CUTS International Accra, a leading public policy think tank on consumer protection and competition policy advocacy organisation has commended the Bank of Ghana (BoG) for its prompt intervention in suspending the proposed 0.75% wallet-to-bank transfer fee announced by Mobile Money Fintech Limited (MMFL), the operator of MTN Mobile Money (MoMo).

The fee, which was scheduled to take effect on 1 June 2026, has been placed on hold pending further consultation.

Speaking on the development, Appiah Kusi Adomako, West Africa Regional Director of CUTS International, Accra, stated: “We applaud the Bank of Ghana for acting swiftly to protect consumers. This is exactly the kind of proactive regulatory oversight that builds public trust in our financial system. The regulator has sent a clear signal that changes to charges in the mobile money ecosystem must be introduced fairly, transparently, and in a manner consistent with the law.”

CUTS made it clear that it does not, in principle, oppose the intention of MMFL to review and adjust its fees. "Businesses operating in a competitive marketplace have a legitimate interest in pricing their services in a manner that ensures sustainability. However, such adjustments must be made in strict consistency with the applicable regulatory framework and in a manner that is fair to consumers".

Dominance, Market Power, and the Duty of Care

CUT said MMFL commands approximately 75% of the mobile money market in Ghana, making it an unambiguous dominant player in the industry.

It added that competition law around the world does not prohibit dominance itself, but rather the abuse of a dominant position is prohibited.

As a dominant player, it alluded that MMFL possesses significant market power, that is, the ability to raise prices above competitive levels and sustain them without facing the risk of customer attrition or meaningful loss of market share.

“Giving consumers barely one week’s notice about such a significant new charge is, in our view, a textbook example of the kind of conduct that constitutes an abuse of dominance. It is not just a matter of inconvenience; it is a fundamental breach of the principle of fair notice. Consumers deserve adequate time to understand a change, assess its implications, and make an informed choice about whether to continue with a provider or switch to an alternative,”, said Mr. Adomako

The Doctrine of Fair Notice

CUT also argued that a notice period of just seven days is wholly inadequate for a change of this nature and magnitude. "The doctrine of fair notice is a cornerstone of consumer protection and a basic tenet of ethical commercial conduct. By providing sufficient and reasonable notice, service providers enable consumers dissatisfied with new terms to exercise their right to switch to competing providers, such as Telecel Cash or AT Cash. The truncated notice period offered by MMFL effectively denied consumers this fundamental right", it added.

Protecting Mobile Money’s Role in Financial Inclusion

It continued that mobile money is a critical pillar of Ghana’s financial inclusion agenda.

Therefore, the ability to transfer funds seamlessly between a mobile wallet and a bank account has transformed how millions of Ghanaians manage their finances. "It has reduced congestion at banking halls, lowered transaction costs, extended financial services to the unbanked, and empowered ordinary citizens to participate more fully in the formal economy", it stated.

“Mobile money has come to stay. It is central to our financial inclusion story and the daily lives of millions of Ghanaians. Any changes to its fee structure must therefore be handled with the utmost care, transparency, and respect for the consumer. We call on MMFL to engage meaningfully with regulators, consumer advocates, and the public during the consultation period to arrive at a fair and sustainable outcome.” The statement concluded.