Digital Skills and Mobile Money Agent Level 3

Who it is for. People who finished Level 2, or can show the same skills, and want to run more than one outlet or start their own business. Ghana's qualifications framework places National Proficiency II before National Certificate I. This module is written at an advanced level, comparable to National Certificate I, but it is not a CTVET curriculum. Trainees with disabilities are welcome; Units 5 to 7 include accessibility notes.

Bridge from Level 2: what you already know

Level 2 treated one kiosk. Level 3 covers several outlets and staff, reconciliation, anti-money-laundering rules, cloud backups, online selling, registering and financing a business, and a full set of simple accounts. Never use real PINs, real customer data or real money in class.

How the module works

Each unit has learning outcomes, performance criteria, the range and the evidence your assessor needs. You are judged Competent or Not Yet Competent. About 70% of the time is practical, following CTVET's Oil Palm programme split.

Competency standard

Range. Three practice outlets (play money). Evidence. Float plan; staff duty sheet; commission sums; oral questions.

Float across outlets

Poor planning and low capital cause shortages; super agents, banks and microfinance supply top-ups. With several outlets you can balance them against each other: one outlet with too much cash lends to another with too much e-float. Rules:

• Every outlet has its own float plan: opening cash, opening e-float, a top-up trigger (for example "call at GH¢1,000 cash left") and a ceiling above which cash goes to the bank.
• One person owns the decision to move float, and writes every move in a transfer log (time, from, to, amount, who carried it, who received it).
• Moving cash between outlets is the most dangerous step. Avoid carrying large cash on foot; vary times and routes; use bank deposits and e-float transfers where you can.

Supervising sub-agents and staff

You stay responsible to the network for what your outlets do. MTN's 2026 audits look for commission manipulation, unauthorised fees, cash-in and cash-out misconduct and KYC breaches, and can lead to suspension or permanent removal. So:

Agent models

At least three layers exist: the licensed e-money company; super agents or aggregators who hold large float and recruit agents; and the agents who serve customers. The Bank of Ghana's 2015 guidelines require e-money to be provided by licensed institutions, with agents acting for them. How much commission a master agent keeps from sub-agents, and what the contract says about liability, was not verified for Ghana. Foreign examples show what to ask about. A MicroSave study of agent networks in Africa, Asia and Latin America found agents are paid either directly or through aggregators (also called super agents); paying through aggregators sometimes made agents wait for their commission, and in Kenya M-PESA agents complained until Safaricom began paying agents directly once a month. In Kenya, the payment rules say a provider is liable to its customers for what its agents do under the agency agreement, the agreement cannot remove that liability, and an agent contract may not be exclusive. These are Kenyan rules, not Ghana law. Ask for the contract in writing and read it with an adviser before signing.

Commission

MTN's agent commission from March 2024 is 0.4% up to GH¢2,000 and GH¢8 at GH¢2,000 and above. A table supplied to the author states: GH¢0.20 below GH¢50; 0.4% from GH¢50 to GH¢1,999.99; GH¢8 from GH¢2,000 up. A May 2026 business article reports the same three rates, without citing an MTN document. An MTN help page on agent commissions could not be read. Figures like 1% and GH¢20 are the customer's fee, not agent pay. Get the current table from MTN in writing.

Competency standard

Range. Practice day-books and statements. Evidence. Reconciliation sheet; incident report; role plays.

Three-way reconciliation

Match three records every day: (1) your day-book, (2) the physical cash count, (3) the network's wallet statement for each outlet. Total cash + e-float should equal the starting total plus commission minus costs. Steps: count cash; read the wallet balance in the real app; list every transaction in the statement; tick each against your day-book; list unticked items; find the cause before closing. Common causes: a transaction not written down, a wrong amount, a failed transaction that still took cash, a reversal, a worker's theft.

Detecting fraud

Patterns that deserve a second look:

Agents say fraud is rising; one report said Ghanaians lost about US$1.3 million in the first quarter of 2026, and agents have faced robbery and mob anger. MTN says nobody from the company will ask for your PIN, and its calls come from 0244 300 000.

