The recommended structure gives the EMI approval over one complete customer price schedule. The fintech supplies evidence about acquisition, app use, charges and support, with enforceable commitments to correct poor outcomes. Launch without inactivity charges, include effective essential support in the core service, and retain premium features only where their additional benefits justify their price. These are product recommendations; the facts described establish no legally fair fee amount.
- The UK EMI must assess value for its in-scope retail wallet. Ghanaian incorporation does not transfer that responsibility or make the supplier FCA-authorised. (FCA Handbook, PRIN 3.1.1AR, 3.2.1BR and 2A.4.14R.)
- Assess total customer costs, each component product and the intended package. Include linked app charges and distribution remuneration without counting the same money twice. (PRIN 2A.4.7R–2A.4.8R and 2A.4.16R.)
- Test subscriptions and FX charges against benefits available to each customer group. For this launch, remove inactivity charges and include essential support in the core service. (PRIN 2A.2.8R, 2A.4.11G and 2A.6.2R.)
- Require data access, prior pricing approval, regular monitoring and funded remediation in the programme agreement. A supplier indemnity leaves the EMI's regulatory responsibility intact. (PRIN 2A.4.14R and 2A.4.24R–2A.4.27R; Electronic Money Regulations 2011, reg. 36.)
- Keep Ghanaian permissions and any Ghana-facing FX activity within the approved operating model. A UK pricing approval supplies no Ghanaian permission. (Ghana Payment Systems and Services Act, 2019, Act 987, ss. 7 and 43; Foreign Exchange Act, 2006, Act 723, s. 3.)
Establish the customer scope
The Duty applies to the EMI's retail market business, including relevant payment and e-money activities. Payments scope includes consumers, micro-enterprises and qualifying small charities. A business-wallet label therefore does not settle the question. Larger business customers require separate classification; Financial Ombudsman eligibility uses a different test. (PRIN 3.2.1BR and 3.2.6R–3.2.8R; FCA Glossary, “retail customer”; DISP 2.7.)
For this programme, the assessment should identify where customers are located, their legal category and the services supplied to them. Ghanaian staff supporting a UK wallet do not, by their location alone, remove the UK EMI's duties. Any proposal to add customers outside the UK needs a fresh territorial check. (PRIN 3.3.1R; PRIN 2A.1.)
The FCA's June 2026 consultation proposes changes to overseas-customer scope and distribution-chain arrangements. Those proposals do not provide an exemption for this launch. As at 5 November 2026, the FCA expects any new rules in the first quarter of 2027. (FCA, CP26/23, “Next steps”, updated 21 September 2026.)
The operating route is addressed separately in UK business wallets for a Ghanaian fintech under an EMI principal. The pricing decision starts with the roles and customer market selected for that route.
Allocate the assessment by actual influence
The EMI issuing and operating the wallet is a manufacturer for Consumer Duty purposes. Determine whether another regulated participant also designs the product or determines its essential features. A contract calling that participant a distributor cannot settle its actual role. Where firms manufacture together, their written agreement must allocate responsibilities for the value assessment. (FCA Glossary, “manufacturer”; PRIN 2A.3.11R and 2A.4.13R.)
If the fintech is an unregulated technology and acquisition supplier, its obligations under this arrangement are contractual. Collaborating with it leaves the EMI fully responsible for its own manufacturer obligations. If the supplier or a group company is itself a firm within the Duty's scope, assess its direct obligations separately. (PRIN 2A.4.14R; PRIN 3.1.)
The responsibility schedule should name who sets each fee, supplies each benefit, approves promotions and holds the relevant records. Include introducers, affiliates, FX providers and support subcontractors where their charges or actions affect value.
A regulated distributor needs enough information to understand the manufacturer's value assessment and the effect of its own distribution arrangements. It must consider remuneration received by itself and, so far as it knows, others in the chain. It does not routinely have to reproduce the manufacturer's assessment. Where the manufacturer controls the final price, including commission, the FCA's guidance permits proportionate reliance while preserving the distributor's obligations. (PRIN 2A.4.15R–2A.4.18R; FCA FG22/5, paras. 7.31–7.35.)
