Ghana’s Financial Institutions & Capital Markets Outlook 2025

12/3/2025
Bentsi-Enchill, Letsa & Ankomah

​The recent change in government (on the back of the ongoing ECF Arrangement and other global issues such as new US policies in the Trump era) introduces fresh dynamics into Ghana’s economic trajectory. It may have significant implications for fiscal policy, investor confidence, and regulatory reform especially in the financial services sector and the capital markets. Our sector specific outlook for 2025 is as follows:

Macroeconomy

We expect macroeconomic stability and debt sustainability to be the key goals for 2025. Towards that, the new government is expected to continue implementing the relevant policies and reforms under the ongoing ECF Arrangement. This will be alongside the fiscal policy objectives of the new government under the NDC Manifesto, which include the reduction of government expenditure, fiscal deficit and public debt to sustainable levels as well as enhanced revenue mobilisation and capital investments to spur economic growth and job creation. Investors and analysts will be waiting to see how the 2025 budget statement addresses these key points.

Securities & Investments​

Capital markets – we anticipate that the proposed Securities Industry Bill to overhaul the legal framework for the securities market will be finalised and passed by the end of 2025. The overhauling is intended to align the legal framework with international best standards and, among others, and address some of the issues affecting the capital markets including inadequate disclosure requirements for issuers and lack of product diversity and innovation. Market participants and stakeholders have reviewed the drafts and are largely aligned on the new concepts. The proposed bill, which aims to build a strong legal structure, is essential to the development of the capital market and so we hope that it is given the required push.

Still on legal and regulatory intervention, our understanding of the NDC Manifesto is that, subject to any tweaks under the 2025 budget statement or any official government policy, the new government intends to restore investor confidence in the capital markets (especially after the DDEP) by undertaking the following:

  • update the capital markets master plan introduced by the SEC in 2021
  • attract more issuers (including state-owned enterprises) to list on the GSE to enhance market liquidity and growth opportunities
  • exempt dividend tax for individuals regarding listed securities
  • revise capital duty to lower the cost of raising capital

Beyond legal and regulatory intervention, we expect increased activity on both the equity and debt markets later in the year as a reflection of increased investor confidence in the markets. We also expect growth on the GSE’s new markets, especially the commercial paper market as prospective issuers get ready to implement their pipeline deals.

Investments – the SEC, in line with its existing capital markets master plan, continues to express its commitment towards diversifying investment products and trading options. We envisage the introduction of rules on asset backed securities, securities lending and borrowing, margin trading, market making, derivatives and digital assets including cryptocurrencies.

The SEC issued guidelines on crowdfunding in 2024. We hope this will lead to positive developments in SME investments through the provision of alternative sources of attractive and long-term financing. We expect the SEC to issue more crowdfunding intermediary licences in 2025 to foster a competitive environment for equity and debt (peer-to-peer) crowdfunding. We also envisage that the Bank of Ghana would clearly delineate its crowdfunding regulatory powers through directives or guidelines for rewards-based or donations-based crowdfunding activities to prevent any overlaps with the SEC.

The NDC Manifesto indicates that the new government intends to strengthen the private equity ecosystem and reform the Ghana Venture Capital Trust Fund. If implemented, these will undoubtedly boost regulated funds business and provide the private sector with much needed capital pipeline.

​Banking and Finance

We are cautiously optimistic for the banking sector based on the ongoing stabilisation of the macroeconomic environment under the ECF Arrangement and potential policy shifts under the new government. We expect to see enhanced stability and improved credit conditions.

The recapitalisation of the banking sector is expected to continue in 2025, with particular focus on enhancing the CAR beyond the regulatory minimum. In line with the ECF Arrangement, the Bank of Ghana is expected to sustain the cash reserve ratio policy, compelling banks to maintain a high level of liquid assets to meet regulatory requirements. As a result, we foresee an increase in cash and bank balances as a share of total assets, with a moderate decline in investment portfolios as banks prioritise liquidity over long-term investments.

Credit extension to the private sector is projected to strengthen as macroeconomic stability boosts consumer and business confidence. We expect banks to increase lending to the private sector, reversing the current risk-averse posture. However, tighter credit underwriting standards are anticipated due to the elevated NPL ratio. Banks are likely to enhance credit risk assessment processes and focus on recovery strategies to reduce loan impairments. Notwithstanding these challenges, we project gross loans and advances to grow at a steady pace, driven by increased demand for credit from SMEs and sectors prioritised in the new government’s policy agenda.

We anticipate a moderate decline in the NPL ratio as banks tighten credit approval processes and prioritise loan recovery efforts. The ECF Arrangement’s emphasis on enhancing financial sector resilience will likely drive regulatory measures to reduce NPLs. We also expect the Bank of Ghana to introduce stricter provisioning requirements for banks, compelling them to write off or restructure bad loans more proactively. This, combined with improved macroeconomic conditions, should ease asset quality pressures.

We expect bank profitability to improve, supported by higher lending volumes, cost containment measures, and greater operational efficiency. The expected growth in pre-tax and after-tax profits will be driven by increased income from lending activities, while cost rationalisation efforts will further improve profit margins. We expect banks to continue leveraging digital transformation and fintech partnerships to optimise operational efficiency. Regulatory adjustments aimed at curbing operational risks and promoting cost efficiency will likely feature prominently in the policy agenda for 2025.

