The Bank of Ghana issued the Guidelines for the Regulation and Supervision of Non-Interest Banking (the NIB Guidelines), effective 13 January 2026. The NIB Guidelines establish the regulatory framework for non-interest banking (NIB).
This briefing focuses on the implications of the NIB Guidelines for existing and incoming financial institutions seeking to offer NIB products within Ghana’s regulated financial system.
What is NIB?
The NIB Guidelines define NIB as a regulated form of banking that prohibits charging, paying, or receiving interest and avoids contractual uncertainty, gambling or betting, and financing or investing in activities not backed by permissible real economic assets. NIB institutions generate income through trade, leasing, and partnership-based transactions tied to real economic activity.
In practical terms, a NIB institution does not lend money at a rate of interest. Instead, it finances customers by buying and selling assets, leasing assets, or entering into profit and loss sharing arrangements. Returns arise from mark-ups, rentals, or shared profits-not from interest accruing over time.
Although NIB is commonly associated with Islamic finance, the NIB Guidelines indicate that NIB should be available to any person regardless of their religion and that a financial institution providing NIB services should not be associated with any religion.
Licensing and entry models
An entity seeking to provide NIB services in Ghana is required to obtain a licence from the Bank of Ghana. The NIB Guidelines distinguish between incremental roll-out of NIB products by an existing financial institution (NIB-inclusive model) and full market entry or roll-out of NIB products by a new or standalone financial institution (NIB-only model). The documentation and capital requirements differ materially between the 2 models. This reflects the underlying logic that an existing financial institution already sits within the Bank of Ghana's supervisory perimeter and carries an existing capital base, whereas a new entrant must demonstrate from the ground up that it has the financial soundness, governance architecture, and operational capacity to carry on NIB business safely and in accordance with NIB principles.
- NIB-inclusive model - an existing financial institution wishing to offer NIB products through a dedicated window need not raise additional capital as a baseline requirement. It is only required that the relevant institution apply to the Bank of Ghana for approval to operate the NIB-inclusive model. In assessing the application, the Bank of Ghana will evaluate the institution’s capital adequacy, risk profile, governance arrangements, and operational capacity to determine whether it can safely support non-interest activities alongside its conventional business. Additional capital would only be required for the NIB-inclusive model, if the Bank of Ghana concludes, based on its assessment, that extra capital is necessary to mitigate risk or protect depositors. NIB-inclusive model operators are also required to execute service level agreements governing shared services between their conventional and NIB units.
- NIB-only model - applicants for a full-fledged licence must, among other things, submit a detailed feasibility report with a 5-year business plan, demonstrate adequate paid-up capital at the level prescribed by the Bank of Ghana from time to time, and satisfy the fit and proper test in respect of all proposed directors, key management personnel, and significant shareholders. For foreign-owned applicants, at least 60% of the required capital must be remitted to Ghana in convertible currency and invested in NIB-compliant instruments.
Governance & advisory structures
The NIB Guideline introduces a 2-tier advisory governance structure that operates alongside the standard corporate governance framework (including the Bank of Ghana’s Corporate Governance Directive and fit and proper person requirements) applicable to all licensed institutions.
NIBAC (Institution level)
A NIB-inclusive or NIB-only financial institution is required to establish a non-interest banking advisory committee (NIBAC) comprising at least 3 members with balanced expertise across banking, finance, economics, law, and NIBF principles. The NIBAC must include at least one Ghanaian member, one female member, and one independent member. An individual may not concurrently serve as a NIBAC member of more than one NIB licensee. NIBAC members are appointed for renewable 4-year terms, with a maximum of 3 terms, and their remuneration is determined by the board of the NIB licensee. Any resignation or removal of a NIBAC member before the end of their tenure must be notified to the Bank of Ghana.
The NIBAC is responsible for advising the board and management of the NIB licensee on NIBF compliance and the appropriateness of products and operations, acting as the primary internal dispute resolution body, and submitting quarterly dispute resolution status reports to the Bank of Ghana’s Non-Interest Financial Advisory Council (NIFAC). Where an institution discovers non-compliance with NIBF principles, it must immediately notify the NIFAC, cease the non-compliant activity, and submit a rectification plan to the NIFAC within 30 days. Failure to do so attracts penalties.
NIFAC (Bank of Ghana level)
The NIFAC is the Bank of Ghana’s own advisory body on NIB governance. It comprises 5 members and advises the Bank of Ghana on the effective regulation and supervision of NIB licensees, reviews and approves product proposals submitted by an NIB licensee, and serves as an escalation body for disputes not resolved at the NIBAC level. The opinions of NIFAC do not displace the supervisory, enforcement, or regulatory discretion of the Bank of Ghana. Pending the development of sufficient sectoral expertise, the NIFAC will also serve in an advisory capacity to the Securities and Exchange Commission (SEC) and the National Insurance Commission (NIC).
