A policy group has called on the Bank of Ghana (BoG) to withdraw its draft guidelines on non-interest banking, warning that the proposed framework is “not fit for implementation” due to legal, regulatory and prudential weaknesses.
In a formal submission to the central bank, Advocates for Christ Ghana – Economy, Business and Finance Gate (A4CG) said the draft guidelines contain internal contradictions and structural flaws that could undermine regulatory credibility, consumer protection, and market confidence if implemented.
“The exposure draft, in its current form, is not fit for implementation,” the group stated, adding that proceeding with the guidelines “poses material risks to the integrity of the regulatory framework and the stability of the financial system.”
The submission, dated December 23, 2025, was made in response to the Bank of Ghana’s call for public comments on the draft regulatory and supervisory framework for non-interest banking.
According to A4CG, the guidelines raise serious legal concerns, particularly around constitutional neutrality and equal treatment under the law, while also presenting supervisory and prudential challenges that could complicate enforcement.
“The draft guidelines suffer from internal inconsistencies and legal vulnerabilities that expose the Bank of Ghana to regulatory and constitutional risk,” the group said.
A4CG stressed that its position was not rooted in opposition to faith-based or alternative banking models, but in concerns over governance, consumer safeguards, and policy coherence.
“We are not opposed to innovation in financial services,” the group noted, “but such innovation must be grounded in clear legal authority, prudential soundness, and strong consumer protection.”
The group urged the central bank to withdraw the draft and re-issue a revised framework after a comprehensive technical review and broader stakeholder engagement.
“The safest and most responsible course of action is to withdraw the draft guidelines and re-issue them only after the identified defects have been fully addressed,” the submission said.
The Bank of Ghana has not yet publicly responded to the concerns raised.