Disputes: a six-step routine

1. Stay calm; do not hand over cash or refund on the strength of an SMS.
2. Write the details: time, number, amount, what the customer says.
3. Check your own wallet in the real app or menu.
4. If the transaction failed, give the customer the network's reference and tell them how to open a complaint; do not promise what you cannot control.
5. Escalate to the network; keep logs and copies.
6. Close the entry in your book with the result and date.

Incident report

If a theft, robbery or fraud happens: make everyone safe first; tell the network at once; report to the police and the Cyber Crime Unit; call or text 292. Money already withdrawn may never come back, so report in minutes.

Competency standard

Range. A multi-outlet shop with phones and spreadsheets. Evidence. Policy sheet; settings check; backup test.

The rules

• The Bank of Ghana regulates mobile money under the Payment Systems and Services Act, 2019 (Act 987). The 2015 guidelines require licensed providers and agents acting for them.
• KYC. The agent must record a valid ID before a cash-out. Verify ID checks with your network; do not make up your own rule.
• AML. Ghana also has anti-money-laundering rules; the Act's name, number and the agent's reporting duty were not verified in this module. For comparison, Kenya's payment rules say providers and their agents must obey Kenya's anti-money-laundering law; expect a similar duty in Ghana, but confirm it. Ask your network what a suspicious-transaction report is and how to make one. Never help a customer to hide the source of money or to split amounts to avoid limits.
• MTN's audits can warn, suspend or remove an agent.
• The e-levy no longer exists; the Level 2 guide has the details.

Data protection

The Data Protection Act 2012 (Act 843) gives people rights over their personal data and created the Data Protection Commission. The Commission says anyone who collects, stores or manages personal data must register; a summary listed a small-business fee of GH¢156. A kiosk that keeps its own notebook of names, numbers or ID copies is likely a controller for those records. Section 27(1) of the Act says a data controller who intends to process personal data shall register, and being a one-person business does not remove that duty. The Commission's website has moved to dpc.gov.gh; pay only an amount shown on its own portal or invoice. Collect only what the transaction needs, do not photocopy or photograph Ghana Cards unless your network requires it, and lock away paper records.

Practical rules for a multi-outlet business: collect only what the transaction needs; do not keep ID copies; give each worker access only to what they need; lock phones and sheets; tell staff in writing never to post customer details; delete old data. The Ghana Card rule of 2026 replaces photocopying with biometric verification; whether small agents must use the NIA system, and from when, was not verified. Ask your network and the NIA.

Cybersecurity at business level

The Cybersecurity Act, 2020 (Act 1038) set up the Cyber Security Authority. Report cyber crime to 292. A business-level checklist:

Cloud backup

Back up your books and your customer-free files to the cloud. Google Drive and Google Sheets work on a phone; sheets total with SUM. The 3-2-1 rule: three copies, on two kinds of storage, one away from the shop (a common practice rule, not a Ghana law). Test a restore: a backup you have never opened is a hope, not a backup. Never put ID photos, PINs or passwords in the cloud folder.

Competency standard

Range. Practice accounts and made-up data. Evidence. Tool comparison; training plan; online profile.

Spreadsheet or accounting app

A spreadsheet in Excel or Google Sheets is free and flexible. Zoho Books has a free plan for one user plus an accountant, up to 1,000 invoices a year for revenue under US$50,000; Wave has a free Starter accounting plan. Plans change: read the current page. Start with a spreadsheet; move to an app when you have several outlets or staff, invoices to chase, or a need to show an accountant or a lender.

Government portals

Ghana.gov gives one point of access to government services at www.ghana.gov.gh, the Citizen app, or *222#; which services work fully online was not verified at Level 2. For tax you need a TIN: since April 2021 your Ghana Card number is your tax number. The GRA portals' individual steps (filing, pay by *880# under the Modified Taxation Scheme) are in Unit 5.

