Notice No. 36 – Unlicensed Digital Credit Services Providers

The Bank of Ghana has issued a further public warning against 20 digital credit apps it says are operating without authorisation, reinforcing its September 2025 Directive and earlier Notice No. 22. For compliance teams at licensed banks, fintechs, payment firms and consumer credit providers, the notice is a clear signal that the regulator is actively monitoring the digital lending perimeter and will publicly name non-compliant operators. The primary risk is regulatory contagion: any association—funding, referral, white-label partnership, payment processing or data sharing—with a listed app could attract supervisory scrutiny, reputational damage and potential enforcement.

The BoG cites significant breaches of customer data privacy and consumer protection, so third-party due diligence, outsourcing oversight and data governance should be revisited immediately. Actionable steps: (1) screen the 20 named apps against your partner, vendor and merchant lists; (2) confirm that all lending-related activities and embedded finance arrangements are within licensed permissions; (3) enhance monitoring for unlicensed activity and report suspicious entities to BoG; (4) review customer complaint and data breach escalation routes; (5) consider customer communications to steer borrowers toward licensed alternatives. The notice also creates a competitive opening for compliant lenders to win trust and market share as the unlicensed segment is sanitised.

Firms should document their exposure assessment and be ready to demonstrate to supervisors that no unlicensed digital credit service is being facilitated through their channels. RegCanary will continue to track BoG digital credit enforcement and licensing updates.