Directive on Digital Credit, Account Opening, and Savings

The Governor DIRECTIVE No 43/2025 OF 08/12/2025 ON DIGITAL CREDIT, DIGITAL ACCOUNT OPENING, AND DIGITAL SAVINGS

1 THE NATIONAL BANK OF RWANDA: Pursuant to Law n o 48/2017 of 23/09/2017 governing the National Bank of Rwanda as amended to date, especially in Article 6, 6 bis, 8, and 15; Pursuant to Law n o 017/2021 of 03/03/2021 relating to Financial Service Consumer Protection, especially in Articles 36, 37 and 38; Pursuant to Regulation n o 27/2019 of 09/09/2019 Relating to Credit Reporting System, especially in Article 31; Pursuant to Regulation n o 55/2022 of 27/10/2022 Relating to Financial Service Consumer Protection, especially in Articles, 18, 28 and 29; ISSUES THE FOLLOWING DIRECTIVES: CHAPTER ONE: GENERAL PROVISIONS Article One: Purpose of the Directive This Directive – (a) establishes a regulatory framework governing digital account opening, digital credit, and digital savings services offered by financial service providers, with the objective of promoting safe, transparent, and responsible financial practices; (b) safeguards financial service consumers, promotes fair market conduct, and mitigates risks inherent in digital account opening, credit, and savings services, including risks related to data misuse, over-indebtedness, and inadequate disclosure of material credit terms, thereby reinforcing the Central Bank’s commitment to financial inclusion, financial integrity, and the stability of the financial sector; and (c) serves as a regulatory benchmark for institutional policies, internal procedures, and control mechanisms governing the design, marketing, issuance, and ongoing administration of digital financial services, including digital account opening, digital credit, and digital savings products and services. Article 2: Interpretation In this Directive: (a) “Central Bank” means the National Bank of Rwanda; (b) “Credit Reporting Service Provider” means a legal entity that administers a Credit Reporting System as a Credit Registry or Credit Bureau; (c) “Digital Account Opening” means the process of creating and activating a new account such as a bank account, investment account, or mobile wallet through

2 online or electronic channels without the need for physical paperwork or in person interaction. (d) “Digital Credit/Loan” means the process of extending credit through digital channels, including mobile applications, websites, or USSD platforms, with minimal or no physical interaction between lender and borrower; (e) “Digital Platform” means a technology-based interface, system, or infrastructure used to deliver financial products or services digitally specifically digital account opening, credit and saving; (f) “Digital Saving” means the process of setting aside money using electronic or online platforms, rather than traditional physical methods. It typically involves the use of digital platforms, including mobile banking apps, digital wallets, USSD and online saving accounts; (g) “Financial Service Consumer (the consumer)” means an individual, group of individuals or enterprise that enters, or may enter, into a business relationship or a contract with a financial service provider for the purpose of acquiring or providing a financial product/service; (h) “Financial Service Providers (FSPs)” means an individual or legal entity who carries on the business of providing financial product/service; (i) “FinTech Provider” means a company or organization that delivers financial services or products using technology. FinTech providers typically leverage software, mobile applications, artificial intelligence, big data, blockchain, or cloud computing to offer innovative financial solutions. Article 3: Scope of Application This Directive applies to: (a) financial service providers engaged in the provision and facilitation of digital account opening, digital credit and digital savings services. (b) digital financial services’ lifecycle, including application, approvals, consumer redress, disclosures and disbursement, interest rate, interest computation, fees and charges, access to digital contract, Key Fact Statement and payment of loan and interest on digital credit and saving specifically; and (c) the use of digital channels, algorithms, and platforms in delivering credit products. Article 4: Structure of the Platform (1) The structure of the platform must be user-friendly. The platform allows the user to first read the terms and conditions of the product or service and consent to have read them before proceeding with formal application.