Assess what the customer pays and receives
Start with the whole period customers can reasonably be expected to hold the wallet. Model subscriptions, FX use, optional purchases and contingent charges together. If products are intended to be supplied as a package, assess each component and the package. Splitting an indispensable app fee into another contract does not establish that customers receive value. (PRIN 2A.4.5R–2A.4.8R.)
Count the customer charge once. If the EMI collects a fee and pays part to the fintech, the revenue share is an allocation of that fee. Record the allocation to assess incentives and distribution costs, but do not add it again to the customer's total. Add any genuinely additional charge imposed elsewhere in the chain.
Benefits need evidence: usable currency conversion, payment functionality, access, reliability and the service actually delivered. Assess limits, outages, failed transactions and the effort needed to obtain help, switch or cancel. Personal-data use can also impose non-financial costs. (PRIN 2A.4.8R and 2A.4.10G; FG22/5, paras. 7.24–7.29.)
Compare active users, occasional users, customers with low balances, frequent FX users and those paying for priority support. Examine relevant vulnerability characteristics without assuming every Ghana-linked customer is vulnerable. Product averages can conceal groups paying recurring charges for little usable benefit. (PRIN 2A.4.8R(4) and 2A.4.11G.)
Competitor prices can challenge an assessment, but matching them does not establish fair value. Nor does customer acceptance replace the EMI's judgement. The FCA's 29 October 2026 consumer-finance findings reinforce these evidential points. Their examples may inform a wallet assessment, but create no new requirements or wallet-specific price limits. (PRIN 2A.4.9G and 2A.4.20R; FCA, Fair value in consumer finance, sections 2 and 4.5.)
Provider costs and profit can inform the assessment. High acquisition costs or an agreed revenue share do not themselves establish customer benefit. The Duty does not prescribe cost-plus pricing or a maximum profit. (PRIN 2A.4.9G; FCA, Price and Value Outcome: Good and Poor Practice, updated 10 July 2026, section 1 and section 5, Finding 5.)
Change the proposed fee design
Monthly subscription
Specify the continuing service purchased by the subscription and test whether occasional users can reasonably obtain its benefits. Examine what happens after introductory discounts end and when activity falls. A subscription can provide value through continuing access or availability; every customer need not use every feature each month. Persistent non-use should trigger investigation and appropriate support. (PRIN 2A.4.1R, 2A.4.5R and 2A.4.24R.)
For this programme, offer a clear downgrade or exit route when the paid package ceases to fit the customer. Confirm how cancellation affects unused prepaid charges and wallet redemption. Payment-services rules govern proportionate recurring charges on termination, while e-money redemption has separate conditions. (Payment Services Regulations 2017, SI 2017/752, reg. 51(4); Electronic Money Regulations 2011, SI 2011/99, regs. 39–42.)
FX spread
Include the FX margin in the assessment even where no separate conversion fee appears. The evidence should record the currency pair, transaction size, timestamp, reference rate, customer rate, additional fees and amount received. Compare realistic usage patterns and the total price of the same transaction. A margin against a selected benchmark is an analytical measure whose assumptions must be stated.
Keep quote approval and spread changes within the EMI's controls. Required customer information includes charges and the applicable exchange rate or reference-rate method. An agreed reference-rate movement and a discretionary increase in markup need different change-control treatment. (PSRs, reg. 50 and sch. 4, para. 3; PRIN 2A.5.3R.)
Inactivity charges
Remove the proposed inactivity fee from the initial product. A subscription plus a second recurring charge when the wallet is unused needs evidence of continuing customer benefit. The facts described supply none. Small balances, illness, lost access and unresolved account restrictions can make repeated deductions particularly harmful. (PRIN 2A.2.8R and 2A.4.8R.)
This recommendation does not establish a universal ban on inactivity charges. Any later proposal needs its own value evidence, notices, cumulative-charge controls and a usable exit route. Test the fee's substance against the redemption rules; renaming a redemption charge does not remove their restrictions. (EMRs, regs. 39–42; PRIN 2A.6.2R.)
Paid priority support
Retain a premium tier only for a demonstrable additional service. Define the benefit, staffing, availability and performance measures. Compare paid and standard service outcomes before assigning a value to faster access.
The core service must provide effective support for using the wallet and exercising customer rights. Access to fraud reporting, complaints, cancellation and necessary assistance should not depend on buying priority status. A deliberately ineffective standard queue would undermine the product's value. The Duty permits enhanced service benefits while prohibiting unreasonable support barriers. (PRIN 2A.4.10G(1) and 2A.6.2R–2A.6.4G.)
