Bank of Ghana Issues Implementation Framework for the Financial Inclusion for Persons with Disabilities Directive
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Bank of Ghana Issues Implementation Framework for the Financial Inclusion for Persons with Disabilities Directive
In January 2025, the Bank of Ghana (BoG) issued the Financial Inclusion for Persons with Disabilities Directive (the FIPD Directive), marking a significant step towards inclusive financial services in Ghana. As discussed in our earlier briefing on the FIPD Directive, regulated financial institutions (RFIs) must ensure that persons with disabilities (PWDs) have reasonable and fair access to financial services and products. While the FIPD Directive established broad obligations concerning accessibility, non-discrimination, data collection, staff training and reporting, it did not prescribe a compliance timeline. On 20 April 2026, the BoG issued Notice No. BG/GOV/SEC/2026/10, setting out the implementation framework for the FIPD Directive (the FIPD Implementation Framework), which provides RFIs with specific timelines and guidance for achieving full compliance.
This briefing examines the key requirements and implications of the FIPD Implementation Framework.
Key components and compliance timelines
The FIPD Implementation Framework prescribes 13 specific compliance requirements for RFIs, each with defined timelines. These requirements can be grouped as follows:
- Policy development and governance
RFIs must develop an internal Disability Inclusion Policy setting out how PWDs will be served equitably. By 31 July 2026, each RFI must finalise this policy and appoint a senior manager to oversee implementation of the FIPD Directive.
Board approval for the Disability Inclusion Policy must be obtained by 30 September 2026, with disability inclusion metrics incorporated into annual management reports to the board. The policy must then be submitted to the BoG for review by 31 October 2026.
- Staff and agent training
RFIs must conduct disability inclusion training for all staff and agents. The first programme must be completed by 31 October 2026, with further training conducted annually thereafter. A report on all completed training programmes must be submitted to the BoG.
- Accessibility audits and infrastructure upgrades
By 31 October 2026, RFIs must conduct a comprehensive accessibility audit of all physical and digital channels. This audit must cover ramps, tactile signage, screen readers, websites, mobile applications and USSD services. A report on the audit findings must be submitted to the BoG.
By 31 December 2026, RFIs must ensure that notices regarding support services for PWDs are available in accessible formats (including Braille, large print and audio) on their websites and at all branches. Call centres and support channels must also be upgraded with voice and text feedback systems to enable accessible and responsive communication.
Banks must designate, upgrade and maintain at least one fully accessible branch within each broad branch grouping or operational zone by 31 December 2026. The designated branch must comply with the Ghana Standards Authority’s Building and Construction – Accessibility Standard for the Built Environment and all applicable BoG regulatory requirements.
- Consumer awareness and financial literacy
The FIPD Implementation Framework introduces a phased approach to consumer awareness and financial literacy programmes for PWDs. An initial consumer awareness session for customers must be conducted by 30 June 2026, followed by a second session by 31 October 2026.
Thereafter, financial literacy education tailored to PWDs must be conducted at least twice annually.
- Inclusive product design
By 31 December 2026, RFIs must adapt existing products, services and delivery channels, and design new ones, to ensure accessibility for PWDs. This includes providing critical customer documentation (such as account opening forms and product terms and conditions) in accessible formats.
RFIs must prominently display accessible information about support services for PWDs in all branches. They must also develop internal procedures to govern inclusive product design and accessibility.
- Data collection
The FIPD Implementation Framework requires RFIs to collect PWD identifiers at onboarding (subject to consent) and to use this data for tailored product offerings and accessible financial education. This is an ongoing obligation.
- Annual disclosure and reporting
By 31 December 2026, banks must prepare an annual report using the prescribed template and submit it to both the board and the BoG. The report must include details on (i) disability-inclusive measures implemented, (ii) associated costs incurred, (iii) user feedback and service uptake, and (iv) any gaps identified in implementation.
Conclusion
The BoG has indicated that it will monitor compliance and conduct periodic audits. All RFIs should therefore carry out an internal assessment and take immediate steps to ensure full compliance with the FIPD Implementation Framework by 31 December 2026.
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