Online selling and marketing

• WhatsApp Business: labels, quick replies, greeting and away messages.
• Google Business Profile: free listing on Search and Maps; Google never asks for your verification code.
• Social selling: clear photos, prices, and payment only after the money is in your own wallet.
• A simple routine: three posts a week (price board, new service, customer thanks), reply within one hour, ask for referrals.
• Do not message people who did not ask; do not post customer details.

Training staff

Use four steps: tell (explain the task), show (do it in front of them), do (they do it while you watch), check (a short test and a signed record). Topics for a new MoMo worker: PIN and fraud rules, ID checks, float limits, cash counting, dispute routine, data rules. Under the Labour Act 2003, a worker employed for six months or more should have a written contract; see Unit 5.

Freelancing and remote work

Freelancing (writing, design, data entry, translation, virtual assistance) can bring dollars; one guide says common routes are Payoneer or Wise, then withdrawal to MoMo. Payoneer's own price page says a withdrawal to a local bank account in the same currency costs US$1.50, a withdrawal with currency conversion costs 1.2% to 4% depending on the currency, some countries have a minimum fee of up to US$20, and a US$29.95 yearly fee applies if the account receives less than US$6,000 in 12 months; fees for marketplaces such as Fiverr vary. These are the company's global prices, not a Ghana quote. Wise fees and the delay before money reaches MoMo were not verified. Never pay a fee to get a job; never give a PIN or Ghana Card details to an unknown "employer"; report fake offers to 292.

Competency standard

Range. A real or planned MoMo and digital services shop. Evidence. Registration checklist; budget; one-page plan; pitch.

Choose a legal form

Annual returns cost GH¢175 a year; late filing costs GH¢1,000 or GH¢2,000. A sole proprietor is simple but your personal property is at risk; a company separates you from the business but needs more paperwork. Ask an adviser before choosing.

Registration step by step

1. Ghana Card and Ghana Card number as your TIN. Companies get a GRA TIN after ORC registration.
2. Register with the ORC (name or company), using the fees above.
3. Network application. MTN's agent requirements (a guide, not an MTN document) include business registration, a tax number, a Ghana Card, a fixed shop, float and a site inspection. Confirm with MTN.
4. STMA permit. In 2025 mobile money vendor permits were GH¢270 small, GH¢330 medium and GH¢460 large; a business centre with under 11 workstations GH¢100; container permits GH¢20 per square metre. Apply on the Assembly portal. Check this year's fees.
5. Data Protection Commission: register if required.
6. Tax: register for the right scheme (Unit 6). Check the filing calendar every month.
7. Fire safety, FDA, GSA, EPA: these do not usually apply to a MoMo kiosk. Ask the Assembly and the fire service what applies to your premises (not verified).

Premises and location

Use the Level 2 checklist: footfall, safety, signal, float access, access for wheelchair users. In towns agents are crowded; many rural areas have none. A second outlet should be where the first is not: a different market day, a clinic or a school.

Accessibility. Ghana's Persons with Disability Act 2006 says those who serve the public must provide accessible facilities. Build a ramp and a low counter, and hire people with disabilities where the work suits them. The Assemblies' disability fund rose from 3% to 5% in 2026.

Start-up budget (example)

Example figures for one new MoMo and digital shop. Actual prices vary; get three quotes.

Where the money can come from

Savings; a susu or VSLA group; microfinance; a bank; the Ghana Enterprises Agency (GEA) programmes SME GO, Business-in-a-Box and others, with advisory centres in Takoradi, Shama, Effia-Kwesimintsim, Mpohor and Ahanta West. The 2026 budget set aside GH¢160 million for Adwumawura, GH¢170 million for a National Apprenticeship Programme and GH¢401 million for a Women's Development Bank. Which programme is open to you, and the terms, are not verified: ask the GEA. Where a loan is offered, keep clean records (Unit 6). Beware of anyone who asks for an advance fee.