3 (2) Upon completion of the application, the platform displays a complete summary of the applicant’s request for confirmation prior to submission. The platform further enables the applicant to track the status of the application and receive notifications indicating whether the request has been approved or rejected, including the reasons for such decision. Where the request is approved, the platform communicates the agreed terms in a durable format, constituting a binding contract between the parties. (3) The platform clearly displays key contact details for use by the consumers when making enquiries or seeking support, including telephone numbers, email addresses, and other relevant contact channels. (4) The platform allows transaction notification and extracting account statements. (5) The platform must be able to be integrated with other systems to allow the screening of the consumers based on real data, including credit reporting systems, National ID, transaction data providers and other databases. (6) The platform clearly and prominently displays the name of the financial service provider offering the product or service. (7) The design of the digital platform used by financial service providers is submitted to the Central Bank for information upon public rollout. The Central Bank reserves the right to assess the efficiency and appropriateness of the platform and may request amendments or suspend its operation in cases where it does not meet the minimum requirements of this Directive. CHAPTER II: REGULATORY CONDITIONS FOR DIGITAL ACCOUNT OPENING Article 5: Digital account application and onboarding procedures (1) The digital account application process is guided by pre-disclosed terms and conditions. (2) Key Facts Statements, and account types with summarized account opening conditions are displayed in the platform before the accounting opening process for the applicant to consent before proceeding with formal application in the platform. (3) The terms and conditions include the following: (a) types of accounts that can be opened; (b) interests rates associated to those accounts and conditions, if any; (c) fees and charges associated to those accounts; (d) conditions for account using; (e) conditions in case the accounts becomes inactive; (f) conditions for closing the accounts;

4 (g) products associated to those accounts (internet banking, mobile banking, cards, linkage with mobile money, etc.); (h) sanctions and rewards associated to those accounts; (i) security tips on using those accounts, etc. (4) For USSD users, where all the above information cannot be displayed, at a minimum the type of account, associated fees, and applicable interest rates are given via SMS. (5) Digital account opening complies with the existing Know Your Customer (KYC) standards as traditional onboarding. This includes real-time identity verification using national ID systems, biometric authentication (e.g., facial recognition), and document scanning where applicable, for AML/CFT purposes. (6) All consumers must have access to responsive consumer support channels during the onboarding process. This may include live chat, help lines, or virtual assistants. (7) After filling in the KYC, the platform displays information on the application for the applicant to confirm before submission. (8) Instead of requesting data during the consumer on-boarding process, the platform gets some data directly from the integrated systems such as National Identification Agency, Credit Reference Bureaus and other databases. Article 6: Digital Account Confirmation Upon completion of the application process, the consumer is notified through SMS, email, or any other appropriate communication channel of the type of account opened, the account number and name, and is provided with the applicable terms and conditions, together with security guidance for the use of the account. CHAPTER III: REGULATORY CONDITIONS FOR DIGITAL CREDIT SERVICES Article 7: Guiding principles for digital credit provision (1) Digital credit is offered in a manner that upholds transparency, consumer protection, financial inclusion, and data privacy. (2) The FSPs ensure that digital credit products are responsibly designed and delivered using secure, user-centric digital platforms. Article 8: Digital Credit Platforms A rolled-out platform must: (a) integrate with credit reporting systems to assess borrower credit history and data;

5 (b) employ automated systems to evaluate income-to-debt ratios and borrower creditworthiness using verifiable data. Article 9: Publication and Accessibility of Digital Credit Terms and Conditions (1) The FSPs publish the general terms and conditions of all digital credit products on their websites and within the digital application platforms. (2) The prospective borrowers must confirm having read and understood these terms and conditions before submitting any loan application. (3) General terms and conditions include the following: (a) available loan types and limits; (b) interest rate ranges and methods of calculation; (c) fees and charges applicable to the loan, including service and penalty fees; (d) repayment periods and frequency; (e) repayment modalities and insurance charges (if any); (f) early repayment provisions; (g) identification of the lender, and contact information; (h) complaints redress mechanism.; (i) consequences of default; (j) eligibility, application, approval, and disbursement procedures. (4) For USSD users, where all the above information cannot be displayed, at a minimum the loan type loan amount, interest rate, other fees, interest amount, loan period and penalty in case of default is provided through SMS. Article 10: Credit application and onboarding procedures (1) The application process is guided by the pre-disclosed terms and conditions. (2) Prior to submission of a loan application, the digital platform clearly displays the following for borrower confirmation: (a) loan amount applied for; (b) interest rate to be charged and method of computation; (c) applicable fees and their computation methods;

