Mobile Money Agents Association of Ghana (MMAAG)

1. POST E-LEVY SURVEY/RESEARCH
BY
MOBILE MONEY AGENTS
ASSOCIATION OF GHANA (MMAAG)
Prepared by: RESEARCH TEAM
MMAAG
Dated: October, 2022.

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TABLE OF CONTENT
1.0 Organogram of MMAAG
2.0 Background of the study
2.1 Statement of problem
2.2 Purpose of the study
2.3 Objectives of the study
2.4 Research questions
2.5 Significance of the study
2.6 Limitations of the study
3.0 Methodology
3.1 Survey design
3.2 Population of the study
3.3 Population Sampling techniques
3.4 Data collection
3.5 Analysis of data
6.0 Conclusion
6.1 Recommendations

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2.0 BACKGROUND OF THE STUDY
The mobile money financial sector started in 2009 in Ghana and it has become one of the
fastest growing financial sectors in Ghana. In 2014, empirical data shows that, only 13%
percent of the Ghanaian adult population from the ages of 15years and above has mobile
money accounts. Fast forward in 2017, 39% of the same age group has registered on the
mobile money services, a three-fold increase over the 3-year period. According to Max
Martin, a financial sector specialist, after three years of the introduction of mobile money in
Ghana, only 350,000 Ghanaians were actively using mobile money accounts.
However, Tanzania introduced mobile money only a year before Ghana and had about 8
million active accounts by the time Ghana reached the 350,000 users.
Faced with the problem of penetration difficulties, providers and experts were concerned that
uptake would never reach the levels found in Kenya and Tanzania.
Fast forward today in the same industry, empirical studies show that, the mobile money
industry is the fastest growing financial industry in Ghana with over 17.1 million active
customers, three hundred and twenty-eight thousand (328,000) agents who serve as the
intermediaries between the service providers and the customers, 7million daily transaction
volumes and GHC 7billion float balance according to 18th Knowledge Forum held by Ghana
Chamber of
Telecommunications in September, 2021. An achievement that has never been seen in the
banking industry over 10 years. There are so much trending views and discourse regarding the
fast-growing financial sector in the industry concerning taxation of the services by the
government of Ghana.
One side of the dissenting views are of the argument that, mobile money contributes GHC
250 million in tax from corporate tax and withholding tax from agents’ commissions,
therefore, introducing another direct tax on the services of mobile money is a course to
impede the progress of the sector. Among all the views, there is a total neglect and focus on
the agents who serve as intermediaries between the service providers and the larger
consumers of the services, the need to take a critical look at the impact of the e-levy on the
sector and the challenges facing the agents

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2.1 STATEMENT OF PROBLEM
Empirical studies shown that, consistency in the use of mobile money to access social-
economic services will result in promoting financial inclusion, financial empowerment and
general wellbeing of people (Amoah, Korle & Asiama, 2020). Other research works explore
the causes of fraud in the fast growing financial sector (mobile money services) in Ghana and
the effort to eradicate or minimize these frauds that characterize the mobile money services.
One of such studies was conducted recently due to rampant fraudulent transactions and the
need to minimize or eradicate these fraudulent transactions with effective and practical
measures in place to sustain the service (Akomea-Frimpong et al, 2019). Other papers also
examine the experiences of the service consumers in Ghana and also the impacts on society,
financial service innovation, delivery and operations (Glavee-Geo et al, 2019).
Researchers such as Twumasi, Baffour and Mohammed, 2020, also contributed to the
literature by examining the impact of mobile money access on internal remittances received
per capita consumption expenditure and welfare of household in Ghana to add knowledge to
the growing discourse of the mobile money financial sector.
However, much attention has not been paid to the most important intermediary between the
service providers and the consumers of the services. Over the recent years, there have been
several attacks on the agents of the mobile money services in the country, with several of
these victims being bathed with acid, others ending up with one or several deformities, loss of
monies and other valuable items and the worse of all several losses of lives. This has become
a critical problem facing the growing mobile money sector that policy makers should
prioritize other than burdening the sector with levies, based on our experience as major
players in the sector.
However, attention has not been paid to this problem by government authorities,
telecommunications networks, experts and researchers. There are several agitations from the
agents or merchants over their total neglect in the supply chain of the service provision and
how they contributed to the success of the mobile money sector of Ghana.
One can predict the usage of mobile money services in Ghana without the numerous agents
serving as the intermediaries to help get consumers served. This study is of much essence to
focus once again on the impacts of the e-levy on mobile money on the economy of Ghana and
the challenges facing the agents or merchants of the services. The agents are now coming

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under groups to champion their contributions in the sector and why attentions must be paid to
them.
Among these emerging groups is the Mobile Money Agents’ Association of Ghana
(MMAAG), the fastest growing body with the highest membership.
2.3 PURPOSE OF THE STUDY
The purpose of this survey is to examine the impacts of e-levy on mobile money services in
Ghana and the challenges facing the agents or merchants who serve as the intermediaries
between the telecommunication companies and the final consumers of the mobile money
services in Ghana.
2.4 RESEARCH OBJECTIVES
To examine the impacts of e-levy on mobile money services in Ghana.
To examine the challenges the e-levy poses on agents or merchants and the entire mobile
money ecosystem.
To explore the need for policy makers to pay attention to the agents as crucial stakeholders in
the mobile money value chain.
2.5 RESEARCH QUESTIONS
What are the impacts of e-levy on mobile money services in Ghana?
What are the challenges e-levy poses on the agents or the merchants of the mobile money
services?
What are the solutions to the challenges facing the agents or merchants?

