Bank or mobile money: where should your takings settle?

A Ugandan business today is paid on at least three rails: cash over the counter, mobile money to a merchant code, and bank transfers from larger customers. The question is not which one to accept (you accept all of them) but where the money should rest at the end of the week, and how it gets there without leaking fees or losing its trail.

The rails, briefly

The Bank of Uganda's payment systems oversight framework describes the Uganda National Interbank Settlement System (UNISS), the real-time gross settlement system, as the core of the national payments infrastructure, used to settle other systems including the Automated Clearing House (ACH), a multilateral net settlement system for cheques and electronic funds transfers. Both are owned and operated by the central bank. Mobile money sits on top of this: the National Payment Systems Act came into force in September 2020, with implementing regulations gazetted on 5 March 2021, giving the Bank of Uganda the mandate to license and oversee payment service providers, including the electronic money issuers behind MoMo and Airtel Money. Those issuers must apply to open a trust account at a financial institution for customer funds.

The practical point: a bank account and a mobile money wallet are both regulated places to hold money. The difference is cost, speed and what records each produces.

What it costs to move between them

Moving money from wallet to bank has a published price. MTN's tariff lists sending to a bank at UGX 1,500 for amounts between UGX 2,501 and UGX 125,000, rising to UGX 11,300 for UGX 2,000,001 to UGX 5,000,000. Airtel's formal merchant FAQ says a standing order liquidation to a bank usually takes 24 to 48 hours to reflect. MTN's business wallet page describes bank transfers by USSD, with the phone number linked to the bank account.

Compare that with cashing out: for UGX 2,000,001 to UGX 4,000,000 the MTN agent fee is UGX 18,000 plus withdrawal duty of UGX 10,000 to UGX 20,000, against UGX 11,300 to send the same band to a bank with no duty. Wallet to bank is the cheaper and better documented route, and that is before counting the time spent at an agent.

Where each kind of money should rest

• Daily small payments can stay in the wallet and pay the costs that suit the wallet: airtime, small supplier top-ups, transport. Keep a ceiling, because a wallet balance is working capital you cannot see on a bank statement.
• Anything you will need to prove (rent, salaries, VAT, a supplier invoice above a few hundred thousand shillings) is better paid from the bank, where the statement names the payee and the reference.
• Cash should be banked, not held, and the direction of regulation supports that: the Bank of Uganda has set over-the-counter cash withdrawal limits of UGX 50 million a day for individuals and UGX 500 million for businesses from 1 January 2027, explicitly to push the economy towards digital payments.

A weekly settlement routine

1. On a fixed day, sweep each merchant wallet down to its ceiling by transfer to the business bank account. One transfer per wallet, with the week in the reference.
2. Bank the week's cash the same day, with a deposit slip per till.
3. Record each movement as a transfer between two accounts. It is not income (that was recorded at the sale) and not an expense (only the fee is).
4. When the bank statement arrives, tick each transfer and each deposit. Anything unticked after 48 hours is a query to raise, with the transaction ID.

Fees must be disclosed to you

Uganda's National Payment Systems (Consumer Protection) Regulations, 2022 require a licensee to disclose charges and fees, through a schedule of fees, material displayed at its offices, on social media or its website, and forbid charges that were not disclosed at sign-up unless thirty days' notice of an increase has been given. If a fee appears on your merchant statement that you cannot find on a published schedule, you are entitled to ask, and the regulations give the provider's channels a duty to answer.

The test of a good settlement routine

Open your books on any day and you should be able to say, for every shilling taken last week, where it is now: in the drawer, in a wallet, in the bank, or spent on a named thing. If the answer is "somewhere between the wallet and the bank", you have a settlement routine that needs a fixed day and a ceiling. That is all most businesses are missing.

Sources

1. https://bou.or.ug/uploads/Revised_BOU_National_Payment_Systems_Oversight_Framework_2025_698b3e9745.pdf
2. https://bou.or.ug/uploads/Frequently_asked_Questions_on_the_NPS_ACT_2020_and_the_NPS_Regulations_2021_5818aec7f5.pdf
3. https://www.mtn.co.ug/tariffs/mobile-money-tariffs/
4. https://www.mtn.co.ug/momo/merchant/
5. https://cdn-webportal.airtelstream.net/website/uganda/assets/pdf/Airtel-Money-Pay-Merchant-FAQs-2026.pdf
6. https://commons.laws.africa/akn/ug/act/si/2022/103/media/publication/ug-act-si-2022-103-publication-document.pdf
7. https://observer.ug/business/bou-caps-individual-cash-withdrawals/