6 (d) annual percentage rate (APR); (e) repayment period and frequency; (f) instalment breakdown, including principal, interest, and fees; (g) total repayment amount; (h) available repayment methods. (3) For USSD users, where all the above information cannot be displayed, at a minimum the type of loan amount, interest rate, other fees, interest amount, loan period and penalty in case of default is provided. Article 11: Approval of mechanism and disbursement protocols (1) Applicants are notified promptly upon the approval or rejection of their loan applications. In cases of rejection, the reasons are clearly stated. (2) A digital interface is made available to the applicant to monitor the status of the loan request in real time. (3) Upon approval, an electronic loan contract and repayment schedule are sent to the borrower via SMS, email, or both. (4) The electronic contract include the following information: (a) full identification of the lender and borrower; (b) approval and disbursement dates; (c) approved loan amount; (d) interest rate and computation method; (e) applicable fees and penalties; (f) repayment period and frequency; (g) instalment breakdown; (h) repayment and deduction modalities; (i) CRB reporting provisions; (j) rights and obligations of both parties; (k) dispute resolution procedures.

7 Article 12: Repayment schedules and recovery processes (1) Digital lenders provide a repayment schedule immediately following loan approval. (2) The schedule must: (a) distinguish clearly between principal and interest in each instalment; (b) indicate the total repayment amount; (c) indicate a repayment period; (d) indicate the total interests to be paid; (e) indicate the interest computation method; (f) be provided to the borrower via SMS, email, or downloadable document; (g) be updated and re-issued in the event of changes to loan terms. Article 13: Due diligence on credit financial service provider (1) The identity of the credit institution is clearly disclosed in the terms and conditions, Key Facts Statements and any communications relating to the loan. (2) Where third parties who will be interacting with the consumers are involved in the loan recovery process, complaints or queries management, their contact details and responsibilities are also specified in the contract. Article 14: Determination and disclosure of interest rates and charges (1) Financial service providers determine interest rates and related charges through a transparent and risk-based pricing framework that reflects the credit profile of the borrower, and the nature of the product offered. All cost components including interest, fees, and penalties are clearly defined, consistently applied, and disclosed to the consumer prior to loan disbursement. (2) The disclosed interests, fees and charges are the ones to be applied. In case of change, it will need the consent of the borrower. (3) The Central Bank reserves the right to suspend, restrict, or prohibit any digital loan product or pricing structure that is deemed excessive, deceptive, or detrimental to consumer welfare or the stability of the financial system. (4) (4) The interest rates are clearly indicated and separated from other associated fees on digital loans, and no interest rate is disguised or labelled as a facility fee or by any other name. Accordingly, FSPs are prohibited to mislead or purport to mislead a consumer into believing that a loan product is free of interest.

8 (5) Daily or monthly interest rates are annualized and disclosed during the application process, as well as in terms and conditions. (6) The digital loan pricing model is submitted to the Central Bank for information upon Board approval and upon any material change. Article 15: Creditworthiness assessment and risk-based pricing (1) Digital credits are only granted if the lender has taken reasonable steps to confirm the borrower’s ability to repay. (2) Platforms must: (a) collect detailed borrower profiles including age, occupation, and income; (b) calculate income-to-debt ratios in real time; (c) integrate with CRBs to assess and update credit scores; (d) provide explanations for loan decisions; (e) reassess borrower profiles periodically for credit limit adjustments. Article 16: Submission of credit information to the Credit Bureau CRB updates are made within 48 hours of repayment. Article 17: Transparency in tariff publications and service charters (1) All digital credit tariffs, including interest rates, fees, repayment terms, and loan durations, are publicly disclosed. (2) The estimated delivery timelines for digital loan products are included in the financial service provider’s service charter. Article 18: Provisions for early settlement of credit facilities Platforms enable daily interest computation and allow borrowers to settle loans early by paying interest accrued only up to the date of repayment. Article 19: Amendment and variation of contractual terms (1) A financial service provider does not amend contract terms, including charges or credit limits, without the express prior consent of the borrower. (2) Any changes are communicated to the consumers in advance prior to implementation. Article 20: Prohibited practices in digital credit Digital lenders are not allowed to –