Your one-page plan

Write on one page: the business and legal form; who the customers are; services and prices; location and permits; start-up budget and sources; the first-year profit estimate; the three biggest risks; how staff and safety are managed. Practise a two-minute pitch.

Hiring, SSNIT and insurance

• Contract: a written contract for six months or more (s.12); a written statement of terms within two months (s.13); 15 working days' paid leave (s.20); 12 weeks' maternity leave (s.57).
• Minimum wage 2026: GH¢21.77 a day, about GH¢588 a month.
• SSNIT: employee 5.5% plus employer 13% of basic pay; the employer pays SSNIT 13.5% (Tier 1) within 14 days after month-end and 5% to a Tier 2 trustee. Late payment 3% a month.
• PAYE: first GH¢588 a month tax-free; due by the 15th.
• Insurance: use only a licensed insurer; check at nic.gov.gh. Which covers are compulsory for a kiosk was not verified.

Competency standard

Range. One month of practice records for a MoMo and digital shop. Evidence. Cash book; statements; forecast; oral questions.

See also the hub's Money Skills Level 2 for the basics. This unit applies them to your shop.

The records you keep

• Cash book: every cash and wallet movement; day total and balance.
• Customer money vs your money. The customers' e-float and cash held for transactions are not your profit: only commission and service income are yours.
• Receipts and invoices for printing, typing and bill-payment services.
• Petty cash (small expenses): a fixed amount (for example GH¢100); each spend has a slip; refill the float to the fixed amount.
• Stock: paper, ink, airtime and data bundles bought for resale: opening stock + purchases − closing stock.
• Debtors and creditors: who owes you (people who took printing on credit); whom you owe (the paper seller). Write due dates.
• Ledger: one page per account (commission, printing income, rent...). Double entry: every transaction has a debit and a credit; assets equal liabilities plus equity. A trial balance (total debits equal total credits) is a partial check only, because some errors cancel out.

Sample cash book page

Example figures, one day, shop W1.

(Customers' cash movements are in the day-book of Unit 1, not here; this cash book shows the owner's money.)

Month-end routine

1. Reconcile the cash, wallet and statement (Unit 2); fix differences.
2. Reconcile the bank or MoMo account that holds your business money against your cash book.
3. Count stock; update debtors and creditors; pay or schedule the bills.
4. Add up income and costs; calculate depreciation.
5. Work out the profit statement and balance sheet; compare with your forecast.
6. Back up (Unit 3); file tax and SSNIT on their dates.

Costing and pricing

• Margin = profit ÷ selling price. Mark-up = profit ÷ cost. A 100% mark-up on GH¢3 is a price of GH¢6, a margin of 50% (the numbers are example).
• Break-even (monthly) = fixed costs ÷ (price − variable cost per unit).
• Depreciation (straight line) = (cost − salvage value) ÷ useful life.
• Owner and business money must never mix. Pay yourself a fixed wage, and write it in the books.

Worked example: profit statement

Example figures, one month, shop W1.

The helper's pay is above the monthly minimum of about GH¢588.

Worked example: balance sheet

Example figures at the end of the month.

The two sides match because assets = liabilities + equity. If yours do not match, an entry is missing or wrong: look for it, never force the number.

Break-even and cash-flow forecast

Fixed monthly costs (helper, rent, power, depreciation) are GH¢1,271.67 from the example. If one average transaction earns GH¢1.60 and variable cost is nil, break-even is 1,271.67 ÷ 1.60 = 795 transactions a month, about 31 a day over 26 days. A 12-month cash-flow forecast is a table with months across, and rows for cash in (commission, printing, loans), cash out (every cost, loan repayments, tax) and closing cash. Build it in a spreadsheet; first fill month 1 from your records and then use averages; update each month.

