IMF Flags Gaps in Ghana’s Crypto Framework Ahead of December 2026 Licensing Go-Live
The IMF warned the Bank of Ghana and SEC Ghana to address key regulatory gaps in stablecoins, custody, and market abuse before December 2026.
Table Of Content
- The Central Bank of Ghana asked the IMF to conduct a technical assistance mission regarding its digital asset regulatory framework.
- In its report, the IMF identified several structural gaps in market abuse protections, stablecoin redemption rights, and offsite reporting, and proposed solutions for Ghanaian regulators to implement.
- The IMF also noted that Ghana’s cryptocurrency volume was driven mostly by stablecoin use, for trading, cross-border commerce, and inflation hedging.
- The Bank of Ghana and SEC Ghana have till December 2026 to implement the IMF’s proposed regulations.
The International Monetary Fund (IMF) released a technical assistance report on September 25. In the report, the IMF informed the Bank of Ghana (BoG) and Ghana’s Securities and Exchange Commission (SEC Ghana) that its current guidelines and regulations “fall short of comprehensive oversight.”
The IMF noted that while current regulation was “directionally aligned with global standards,” Ghana’s central bank and the SEC must close key gaps before the digital asset licensing regime goes live later in December 2026.
Ghana’s Current Crypto Framework
In December 2025, Ghana passed the Virtual Asset Service Providers (VASP) Act (Act 1154). The Act gives the Bank of Ghana and SEC Ghana regulatory and supervisory authority over virtual assets.
In line with the VASP Act, the Bank of Ghana regulates and supervises:
- stablecoin issuance,
- payment processing,
- Custodial and noncustodial wallet services
- Crypto lending and borrowing
- Bitcoin ATMs.
The Securities and Exchange Commission Ghana regulates and supervises:
- Crypto Trading Platforms
- Brokers and Advisory
- Asset Tokenisation and ICOs
- Fund Management and ETFs
The current framework also requires stablecoin issuers (cedi-backed or backed by foreign currency) to obtain a licence to continue marketing to the Ghanaian market. Stablecoin issuers may keep reserves abroad, provided they are held in banks in “non-high-risk” jurisdictions.
The Bank of Ghana and the SEC each have their own sandbox. On August 19, 2026, SEC Ghana added 9 new firms to its crypto sandbox, growing the number from 11 to 20 participants. The sandbox, which initially launched in March 2026, is expected to run for a 12-month pilot period.
Later that month, on August 25, the BoG inaugurated a five-agency Virtual Assets Coordinating Committee (VACC). The committee includes representatives from the BoG, SEC Ghana, the Ministry of Finance, the Financial Intelligence Centre (FIC), and the Cyber Security Authority (CSA).
The BoG governor described the committee as necessary for coordinating regulatory and supervisory activity.
Less than a week later, UMB Bank gained approval from both the SEC and the Bank of Ghana to provide virtual accounts to eligible VASPs.
The Gaps the IMF Flagged and its Recommendations
Despite all this and the IMF’s acknowledgement that “legislation is in place” and that Ghanaian “authorities are ready to regulate,” the IMF still found gaps in the current framework. The IMF outlined those gaps and its recommendations, urging the BoG and SEC Ghana to implement them before December 2026. They include, but aren’t limited to:
- Broad Regulatory Scope: The IMF noted that there were no tailored, activity-specific guidelines for trading platforms, brokers and lending services in Ghana’s VASP Act. It also noted that the Act extends unnecessary financial oversight to network mining, validation and self-hosted wallets.
To combat this, the IMF urged the SEC and the BoG to provide regulations that allow for “comprehensive regulation and supervision of the crypto market’s activities.”
- Market Conduct, Abuse, Custody and Trading: The existing market abuse provisions apply almost exclusively to proprietary trading. The IMF called for expanding these rules to cover order books, front-running, wash trading, spoofing, and other order misuse by brokers.
The IMF also noted that the current rules do not explicitly prohibit asset rehypothecation. It called for clear rules prohibiting the rehypothecation of clients’ assets without consent. The IMF asked the SEC to develop dedicated trading guidelines covering pre- and post-trade transparency, disclosure, whitepaper requirements, and listing/delisting criteria.
- Stablecoin Arrangements: The current stablecoin framework does not clearly state end-user redemption rights or minimum rules for liquid reserves. The IMF also noted that the current framework does not clearly distinguish between cedi-backed stablecoins and foreign stablecoins.
The IMF asked regulators to prioritise binding rules for par-value redemption rights. It also asked regulators to enforce liquid reserve allocations and establish clear currency-matching requirements.
- Reporting, Disclosures and Data Collection: The IMF warned that supervisory offsite reporting requirements are sparse, static, and non-standardised. It relies on annual financial statements rather than dynamic market data.
It asked regulators to consider implementing standardised, activity-specific, periodic reporting templates that cover risk metrics, volume, and reserve details.
Why This Matters
The IMF report estimates that somewhere between 8% and 17% of Ghana’s population participate in the crypto market. With an estimated $21 billion in annual virtual asset transactions, Ghana is the fifth-largest cryptocurrency market in sub-Saharan Africa.
The scale of the market means that Ghana’s regulators need to be careful and thorough as they draft regulations.
The IMF also noted that most of Ghana’s crypto transaction volume is dominated by USDT stablecoin. It also highlighted that current volumes show Ghanaians use USDT for crypto trading and to protect their funds against inflation. Unlike remittance-dependent economies, Ghana showed balanced gross inflows and outflows, driven by increased stablecoin use in B2B cross-border commerce.
With just two months before December, the Bank of Ghana and SEC Ghana face a narrow window to review and refine their regulations.
However, considering that the IMF conducted the technical assessment mission at the request of the Ghanaian central bank, the regulators seem intent on providing clear digital asset governance and regulations for its market.
