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Dispute resolution under Ghana’s Payment Systems Act

Fintech and electronic payment systems have swept through the Ghanaian financial sector, bringing efficiency and access to consumers, as well as opportunity to service providers.

In the sector’s fledgling years, it was regulated by the Bank of Ghana (“BOG”) but not backed by a sector-specific statute.

Ghana’s Payment Systems Act came into effect in 2019. In the very next year, the Ghana Interbank Payment and Settlement System reported a total of 77-million transactions process through its platforms (a 103% increase over 2019), with transactions totalling a value of GHS254-billion (about USD40.5-billion at the time of writing).

However, the increase in the use of payment systems is certain to bring more disputes in the sector, mostly around:

  1. BOG’s refusal to grant licences to aspiring payment service providers (“PSPs”);
  2. BOG’s refusal to authorise financial institutions to participate in Fintech;
  3. BOG’s revocation of licences or authorisations; and
  4. disputes between PSPs and their customers.

The 2019 Payment Systems Act provides mechanisms for resolving disputes between PSPs and BOG and disputes between PSPs and consumers. Below, we look at the dispute resolution steps the statute provides for.

Disputes between the Regulator and PSPs/financial institutions

Disputes stemming from BOG’s refusal to license a PSP or to authorise a financial institution go to BOG through a petition. The timeframe for bringing the petition is 30 days from the date of refusal. BOG is required to assess the petition and decide on it within 30 days of receipt.

If the complainant is unhappy with BOG’s decision on the petition, they may appeal to the Chief Justice within 30 days of the decision on the petition. The Chief Justice will constitute an ad-hoc adjudicative panel to review the BOG’s decision. The panel will comprise a judge, an experienced expert in payment systems and an experienced chartered accountant. The complainant and the respondent will bear the costs of the proceedings equally.

Disputes between PSP and consumer

Disputes stemming directly from the PSP-consumer relationship go through an internal dispute resolution procedure, which every PSP is mandated by law to set up. The elements of the procedure include:

  1. clear information on the grievance process;
  2. accessibility to the process (including on holidays and outside business hours);
  3. flexible mode of complaint (oral, written, in-person; email; post, etc.);
  4. speedy resolution; and
  5. zero cost to the complainant.

If the complainant is unhappy with the outcome of the process, they may lodge an appeal with the BOG. On receiving the appeal, the BOG has 20 days to resolve the complaint.


In regulating the payment systems space, the legislature has opted follow the modern trend where internal inquiry or grievance procedures are adopted before they resort to the courts. Time will tell whether this is a more effective method than direct resort to the courts.

David A. Asiedu