Tax and records

• Modified Taxation Scheme: for residents with business income only and not VAT-registered. Up to GH¢20,000 turnover: fixed instalments; GH¢20,001–750,000: 3% of turnover (the Income Tax (Amendment) Act 2026, Act 1178, raised the upper limit from GH¢500,000 to GH¢750,000; GRA's own page still showed GH¢500,000 in October 2026). Pay by *880#. Professionals, owners of several outlets and partners are excluded. If you plan several outlets, you may not qualify: ask GRA.
• Companies pay 25% standard, with lower rates for some sectors; provisional tax is quarterly.
• VAT: from 1 January 2026 under Act 1151: 15% VAT plus 2.5% NHIL plus 2.5% GETFund, effective 20%; registration threshold for goods GH¢750,000. For services there is no turnover threshold: a business supplying taxable services must register for VAT within 30 days of starting. Ask GRA whether your service is taxable; a VAT-registered business cannot use the Modified Taxation Scheme. Whether MoMo agent commission is a taxable service was not verified: ask GRA and your network.
• Withholding tax: services 7.5%; non-residential rent 15%.
• Keep records for at least six years.
• Calendar: SSNIT by the 14th; PAYE and withholding tax by the 15th; VAT by the last working day; STMA permit by 31 March; ORC return yearly.

Competency standard

Range. Real or planned business. Evidence. Standards sheet; plan; forecast; panel presentation.

Quality and customer care

• Service standards: a customer served within five minutes; correct change; prices on the wall; a "fail-safe" line for when float runs out.
• Complaints: listen, write, fix, thank. A fair reply to a dispute (Unit 2) is a marketing tool.
• Transparency: hidden prices make customers distrust agents; reliability keeps them.
• Check: a weekly mystery customer (a friend) and a review of complaints.

Pricing and scaling

Price services on cost, what neighbours charge and your target margin. Commission is fixed by the network, so profit comes from volume, fewer errors and extra services. Add a second outlet only when: (1) the first is profitable for three months, (2) you have a trusted supervisor, (3) you have a float plan, a transfer log and reconciliation, (4) you have cash for six months of costs. Roving agents who went to customers saw deposits rise about 15 times in one study; weigh it against the cash risk.

Partnerships, contracts and tenders

Read every contract (network, aggregator, landlord, supplier); keep copies; ask an adviser. Government tender rules and supplier-credit terms were not verified in this module. Bring clean records to any bank or lender.

Ethics and succession

Never charge hidden fees, split transactions for commission, or keep customer data. Plan succession: name a trusted person who knows the books and logins; keep the registration documents, contracts and passwords in a sealed envelope or manager held by two people; train a deputy. Write a simple will or instructions for the business with an adviser.

Capstone: present to a panel

Present for ten minutes to a panel (trainer, a local business person and an adviser): your one-page plan (Unit 5), your 12-month cash-flow forecast and monthly profit (Unit 6), your float and reconciliation system (Units 1–2), your data and backup plan (Unit 3) and your growth and succession idea. Answer questions.

Accessibility. Your plan should say how people with disabilities can use and work in your shop.

1. Why does an outlet need a top-up trigger?
2. Name two things a sub-agent duty sheet should include.
3. What three records do you reconcile each day?
4. Name two patterns that suggest fraud.
5. What number do you call to report cyber crime?
6. Which Act gives people rights over their data?
7. What is the 3-2-1 backup rule?
8. What is the ORC fee for a business name in 2026?
9. Why may the Modified Taxation Scheme not suit a multi-outlet owner?
10. What formula gives straight-line depreciation?
11. What is the difference between margin and mark-up?
12. Why must owner money and business money be kept apart?

Best next reads: your network's agent contract; the GRA and ORC official sites; the Data Protection Commission; the hub's Money Skills and Entrepreneurial Thinking manuals.

What this module does not cover: the exact Bank of Ghana agent licensing text, the Anti-Money Laundering Act's number and reporting duties, Telecel and AT agent rules, super-agent contracts, whether agent commission is VAT-able, typical agent incomes, cooperative registration steps and compulsory insurance.

Every source used in this manual is listed, with links, in the Teacher Copy.