Advocates for Christ Ghana – Economy, Business and Finance Gate (A4CG) has called on the Bank of Ghana (BoG) to withdraw and re-issue its Exposure Draft on the Guideline for the Regulation and Supervision of Non-Interest Banking, citing internal contradictions, legal vulnerabilities and prudential risks.
In a formal submission dated Tuesday, December 23, 2025, and addressed to the Governor of the Bank of Ghana, A4CG said that following a “comprehensive clause-by-clause review”, the draft guideline in its current form “is not fit for implementation”.
“We acknowledge the Bank of Ghana’s stated objectives of promoting financial innovation, inclusion, and regulatory clarity.
“However, following a comprehensive clause-by-clause review, and informed by both technical regulatory analysis and independent public-interest policy commentary, we conclude that the Draft, in its current form, is not fit for implementation,” the group said.
The submission stressed that its objections are not rooted in ideology or opposition to faith-based financial practices.
“This submission is not an ideological objection to any faith-based financial practice. Rather, it is grounded strictly in constitutional order, regulatory coherence, prudential soundness, consumer protection, and public interest considerations,” A4CG noted.
According to the group, the draft guideline suffers from “material internal contradictions, technical gaps, and prudential risks” that create legal uncertainty and compliance challenges. A4CG argued that the Bank of Ghana “lacks its own tried and tested Non-Interest Banking and Finance model it intends to introduce in Ghana hence the inherent contradictions in the draft exposure”.
Among its key concerns, A4CG pointed to what it described as regulatory incoherence within the draft, including “conflicting hierarchies of applicable standards”, “inconsistent dispute-resolution pathways”, and an “unclear allocation of supervisory authority between BoG and internal committees”.
The group also raised alarm over the creation of internal governance and adjudicatory bodies — the Non-Interest Banking Advisory Committee (NIBAC) and the Non-Interest Finance Advisory Committee (NIFAC) — which it said could undermine existing consumer protection frameworks.
“The Draft establishes internal bodies (NIBAC and NIFAC) with adjudicatory-type functions that displace standard consumer redress mechanisms applicable to other banks,” the submission stated, warning that this could result in “unequal treatment of bank customers and weakens established regulatory safeguards”.
A4CG further cautioned that the proposed “window” model, which allows conventional banks to operate non-interest banking units, is “operationally complex, cost-opaque, and highly vulnerable to manipulation” due to insufficient accounting, audit and supervisory detail.
On market justification, the group said the draft fails to adequately demonstrate demand or systemic benefit. It noted that “serious questions” remain about “whether there is sufficient unmet demand in Ghana to justify the regulatory and supervisory overheads of a specialised non-interest banking regime”.
In its conclusion, A4CG formally requested that the Exposure Draft be withdrawn and substantially revised.
“The Exposure Draft, as currently constituted, is internally inconsistent, operationally fragile, and legally vulnerable,” it said, adding that “it should therefore be withdrawn and re-issued following comprehensive technical revision”.
The group emphasised that any future framework must “preserve constitutional neutrality, ensure equal consumer protection, maintain BoG’s supervisory primacy, avoid parallel adjudicatory systems, and address prudential and accounting realities before permitting window operations”.
