Fintech Governance: Regulatory Space, Coordination Failure, and Polycentric Supervision in Ghana

Abstract

Ghana’s fintech regulatory system is shared among several institutions. The Bank of Ghana (BoG), the Financial Intelligence Center (FIC), the Cyber Security Authority (CSA), the Data Protection Commission (DPC), and the Securities and Exchange Commission (SEC) each regulate different but overlapping aspects of the fintech ecosystem. This study examines how this distributed regulatory system operates in practice, focusing on its coordination mechanisms, governance gaps, and the challenges they create. A qualitative, exploratory design grounded in an interpretivist approach was used. Twelve semi-structured interviews were conducted with participants from three regulatory institutions (BoG, FIC, and CSA), as well as fintech founders, legal advisors, mobile money operators, compliance professionals, cybersecurity managers, and ecosystem experts. Data were analyzed using Braun and Clarke’s six-phase thematic analysis. Four main themes emerged: the fintech regulatory landscape and its key institutions; coordination in practice and its limitations; three governance challenges—coordination gaps, perimeter ambiguity, and regulatory arbitrage risk arising from institutional fragmentation; and the regulatory perimeter problem in digital lending. Using regulatory space theory and polycentric governance theory, the findings show that Ghana's fintech governance combines the strengths of specialized institutions with significant coordination weaknesses. While institutional specialization supports effective regulation, limited coordination creates governance gaps that affect consumer protection, innovation, and financial inclusion. The study recommends establishing a formal cross-institutional coordination mechanism, similar to information-sharing arrangements used in more mature financial regulatory systems.