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2.6 SIGNIFICANCE OF THE STUDY
The significance of this research focuses on three strands; relevance to future research by
providing information as source document for future researchers who will like to fill future
gaps in the phenomenon, relevance to practice and as a guideline for policy makers as this
research work will bring to light the impacts of e-levy and challenges facing the agents as one
of the principal stakeholders helping the mobile money service sector to grow.
Concerning the research significance, the mobile money sector of Ghana is still an emerging
financial sector, this research work will add to the few existing literature concerning the
phenomenon and help future researchers to obtain information for future researches that will
provide indebt knowledge of the sector and help to attain the full potentials of the sector. It
also reminds future researchers of Mobile Money Agents Association of Ghana (MMAAG)
and other mobile money vendors as one of the key stakeholders playing critical role in
championing the success of the emerging mobile money sector of Ghana and the need to
consider them in future research works.
Concerning significance to practice, it offers the opportunity to bring the challenges
confronting members of MMAAG or other operators of the mobile money services to light,
this helps the various associations to educate their members on the challenges of the
businesses and how those challenges can be minimized or avoided. It also helps those agents
who might not be in the various agents’ associations to join to have the benefits of the
education that will crop out of this research work.
Concerning significance to policy, the study exposes the challenges of e-levy to government
and policy makers and gives them the opportunity to tactically devise strategic measures in
addressing the challenges and the need to pay much attention to MMAAG and other agents.
2.7 LIMITATIONS OF THE SURVEY
The mobile money merchants or agents are operating in all parts of the country but this survey
will only focus on the agents that belong to the Mobile Money Agents Association of Ghana
(MMAAG) based on proximity for ease of data collection and time constraint for the study
since the agents are operating in every length and breadth of the country.

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Also, there is possibility that, some of the members of the Mobile Money Agents Association
of Ghana (MMAAG) may not have the access to the questionnaires since they may not have
smartphones and proper educational background to attend to the questions. Also, some of
these agents might not be operating the businesses themselves but have people employed, the
employees may not show keen interest in the survey.
The study focuses more on the challenges of e-levy on the mobile money services. All other
challenges of the sector are not captured under this work.
This work is also restrained by the time available to undertake it. This poses major limitation
as we may not have the luxury of time to get major issues captured.
Also, the sample size chosen is too small as compared to the total number of agents operating
all over the country. Our outcome may not reflect the concerns of all the agents in the country
or may be slightly different if all agents should be captured.
Lastly, the survey focuses on only the members of MMAAG.
3.0 METHODOLOGY
This research makes use of simple qualitative method to describe recorded observations and
analyze metrics to determine the impact of e-levy on agents. The observation span from May
2022 to September 2022. Respondents were required to simple describe the trend of their total
transactions, cash-in commission, cash out commission respect to the said duration. In
addition, based on the observed trends, respondents were asked to provide expectations and
recommendations to stakeholders regarding the e-levy tax policy.
3.1 SURVEY DESIGN
The survey makes use of an online google questionnaire to gather responses. Both multiple
choice questions and open-ended methods are used to design a total of nine key questions, and
a basic bio-data section. The form was designed, tested with 30 agents for feedback. Positive
feedback gave room for redesign and making the form more robust to achieve the survey
objectives. Find the link to the 7-page survey form. http://bit.ly/mmaagpostelevysurvey22

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3.2 POPULATION
Considering the limited time, the survey aimed at sampling 1000 responses from the over
300,000 agents and merchants across the country: both registered and unregistered mobile
money agents. This population is characterized by a common knowledge about the e-levy and
its effect on the mobile money business as over 80% of respondents belongs to a registered
agents association.
3.3 POPULATION SAMPLING TECHNIQUE
The survey employed the random sampling technique from the identified population. 927
samples were collected after data cleansing for analysis and output presentation. This sample
had prior notice education on how to provide appropriate responses to the research questions.
3.4 DATA COLLECTION
Data collection was through an online google form. A notice through WhatsApp and text
messages were sent to the population seeking their responses. The 927 data samples were
collected over a 5-day period.
3.5 ANALYSIS AND PRESENTATION OF DATA
To statistically answer the key research questions of this survey, thereby achieving the
objectives, the following analysis of the responses collected are:

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3.5.1 REGION OF OPERATION
This question is key to analyze the impact on regional bases. In addition, such vital responses
are valuable in preparing remedies to agents across the country. For instance, consultations,
education and other programs regarding e-levy policy and other similar future policies needs
to concentrate on regions that are more impacted. From the responses, the Greater Accra
region has the highest number of 158 respondents representing 17%. On the contrary,
Savannah and North East with the lowest respondents of 4 and 8 representing 0.4% and 0.8%
respectively.
This calls for more publicity and education about MMAAG and its activities in the lowest
regions.

