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GhanaVASP Act 1154 of 2025 establishes a shared framework between Bank of Ghana and the SEC, with implementation continuing during 2026. Authorised testing covers specific activities, including different forms of tokenization, but provider census registration and sandbox participation do not establish general commercial licensing. Launch planning must distinguish entity permissions, approved pilot activities, advertising and restrictions on virtual-asset payment use.
In Ghana, a business evaluating virtual asset services must distinguish the law establishing the framework from its operational implementation. The central bank and securities authority share responsibilities, while testing programmes define what each participant may do. Preliminary registration or inclusion in a sandbox list has a different scope from a commercial licence.
Tokenizing gold, bonds or other rights raises another question: what the investor legally receives and who is accountable for it. This guide connects testing permissions with those rights, advertising restrictions and limits on virtual asset payments, allowing a project to be prepared without assuming implementation is complete.
What the VASP Act establishes and what awaits implementation
VASP Act 1154 of 2025 establishes the basis for provider registration, licensing and supervision. Bank of Ghana confirms parliamentary passage in December 2025. The law targets service provision; it does not turn personal ownership into VASP activity or guarantee assets offered by a provider.
That framework must be separated from operational implementation. In his 25 August 2026 remarks, the governor explained that BoG and SEC were developing guidelines and sandboxes towards fully operationalising the Act by 2027. This is an implementation objective, not a guaranteed date for issuing permissions to any applicant.
How BoG, SEC and FIC responsibilities differ
Bank of Ghana, BoG, and the Securities and Exchange Commission, SEC, share supervision according to activity. The SEC communication includes exchanges, trading platforms, issuance, tokenization, exchange-traded funds, management, advice and brokerage within its remit. It also distinguishes securities-related advocacy, mining and validation; this should not be extrapolated to every technical activity.
The Financial Intelligence Centre, FIC, handles relevant AML and counter-terrorist financing responsibilities. The coordination committee established in 2026 brings together supervisors and other authorities, including cybersecurity. Coordination creates neither an alternative licence nor permission to replace the competent supervisor's approval with tax, company or unrelated sectoral registration.
How the census, sandbox and licence differ
The mandatory census of 10 July 2025 identified providers serving residents, including through digital platforms. It set a 15 August 2025 deadline and expressly stated that registration was not licensing or approval. It is not presented as an ordinary application process open in October 2026, even where the page linking the notice displays a later date.
The SEC programme announced in March 2026 provides twelve months of testing and possible transition after six months for compliant, market-ready participants. Sandbox guidelines subject participation to conditions, safeguards and oversight. Neither completing six months nor appearing on a list automatically produces a commercial licence; subsequent individual decisions must be checked.
What tokenization trials establish
The SEC list of 19 August 2026 identifies pilots tokenizing gold, securities, Treasury bills, bonds and trade finance. It separately identifies gold custody, brokerage, exchange and platform functions. This establishes defined, authorised testing activities; it does not establish general permission to issue every asset or sell to every investor.
Each product must identify the represented right, issuer, registered underlying-asset owner, custody and enforcement on default. Pilot permission does not establish that a token transfer automatically transfers land or company ownership. Documentation must also resolve transferability, customer restrictions and insolvency treatment, without attributing unconfirmed legal effects to the technology.
Which restrictions affect advertising and payments
The joint notice of 20 February 2026 requires express authorisation for public virtual-asset and stablecoin campaigns, including sandbox operators, and addresses registration of advocacy activities. The joint AML communication emphasises identification, controls and obligations of in-scope institutions. A testing programme does not remove those requirements.
BoG FAQs retain the cedi as legal tender and state that invoicing, pricing and wages may not be denominated in virtual assets. They also distinguish regulated partnerships with banks or electronic money issuers, subject to controls and approval. The actual payment flow requires assessment; investment activity should not be confused with unrestricted payment use.
What to prepare for regulatory assessment in Ghana
Prepare an activity description and identify the requested stage: testing or commercial service. Specify the supervisor, customers, assets, custody and trial limits. If participating in a sandbox, include the decision and its conditions; the public list alone does not establish additional permissions or an already granted transition.
For a tokenized offering, document the claim against the issuer and control of the underlying asset. Plan advertising and cedi payment flows separately. Official communications establish the framework, but the complete text of Act 1154 was not recovered: final category rules, permission conditions and token effects need specific verification.
To understand how this framework applies to your project, discuss your case with our team.
Key takeaways
- Act 1154 should not be confused with general opening of all licensing categories.
- The 2025 preliminary census did not authorise operations.
- The August 2026 SEC list identifies specific pilot activities.
- Advertising, payments and token rights require separate assessment.
Regulatory milestones
Mandatory preliminary census
The BoG notice states that registration is not licensing.
Restrictions on public campaigns
BoG and SEC require express authorisation, including for sandbox participants.
Pilot activity list
SEC publishes sandbox participants and their specific activities.
Frequently asked questions
No. The SEC provides for possible transition of compliant, market-ready participants. The individual decision and covered activities need checking.
The July 2025 census notice states that registration is neither licensing nor approval. Its purpose was to identify providers. A business must establish the permission relevant to its activity and stage rather than present preliminary registration as authorisation for products or commercial solicitation.
Bank of Ghana’s FAQs state that virtual assets are not covered by deposit protection or a statutory compensation fund. Supervision of a provider does not turn the asset into a bank deposit. Customer disclosures should explain risks and contractual rights.
The February 2026 joint notice requires express authorisation for public virtual asset and stablecoin campaigns, including sandbox participants. Businesses should check campaign conditions before arranging publicity; admission to testing does not settle this requirement.
Bank of Ghana’s FAQs contemplate regulated partnerships subject to risk management, compliance and supervisory approval. Specify flows and each party’s functions. That possibility does not establish that every private agreement or technology integration is already authorised.
