April 8, 2025
In January 2025, the Bank of Ghana (BoG) issued the Financial Inclusion for Persons with Disabilities Directive (the FIPD Directive) to ensure that persons with disabilities (PWDs) have reasonable and fair access to financial services and products provided by regulated financial institutions including banks, specialised deposit-taking institutions and payment service providers (RFIs).
The FIPD Directive seeks to implement the principles of the UN Convention on the Rights of Persons with Disabilities.
Key requirements for RFIs
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Policy and procedures
An RFI must create and implement internal policies and procedures to ensure PWDs have reasonable access to and equitable use of banking facilities, products, and services. These policies must be reviewed at least every 2 years and the RFI must appoint an officer at a senior management level to oversee the implementation of the policies.
The annual compliance report to be submitted to the RFI’s board of directors must include an annual disability inclusion report. The RFI must also submit an annual report on activities undertaken in respect of disability inclusion to the BoG by 31 January of each year.
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Accessibility
All facilities and digital service channels of an RFI (including websites, branches, agent locations) must be disability-friendly. An RFI must offer tailored products and services to ensure that in-person and digital facilities and services are accessible, available, and convenient to PWDs. Accessibility and user-friendly features must be added to digital service platforms and online banking services. An RFI must also undertake financial literacy initiatives tailored for PWDs at least twice a year.
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Non-discrimination
An RFI must ensure its facilities, products, and services promote full and effective participation and inclusive banking for PWDs. Its ethical code must also incorporate specific provisions against discriminatory behaviour towards PWDs.
An RFI cannot refuse its products or services to a PWD based on their disability.
An RFI is also required to provide priority service to PWDs and display accessible notices informing customers of this.
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Data collection and usage
An RFI must collect specific data of customers during client on-boarding to identify PWDs in order to facilitate their access to tailored products and services. At the on-boarding stage, the RFI must obtain prior approval of the customer and explain the purpose for collecting the data.
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Training and awareness
An RFI must conduct disability inclusion training for staff and agents at least annually. This should include an assessment of staff to create sensitivity and promote awareness of the needs of PWDs. Annual training and capacity building should be provided for frontline staff members, designated technical staff, and the management person responsible for implementing the RFI’s financial inclusion policy.
An RFI must also provide, at least once a year, its PWD customers with information on available products and services and channels to file complaints.
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Feedback & monitoring
An RFI is required to provide mediums (including voice notes and text messaging) for PWDs to give feedback on access to, and convenience of, the tailored products and services offered. The RFI must assess the feedback and use it to improve access, product development, and service delivery.
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Disclosure and reporting
An RFI must publish information on its website about its disability inclusion policies, any fintech innovation designed to promote financial inclusion for PWDs, and available channels for customers to file complaints.
Remedial measures and sanctions
An RFI which fails to institute the required policies, procedures and facilities is liable to pay an administrative penalty of not less than GHS 24,000.
In addition, the BoG is empowered to take any remedial action it considers appropriate, including publishing the names of RFIs that have not complied with the FIPD Directive.
Conclusion
The FIPD Directive reinforces existing legal obligations under the Persons with Disability Act, 2006 (Act 715), which mandates (under sections 6 and 7) that public places and services should be made accessible to PWDs. It also complements section 53 of the Borrowers and Lenders Act, 2020 (Act 1052) which prohibits a lender from discriminating against PWDS and requires a lender to implement necessary measures to make credit services available and accessible to PWDs.
By complementing these existing laws, the FIPD Directive demonstrates a commitment to fostering an inclusive financial environment for all, and is an important step towards promoting financial inclusion and providing access to financial services by PWDs. It is therefore necessary for RFIs to develop and implement policies and procedures in respect of the requirements. RFIs should also be mindful of the relevant fines and other sanctions for non-compliance.