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3.5.2 BUSINESS OPERATION ENVIRONMENT
This data helps to determine the impact of the e-levy policy on the type of business
environment and categories of business activities within these environments.
The data depicts majority of agents are from the rural areas which is 400 and representing
43%. Whilst Rural-Urban areas accommodates the least number of agents as 228 representing
25%.
3.5.3 NUMBER OF OUTLETS
Majority of respondents of 472 representing 51% operate one outlet. Only 17 respondents
representing 9% operate more than 5 outlets.

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3.5.4 TOTAL NUMBER OF TRANSACTION
Out of the 927 respondents, 681 representing 73.5% indicated that, their total number of
transactions has reduced since the introduction of the e-levy. This response supports the
observed complaints on agents’ groups and media complaints. However, 149 respondents
representing 17 %have had their total number of transactions increased and 97 respondents
representing 10.50% have recorded no impact of the e-levy on their total transactions.
3.5.5 IMPACT ON CASH IN COMMISSION
740 respondents representing 80% recorded a decrease in cash in commission for the said
period, while only 82 respondents representing 9% recorded an increase in cash in
commission. Thus, some 105 respondents representing 11% had recorded a no impact on their
cash in commission.

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3.5.6 IMPACT ON CASH-OUT COMMISSION
A total of 638 respondents representing 69% recorded a decrease in cash out commission as
against 166 respondents representing 18% who indicated an increase. Some 123 respondents
representing 13% did not record a change in cash-out commission.
3.5.7 IMPACT ON EMPLOYMENTS AND OUTLETS/SHOPS
While 513 respondents representing 55% have laid off an average of 3 workers,
414 respondents representing 45% have their labour turnover unchanged. Similarly, 249
respondents representing 27% have employed between 1 to more than 3 workers during this
period as against 678 respondents representing 73% having no impact on employment.

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In addition, 417 respondents representing 45% have closed at least one outlet or shop and 510
representing 55% have recorded no impact on closed shops or outlets.
In contrast, only 158 respondents representing 17% have opened at least one new shops or
outlets and 769 representing 83% respondents have shown no impact on new shops opened
for the period considered.
3.5.8 IMPACT ON RETURN ON INVESTMENT
On the impact on investment, 759 representing 82% have recorded no impact on investment,
79 representing 9% have had their return on investment increased as against 89 representing
9% respondents having their return on investment reduced.

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3.5.9A EXPECTATIONS OF FUTURE IMPACT AND ACTION
To ascertain the expectations of agents regarding the e-levy, 640 representing 69% of
respondents expects the continuous implementation of the e-levy to reduce the use of mobile
money services and ultimately collapse the business in future. However, 287 representing
31% believes users of the mobile money services will understand and accept the e-levy with
time.
Consequently, 616 representing 66% of respondents expects the government to completely
repeal the e-levy in its current state while 311 representing 34% expects the government to
either review the tax rate or threshold and exemptions within the tax policy.
A record of 476 representing 51% of respondents have high understanding of the e-levy as
against 451 representing 49% having average or low understanding of the e-levy. This
indicates the need for further and advance education and consultations with agents regarding
the e-levy and other future similar fiscal policies by the government.

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3.5.9B UNDERSTANDING OF E-LEVY
Interestingly, 476 representing 51% of respondents described their understanding of the e-
levy as high, 305 representing 33% describe theirs as average. However, 146 representing
16% described their understanding as low.
4.0 CONCLUSION
From the above analysis and supporting data visualization below, one can say emphatically
that the introduction of the e-levy has had a significant negative impact on the mobile money
business. The 73%, 80% and 69% respondents have observed reduction in total number of
transactions, cash in commission and cash out commission respectively: the key profitability
measuring matrices, establishes this fact. Again, despite having 27% and 17% of respondents
hiring new workers and operating new shops, the net impact of the e-levy is negative on
employment and expansion of business. Thus, the 55% and 45% respondents have laid off
workers and closed existing shops due to the negative impact of the e-levy.

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4.1 RECOMMENDATIONS
As an association of agents and key stakeholders, based on this research we recommend a
further research and keen interest is shown towards periodic continues evaluating of the e-
levy on the mobile money eco-system. In addition, we strongly recommend government
should consider effective and efficient ways of mitigating the negative impact of the e-levy on
agents, through consultations with key stakeholders particularly the agents’ association. Such
discussions should prioritize the allocation of part of generated revenue towards the
renumeration of agents, in the form of commission for playing significant role in the e-levy
mobilization process.
However, as responsible association that believes in honoring our civic responsibility, we
further recommend a broad effective bottom-top consultative approach to efficiently mobilize
taxes that support economic growth and development by reviewing the existing e-levy.
Consequently, government should reduce the current rate, modify the exemptions of
transactions and the daily threshold to ease the negative impact on consumers. Finally,
government should adopt proactive ways of engaging key stakeholders when introducing new
policies.
These recommendations are supported by the 69% and 66% of respondents that believes the
e-levy in its current state will collapse the industry and expect the government to completely
repeal and review the current tax policy respectively.