After lauding the Bank of Ghana (BoG) for suspending MTN MoMo’s 0.75% wallet-to-bank charge, CUTS International is raising strong consumer protection concerns over the suspended charge, arguing that the manner in which the fee was introduced breached basic principles of fair notice and duty of care expected from a dominant market player.
The public policy advocacy organization says its concerns go beyond MTN MoMo‘s fee itself and instead center on how the charge was communicated to millions of customers who rely heavily on mobile money for daily financial transactions.
The comments come after the Bank of Ghana directed Mobile Money Fintech Limited (MMFL) to suspend implementation of the charge pending further consultations.
Dominance Comes With Responsibility
In a statement released by the consumer protection organization, CUTS International revealed that MMFL controls roughly 75% of Ghana’s mobile money market, making it the dominant player within the sector.
The West African Regional Director of CUTS International, Appiah Kusi Adomako, believes that the level of market dominance creates a special responsibility toward consumers.
He was quick to add that while competition law does not prohibit a company from becoming dominant, global competition principles prohibit the abuse of that dominant position, particularly where companies possess enough market power to introduce charges without facing significant customer losses.
In simple terms, the organization believes MTN MoMo’s market influence means many customers may have limited practical alternatives, especially given how deeply embedded the service has become in everyday economic activity across Ghana.
The Responsibility of Fair Notice
One of the criticisms from CUTS centers on what it describes as the inadequate notice period provided before the planned implementation of the fee. According to the organization, giving customers barely one week’s notice before introducing such a significant new charge undermines the principle of fair notice.
According to Appiah Kusi Adomako, fair notice is a key foundation of consumer protection and ethical business conduct. He therefore described the actions of MTN MoMO as a textbook example of conduct that risks amounting to abuse of market dominance.
“Giving consumers barely one week’s notice about such a significant new charge is, in our view, a textbook example of the kind of conduct that constitutes an abuse of dominance. It is not just a matter of inconvenience; it is a fundamental breach of the principle of fair notice, ”he noted.
He added, “Consumers deserve adequate time to understand a change, assess its implications, and make an informed choice about whether to continue with a provider or switch to an alternative.
CUTS further argued that the short notice period effectively weakened consumers’ ability to make informed choices. In theory, dissatisfied customers could switch to competing mobile money services such as Telecel Cash or AT Money.
However, in practice, the organization says a seven-day notice period is too short for many consumers and businesses to meaningfully reorganize their financial habits, payment systems, merchant relationships, and transaction channels.
For many users, switching providers is not as simple as changing a SIM card. Entire customer networks, suppliers, payment relationships, and business operations are often tied to one dominant mobile money platform.
Duty of Care in a Digital Financial Economy
Moreover, beyond competition concerns, CUTS International further raises a broader question about corporate duty of care in digital finance.
As mobile money platforms increasingly function like financial infrastructure rather than ordinary telecom products, the consumer protection advocate argues that operators must exercise greater caution, transparency, and sensitivity when introducing changes that directly affect millions of livelihoods.
CUTS believes the issue raises important questions about fairness, transparency, market power, and consumer rights within Ghana’s rapidly expanding digital financial ecosystem.
For now, the central bank’s suspension of the proposed charge has temporarily halted implementation; however, the bigger question of how Ghana navigates the future balance between digital finance innovation, corporate pricing power, and consumer protection lingers.