According to the NDC Manifesto, the new government may introduce differentiated minimum capital requirements for the banks and review the universal banking concept. It may also create a regulatory framework for digital banking and non-interest banking. It is not yet clear if these will be implemented within 2025 but we assume that, at least, the review of universal banking concept and the introduction of non-interest banking may not occur within 2025 given the nature of consultation and legislative overhaul required.

There is also an intention to establish a National Women’s Bank to support female entrepreneurs. The details (including whether it will be a universal bank or a microfinance institution and include technical support) are not yet clear but, if planned and implemented well, we expect that it will help close the financing gap in the MSME space.

Payment & Fintech

While we expect the payments sector to continue its strong growth, we look forward to a refinement of the existing legal framework to align with international standards and allow for more flexible regulation to meet the evolving landscape. This will be crucial in fostering a more resilient and adaptive ecosystem that accommodates emerging trends while ensuring consumer protection and financial stability.

According to the NDC Manifesto, the new government plans to introduce a Virtual Assets Service Providers (VASP) Law to establish a clear regulatory framework for virtual asset services, including cryptocurrencies, digital fiat currencies, tokens, and blockchain-based financial instruments. This law will empower the Bank of Ghana and the SEC to oversee virtual asset activities, mitigate risks associated with financial crimes, and promote responsible innovation.

Beyond regulation, the new government intends to leverage blockchain and other emerging technologies to enhance government service delivery, improve transaction efficiency, and foster trust in digital financial systems. If implemented effectively, these reforms could position Ghana as a leader in digital finance and virtual asset regulation within the region.

We anticipate continued expansion in Ghana’s fintech sector, driven by increasing digital adoption, financial inclusion efforts, and deeper integration of financial services with emerging technologies. However, sustaining this growth will require regulatory refinements that balance innovation with consumer protection and systemic stability. As fintech evolves, regulatory agility will be key to fostering competition, reducing costs, and enhancing security in digital financial services.

According to the NDC Manifesto, the new government will introduce new legislation for fintech to foster flexibility, innovation, and competition, making financial services more accessible and affordable. Additionally, the government aims to leverage advanced technology for improved risk management, establish a financial data exchange framework, and promote shared infrastructure for fintechs and financial institutions to drive efficiency, innovation, and seamless digital transformation across the financial services industry.

Artificial Intelligence (AI)

Ghana is (and may, for while, remain) more of a consumer than a developer of AI, with adoption primarily driven by financial services, e-governance, and cybersecurity. AI-powered automation, fraud detection, and digital customer engagement will expand, enhancing efficiency and inclusion. However, concerns around data privacy, bias, and regulatory oversight will require attention. According to the NDC Manifesto, the new government intends to develop a National Digital Policy to regulate the deployment and usage of AI, ensuring structured adoption while addressing ethical and security concerns.

Insurance

According to the NDC Manifesto, the new government intends to roll out a risk-based minimum capital regime to link minimum capital to the risks of an insurer as is within the powers of the National Insurance Commission under the Insurance Act, 2021 (Act 1061). Fixed capital standards typically do not address the differences in size and fundamental risks across insurers. The proposal is in accordance with the existing legislative framework and will bring some flexibility and strengthen insurance regulation.

There is also an intention to introduce localisation requirements for foreign insurance companies. This may be good for both local investors and the foreign insurers if the localisation requirements are crafted and implemented well. It may also some create M&A deals in the insurance market.

Pensions

According to the NDC Manifesto, the new government may review the legislative and regulatory framework for pensions to allow workers to use their tier 2 pension contributions as collateral for mortgage loans. This may apply to only workers who have contributed for a minimum of 15 years. This will be a good boost for the home mortgage financing market.

Tax

We expect that Ghana’s fiscal policy in 2025 will prioritise fiscal consolidation and revenue-enhancing measures, driven by the demands of the ECF Arrangement. As the new Finance Minister has indicated ahead of the presentation of the 2025 budget statement, revenue is critical and the new government must prioritise domestic resource mobilisation.

The new government has signalled its intention to abolish certain taxes that have been the subject of widespread public debate. Key taxes that may be removed include the following:

While these proposed tax cuts may offer economic relief, they may have significant implications for Ghana’s revenue mobilisation strategy under the ECF Arrangement. Increased domestic revenue mobilisation is a key pillar of the country's economic recovery and debt sustainability plan. The taxes proposed to be cut have played a crucial role in supporting the government’s revenue targets. The abolition of these taxes may create a revenue shortfall, forcing the government to explore alternative revenue streams or increase enforcement of existing measures. This tension between political commitments to reduce the tax burden and IMF-backed fiscal consolidation efforts is likely to be a key policy challenge in 2025.

To address this potential revenue gap, the government may rely more heavily on administrative efficiency and compliance enforcement. The GRA is expected to intensify efforts in tax compliance, particularly through digitalisation and automation. The operationalisation of the e-VAT system and the expanded use of the modified taxation scheme for SMEs will continue in 2025. With a larger pool of taxpayers expected to be brought under the e-VAT regime, the GRA will increase its use of data analytics and cross-agency data integration to identify non-compliant taxpayers and enforce payment obligations. The introduction of electronic bookkeeping requirements will further strengthen compliance, promote financial transparency, and close informal sector leakages.

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