Ghana, Rwanda and Zambia Test Interoperable Cross-Border Payment System

Ghana, Rwanda, and Zambia are actively testing a unified digital trade corridor designed to facilitate instant cross-border payments across their financial systems. This initiative represents a significant step towards reducing Africa's reliance on external banking intermediaries and fostering an interoperable, Africa-owned financial infrastructure, aligning with the broader objectives of the African Continental Free Trade Area (AfCFTA). The development underscores a continental push for financial integration, aiming to streamline trade, lower transaction costs, and enhance the efficiency of intra-African commerce. Legal professionals must understand the evolving regulatory landscape, including national payment systems legislation and the harmonisation efforts under AfCFTA, to navigate the complexities and opportunities presented by this digital transformation.

The African continent is witnessing a transformative shift in its financial landscape, driven by a concerted effort to foster greater economic integration and self-reliance. At the forefront of this movement, Ghana, Rwanda, and Zambia are currently piloting an interoperable cross-border payment system, a crucial component of a unified digital trade corridor. This innovative system aims to enable instant movement of funds across participating African financial systems, thereby significantly reducing the historical dependence on external banking intermediaries and foreign currencies for intra-African transactions.

This development is not an isolated event but rather a tangible manifestation of the ambitious goals set forth by the African Continental Free Trade Area (AfCFTA). The AfCFTA seeks to create a single, integrated market for goods and services across Africa, and efficient, low-cost cross-border payment systems are fundamental to realising this vision. For legal practitioners, this initiative signals a rapidly evolving regulatory environment that demands close attention, as it will reshape compliance frameworks, contractual arrangements, and dispute resolution mechanisms for businesses operating across these jurisdictions. This article delves into the legal underpinnings and implications of this interoperable payment system, highlighting the national and continental frameworks guiding its implementation.

The impetus for an interoperable cross-border payment system stems from the African Union's Agenda 2063 and, more immediately, the African Continental Free Trade Area (AfCFTA). The AfCFTA, through its Protocol on Trade in Services, explicitly prioritises financial services liberalisation to create an open, transparent, and integrated single services market. Furthermore, the recently adopted AfCFTA Protocol on Digital Trade, approved in February 2024, specifically addresses the need for secure and interoperable digital payment systems, recognising their critical role in facilitating cross-border digital trade and protecting data privacy.

At the continental level, the Pan-African Payment and Settlement System (PAPSS), launched in January 2022 by the African Export-Import Bank (Afreximbank) in collaboration with the African Union and the AfCFTA Secretariat, serves as a central financial market infrastructure. PAPSS enables instant or near-instant payments in local currencies across Africa, bypassing the need for third-party currency conversions and correspondent banking chains, thereby reducing costs and accelerating settlement. This system is already operational in 15 countries, connecting over 500 banks, and aims to cut settlement times from days to minutes.

Nationally, Ghana operates under the Payment Systems and Services Act, 2019 (Act 987), which repealed the earlier Payment Systems Act (Act 662) and consolidates laws relating to payment systems, services, and electronic money business, with the Bank of Ghana (BoG) as the primary regulator. Rwanda's payment system is governed by Law No. 061/2021 Governing the Payment System, which came into force in November 2021, and Law N°03/2010 concerning Payment System, with the National Bank of Rwanda (NBR) exercising supervision and oversight. Zambia's framework is anchored by the National Payment Systems Act, 2007 (NPSA), which empowers the Bank of Zambia (BoZ) to license and supervise payment service providers, though a newer National Payment System Act, 2026, is set to repeal and replace the 2007 Act, further enhancing the regulatory landscape.

The testing of an interoperable cross-border payment system by Ghana, Rwanda, and Zambia highlights both the opportunities and significant legal challenges inherent in achieving seamless financial integration across diverse jurisdictions. A primary legal challenge is the fragmentation of regulatory frameworks across African nations. While each country has its national payment systems legislation—such as Ghana's Payment Systems and Services Act, 2019 (Act 987), Rwanda's Law No. 061/2021 Governing the Payment System, and Zambia's National Payment Systems Act, 2007 (NPSA), soon to be replaced by the National Payment System Act, 2026—these laws often have differing requirements for licensing, operational rules, and compliance.

Regulatory harmonisation is therefore paramount. The AfCFTA Protocol on Digital Trade, while adopted, still has ongoing negotiations for eight supplementary annexes, including those on cross-border digital payments and financial technology. These annexes are crucial for establishing common standards for electronic documents, digital identities, data protection, cybersecurity, and fintech regulation, which are currently inconsistent across the continent. For instance, the National Bank of Rwanda has also issued specific directives governing foreign currency transactions, which would need to be considered in a multi-currency interoperable system.

Furthermore, the implementation of such a system necessitates robust legal frameworks for consumer protection, dispute resolution, and anti-money laundering (AML) and combating the financing of terrorism (CFT). Inconsistent Know Your Customer (KYC) and AML frameworks across borders create friction for payment service providers and risks for regulators. The Bank of Zambia, for example, requires a comprehensive risk management framework addressing cybersecurity, operational, credit, liquidity, and AML/CFT risks for designated payment systems. Similarly, Ghana's Payment Systems and Services Act, 2019 (Act 987) includes provisions for consumer protection and compliance requirements. The success of interoperable systems hinges on aligning these critical safeguards to build trust and ensure the integrity of cross-border transactions.

The Pan-African Payment and Settlement System (PAPSS) provides a foundational infrastructure for this interoperability, connecting central banks and commercial banks to facilitate real-time gross settlement in local currencies. However, the legal and operational frameworks of individual participating countries, including their national real-time gross settlement (RTGS) systems, must seamlessly integrate with PAPSS. This requires not only technical compatibility but also legal clarity on issues such as finality of settlement, governing law for cross-border contracts, and the recognition of electronic evidence across jurisdictions. The ongoing efforts by central banks, such as the Bank of Ghana's Payment Systems Strategy (2025-2029) and Rwanda's National Payment System Framework and Strategy (2018-2024), demonstrate national commitments to modernising payment ecosystems and promoting interoperability, which are vital for the success of regional initiatives.

The pilot of an interoperable cross-border payment system by Ghana, Rwanda, and Zambia marks a pivotal moment in Africa's journey towards deeper financial and economic integration. This initiative, driven by the vision of the AfCFTA and supported by continental platforms like PAPSS, promises to unlock significant trade opportunities, reduce transaction costs, and enhance financial inclusion across the continent. For legal practitioners, this evolving landscape presents both challenges and opportunities. The imperative for harmonised regulatory frameworks, particularly concerning payment services, digital trade, data protection, and AML/CFT, cannot be overstated.

Practitioners must closely monitor the ongoing negotiations of the AfCFTA Digital Trade Protocol's annexes and the implementation of new national payment system legislation, such as Zambia's forthcoming National Payment System Act, 2026. Understanding the interplay between national laws and continental initiatives will be crucial for advising clients on compliance, structuring cross-border transactions, and mitigating legal risks. The successful scaling of these interoperable systems will depend on sustained political will, robust regulatory cooperation among central banks, and the proactive engagement of legal professionals in shaping and adapting to Africa's digital financial future.