Supply an evidence package the EMI can challenge
The fintech should provide acquisition-channel data, referral rewards, conversion rates, cancellations, app-usage records and support performance. It should disclose every charge it or its subcontractors impose, their calculation methods and who receives the proceeds. The EMI should combine this with its payment, balance, FX and complaint records.
The approval package should contain:
- The target market, customer categories and excluded uses, with a reason for the selected groups.
- A versioned fee schedule and cash-flow model covering cumulative charges and different usage patterns.
- Evidence of benefits, availability, limitations, support outcomes and customer understanding of charges.
- Remuneration arrangements and an explanation of the work paid for at each distribution stage.
- Findings for relevant customer groups, unresolved data gaps, proposed changes and named decision owners.
For a new product, distinguish forecasts and testing from observed customer outcomes. Explain assumptions, challenge adverse scenarios and set the post-launch evidence needed to test them. Lack of trading history cannot justify presenting projected benefits as measured results. Manufacturer testing and ongoing monitoring must match the product and risk. (PRIN 2A.3.9R and 2A.9.8R–2A.9.11R.)
Use aggregated or appropriately protected records where they answer the question. The evidence-sharing agreement must specify purposes, data roles, access and lawful international-transfer arrangements. Fair-value monitoring does not itself authorise unrestricted transfer of identifiable customer or vulnerability data. (UK GDPR, arts. 5, 6, 9, 28, 44A and 46; Ghana Data Protection Act, 2012, Act 843, ss. 17–20 and 28–30.)
Put pricing control and remediation into the agreement
The programme agreement should require the fintech to provide complete fee and performance information before launch and with each monthly revenue statement. Monthly reporting follows the proposed billing cycle; the EMI should set faster escalation for emerging harm and a review frequency suited to the product. Include record access and duties to obtain necessary information from subcontractors. (PRIN 2A.4.2R, 2A.4.24R and 2A.9.)
Require prior written EMI approval for changes to fees, FX markups, benefits, support, incentives or target markets. A significant product adaptation needs a value assessment before marketing or distribution. Customer-notice and termination requirements remain separate, including the normally applicable two-month advance notice for framework-contract changes. (PRIN 2A.4.3R; PSRs, reg. 50.)
Give the EMI power to stop a harmful charge or promotion, require a remedial plan, identify affected customers and direct appropriate refunds or other redress. Allocate responsibility for paying for corrections and adjust revenue share attributable to refunded charges. Customer remediation should continue while the parties resolve their own liability dispute. (PRIN 2A.4.25R–2A.4.27R; EMRs, reg. 36.)
Avoid bonuses tied to inactivity fees, support upselling during distress or unnecessary FX transactions. Reward acquisition and service quality using measures that remain consistent with customer outcomes. The agreement should permit remuneration changes when monitoring exposes harmful incentives. (PRIN 2A.8.2G.)
Keep the Ghanaian activity within its approved scope
The fintech should supply its actual Ghanaian permissions and a description of the services performed there. Software and acquisition labels do not settle whether those activities require Bank of Ghana authorisation. For an existing licensee, a new or materially changed product or service can require approval. (Act 987, ss. 7 and 43; Bank of Ghana Notice BG/GOV/SEC/2020/14.)
Keep customer conversion with the EMI or an appropriately authorised provider under the proposed model. Receiving contractual remuneration differs from undertaking independent FX business. If the fintech proposes currency dealing, local collection or Ghana-facing wallets, obtain the necessary local analysis before enabling those functions. A person acting under Act 987's agent regime also faces its express FX restriction. (Act 723, ss. 3 and 15; Act 987, s. 91(1)(d).)
Complete the approval sequence
Confirm customer scope and the role allocation. Revise the fees and support proposition, assemble the evidence, and record the EMI's challenge and approval decision. Sign the information, change-control and remediation commitments before launch. Test disclosures and support, then monitor the first billing cycles against the assessment's assumptions.
Prepare the pricing review
The principal programme review provides the wider contractual context. To review your programme's pricing and responsibilities, contact Licentium with the proposed fee schedule, revenue-share terms, customer groups and available value evidence.