a default rate, a collections operation — and a cost businesses rarely budget: the record itself. Daily submissions to credit reference bureaus, a twenty-day complaints clock and an electronic receipt for every transaction are operations, not build items, and they recur.

What it means for African businesses

The perimeter is narrower than the coverage suggests, and it turns on the word exclusively. Four definitions in the Directive decide it.

• Scope. The Directive applies to a corporate entity which intends to operate exclusively as a digital credit services provider, and to one already licensed.
• Digital credit services. A non-bank financial service which offers, provides and processes credit exclusively through digital channels.
• Digital credit. Credit products that are short-term — under 12 months — of low value, and delivered through digital channels.
• Customer. An individual or natural person. The Directive states expressly that this does not include a company or a partnership.

Applied honestly, that puts most businesses outside. A distributor giving a retailer thirty days through an ordering app lends to a company, not a “customer”; a shop that sells goods and also offers instalments is not operating exclusively as a digital credit provider. Squarely inside is the business whose product is a short-term consumer loan delivered through an app.

Outside the Directive does not mean unregulated. It requires a licensee’s credit policy to be in line with the Borrowers and Lenders Act, 2020 (Act 1052), which governs lenders and borrowers generally; under the provisions the Bank set out on 11 May 2022, a lender must give written notice of default and thirty days to pay. We have not read Act 1052’s own definition of “lender” and make no claim about where its boundary falls — that belongs with Ghanaian counsel, not with an inference from the Directive.

The stage of Ghana’s regime matters too. Kenya has run a comparable framework since March 2022: on 30 September 2026 the Central Bank of Kenya licensed 29 more providers, taking the total to 281, with 9,596,509 loans worth KSh 165.1 billion granted as of August 2026. Ghana is nearly four years behind that curve, publishing the unlicensed rather than the licensed, and the regimes differ in instrument, threshold and supervisor. What travels across the markets we work in is the direction only: consumer lending through a digital channel is becoming a licensed activity, and the licence is priced.

Technology and AI implications

The Directive is specific about what a lending system must do — obligations for a licensee, and a reasonable specification for anyone extending consumer credit digitally.

• A digital pre-agreement issued before the arrangement is concluded, stating the principal, the disbursement schedule, the basis of any cost assessed on default, fees and any loan insurance. A screen and a stored artefact, not a document emailed afterwards.
• Interest disclosed for the tenure and not compounded — a constraint in the pricing engine — and an electronic receipt for every transaction, by email or text message.
• A complaints mechanism that receives and resolves within twenty days: a logged queue with a clock, not a shared inbox.
• Daily submission of customer credit information to licensed credit reference bureaus, with consent obtained first. Consent may be oral, print or electronic, and the provider must satisfy itself that electronic consent is authentic — so it needs a timestamp, a method and an artefact on the customer record.
• Collections conduct. No unauthorised or unsolicited calls or messages to a customer’s contacts, and no unauthorised publication on social media. The cleanest way to comply is not to request the contact list at all.
• Operational controls: fraud monitoring and detection tooling, third-party certification, and Bank of Ghana access to lending and operational systems.

Where technology and AI do not help is worth stating plainly. No model tells a business whether it sits inside the perimeter; that is a reading of four definitions against its own operations. Credit scoring is the one place AI genuinely earns its keep — assessing a thin-file borrower from transaction history is real work, and where a data advantage becomes a lower default rate. It does nothing for the obligations above, which are disclosure, records and conduct. And automated collections are where the conduct rules bite hardest: a flow that escalates to a borrower’s contacts is prohibited however it was generated.

Practical business implications

The questions, in the order they decide it:

1. Is credit our business, or a feature of selling something else? Exclusivity is the first test, and for most retailers and e-commerce operators it settles it.
2. Who is the borrower, and on what terms? The Directive’s “customer” excludes companies and partnerships, and its “digital credit” is short-term — under twelve months — and low in value.
3. If we want the licence: GH¢2,000,000 of capital, gearing of 8, a GH¢10,000 transaction limit, GH¢30,000 of fees, renewal every two years — and a licensee may not operate any other business the licence does not permit, so in practice this means a separate company.
4. If we do not want the licence: integrate a licensed provider. The licensee needs the Bank’s prior written approval for the partnership and stays responsible for the outsourced function — your integration is their regulatory exposure, so expect them to require the controls above before signing.
5. How do we verify a partner today? Ask for the licence reference number, which the Directive requires a provider to disclose on its website and all channels. With no official register published, that number and an enquiry to the Bank’s Fintech and Innovation Department are the available checks.
6. What does our payment provider think we are? One that concludes a merchant is facilitating unlicensed lending can act before any regulator rules on it. Have that conversation before launch, not after a settlement is withheld.

RevenueStack perspective

Three observations, offered as analysis.

Economically, the regulator has done businesses a favour by publishing the price. Most arguments about offering credit founder on unquantified upside; this one has a denominator. Set the capital a licence locks up against the margin a pay-later option adds to sales, and for most non-financial businesses in Ghana the arithmetic points to integrating a licensee rather than becoming one.

Technically, the lesson generalises past Ghana. Every obligation in the Directive is a record with a timestamp and a counterparty: who was told what before they borrowed, who consented to a bureau submission and how, when a complaint opened and closed, which message went to whom. Businesses build the credit decision first and the record second, because the decision is the interesting part — and the decision is the part no supervisor will ever ask about. The same asymmetry runs underneath South Africa’s opt-out registry: these records belong beside the sale in the customer record, a question of how the business system is built.

Operationally, the licence is a one-off and the obligations are daily. A bureau file and a twenty-day clock are a running cost, and they are what fails in year two, once the person who built the launch has moved on. A credit feature is an application with a supervisor among its users.

Conclusion

Ghana has made short-term digital consumer lending a licensed activity, priced the licence, and begun naming the firms operating without one — while telling the banks and payment providers they depend on to think twice about processing for them. For the few businesses whose product is the loan, that is an existential compliance question. For the many that simply want customers to be able to pay later, the Directive is better read as a specification of what a system extending consumer credit must disclose, record and refrain from doing. Most will conclude the credit belongs on someone else’s licence. The records belong on theirs.

Sources

1. Directive for Digital Credit Services Providers in Ghana — Bank of Ghana, 2025-09
2. Licencing Requirements for Digital Credit Services Providers — Bank of Ghana, 2025-09
3. Notice No. BG/GOV/SEC/2025/35 — Deadline for Existing Mobile Loan Applications and Digital Credit Services Providers — Bank of Ghana, 2025-10-31
4. Notice No. BG/GOV/SEC/2026/22 — Unlicensed Digital Credit Services Providers — Bank of Ghana, 2026-07-20
5. Notice No. BG/GOV/SEC/2026/36 — Unlicensed Digital Credit Services Providers — Bank of Ghana, 2026-10-06
6. Notice No. BG/GOV/SEC/2022/05 — Lenders' Right to Enforcement under the Borrowers and Lenders Act, 2020 (Act 1052) — Bank of Ghana, 2022-05-11
7. Press Release — Licensing of Digital Credit Providers — Central Bank of Kenya, 2026-09-30
8. FinTech & Innovation — Approved Institutions — Bank of Ghana