Fund segregation & operational separation
The NIB Guidelines impose strict fund segregation requirements on entities operating the NIB-inclusive model. Such a financial institution is required to establish a non-interest finance fund (NIFF) to ring-fence all non-interest assets, liabilities, income, and expenses. Funds relating to NIB activities may not be commingled with conventional banking funds under any circumstances. The reallocation of funds from NIFF to conventional operations requires the approval of the Bank of Ghana.
While conventional and window operations may share core operating software, the institution must practically separate the recording, processing, and reporting of all NIB transactions to ensure auditability and regulatory compliance. Where shared infrastructure exists, the financial institution remains responsible for ensuring such arrangements do not result in indirect fund commingling or regulatory arbitrage.
Failure to maintain effective segregation exposes the relevant financial institution to supervisory intervention and regulatory sanctions under the applicable financial sector legislation.
Prudential requirements
A financial institution providing NIB services remains bound by standard capital adequacy, risk management, and supervisory standards issued by the Bank of Ghana, including applicable requirements under relevant legislation.
For a NIB-only financial institution, liquidity management must be conducted entirely in accordance with NIB principles. Such an institution may not rely on interest-bearing instruments or conventional interbank facilities and is required to maintain liquidity frameworks, buffers, and contingency arrangements that are fully NIB compliant.
For a NIB-inclusive financial institution, the liquidity requirements apply only in respect of funds held within the NIFF. The NIB Guidelines do not prohibit the financial institution from engaging in interest-based liquidity management for its conventional operations. However, funds attributable to the NIFF may not be invested in interest-bearing instruments or deployed in a manner inconsistent with NIB principles. A relevant financial institution must therefore be able to demonstrate that liquidity management for the NIFF is conducted separately and that NIB funds are not used to support, or exposed to, conventional treasury activities.
Permissible financing modes and contracts
All contracts, products, and services offered by a NIB licensee must be reviewed and approved by the institution’s NIBAC and by the Bank of Ghana’s NIFAC. New products require the prior written approval of the Bank of Ghana. The NIB Guidelines recognise 3 categories of permissible contracts. The first is sale and exchange contracts, which include cost-plus financing (Murabahah), forward sales (Salam), manufacturing and construction financing (Istisna'a), and leasing (Ijarah) — these are the primary financing instruments and the closest functional equivalents to conventional credit facilities.
The second is partnership contracts, namely profit-sharing partnerships (Mudarabah) and joint ventures (Musharakah), under which returns and losses are shared between the institution and the customer according to pre-agreed ratios rather than a fixed interest rate. The third is ancillary contracts — including benevolent loans (Qard al-Hasan), agency arrangements (Wakala), guarantees (Kafala), mortgages (Rahn), undertakings (Wa'ad), and gifts (Hiba) — which function primarily as structural and security instruments supporting the broader product suite rather than as standalone financing tools.
A NIB licensee is prohibited from offering any product that involves interest, excessive uncertainty, gambling, derivative instruments that do not comply with NIB principles, or financing activities that are prohibited under those principles. On fees and penalties, a NIB licensee may charge fees and commissions for services, and those amounts constitute the institution’s own income. However, any penalty for overdue payment must be ring-fenced in a separate designated account and disbursed in full to charitable causes approved by the NIBAC. A NIB licensee is expressly prohibited from deriving any financial benefit from penalty receipts.
Expected regulatory developments beyond banking
The issuance of the NIB Guidelines by the Bank of Ghana is likely to trigger corresponding regulatory developments across other segments of the financial system. In particular, attention will turn to the SEC and NIC, both of which will need to adapt existing frameworks to accommodate NIB financial activities within their respective mandates. On the securities side, the introduction of non-interest banking creates a regulatory foundation for NIB investment products, collective investment schemes, and capital market instruments that align with NIB principles. Similarly, developments on the insurance side are likely to follow. The NIC will need to consider how existing insurance regulations apply to non-interest insurance products and risk-sharing arrangements that differ from conventional insurance models.
Conclusion
The NIB Guidelines represent a significant step in Ghana’s financial sector development. In the near term, the focus will be on implementation within the banking system, particularly the operation of the NIB-inclusive model by existing financial institutions and the licensing of any NIB-only financial institutions. Over time, corresponding regulatory developments are expected across the capital markets and insurance sectors, supported by coordinated oversight and advisory arrangements. Taken together, these measures lay the foundation for a coherent non-interest banking and finance ecosystem that expands product choice, strengthens financial inclusion, and preserves regulatory discipline within Ghana’s financial system.