9 (a) engage recovery agents without prior borrower notification; (b) access a borrower’s phonebook without consent; (c) assign loans to third parties without prior notice to the borrower; (d) transact in any currency other than the Rwandan Franc. CHAPTER IV: CONDITIONS FOR DIGITAL SAVINGS PRODUCTS Article 21: Digital savings conditions (1) The savings application process is conducted in accordance with the pre-disclosed terms and conditions. (2) Before submitting a savings application, the digital platform clearly displays the following information for depositor review and confirmation: (a) available saving terms in summary; (b) saving period, amount and associated interest rate; (c) breakdown of expected returns, including projected interest or bonuses; (d) the total expected amount at maturity (if fixed-term savings); (e) any penalty for early withdrawal; (3) Available methods for making deposits and withdrawals. (4) The exit modalities are clearly defined and transparently communicated. Article 22: Digital savings application process (1) The platform shows the terms and conditions of the savings’ products for the consumer to consent before proceeding with formal application. (2) After filling in the application information, the platform displays what was applied for before submission. (3) After submission of the application, the applicant gets the online contract containing amount saved, interest, remuneration schedule, tenor, etc. Article 23: Interest rate determination and review (1) The FSPs, offering digital savings products, disclose the applicable interest rate whether fixed or variable at the time of account opening, in accordance with the agreed terms.

10 (2) The FSPs also clearly communicate to the consumer, prior to the acceptance of the savings terms, whether the interest rate is expressed on an annualized basis. (3) The methodology used to determine and revise interest rates must be fair, consistent, and subject to internal governance controls. FSPs retain documentation supporting such determinations and make them available to the Central Bank upon request. Article 24: Method of interest calculation (1) Interest in digital savings is computed in a transparent and consistent manner. The applicable method and frequency of interest computation either daily, monthly, quarterly or annually is clearly stated in the product terms and conditions. (2) The formula used for interest calculation is standardized, documented, and disclosed to the consumer. Where applicable, the interest-bearing balance threshold is specified, including any minimum balance requirements for interest accrual. (3) The FSPs ensure that interest is calculated on clear and available balances only, and that the computation methodology does not result in discriminatory or misleading practices. (4) The Central Bank reserves the right to review and approve computation models to ensure consistency with consumer protection principles. Article 25: Interest in crediting procedures (1) The FSPs credit accrued interest to the consumers’ savings accounts or designated digital wallets at a frequency clearly disclosed in the product terms. (2) Unless otherwise agreed with the consumer, interest is credited to the same account as the principal savings are held. Where interest is credited to a separate account or wallet, the FSPs ensure clear and prior disclosure of such arrangement. (3) Interest is credited within a specified timeline, exactly at maturity date. FSPs implement appropriate internal controls to ensure accuracy, timeliness, and transparency in the crediting process. Article 26: Access to real-time account information (1) The FSPs offering digital savings products ensure that the consumers have unrestricted access to their account information in real-time through secure digital platforms. (2) Account statements display, at a minimum, daily balance movements, interest accrued and credited, and a detailed transaction history, in a format that is clear, accurate, and user-friendly. (3) The provision of real-time account visibility must be consistent with applicable data protection and cybersecurity standards and form part of the financial service provider’s transparency and consumer protection obligations under this Directive.

11 Article 27: Conditions for early withdrawal and associated charges (1) FSPs clearly disclose, at the time of account opening and in relevant documentation, any penalties, fees, or restrictions applicable to early withdrawal of digital savings. Such conditions are communicated in plain and understandable language; (2) Where early withdrawal results in the forfeiture or prorating of interest accrued, the method of computation and its implications on the depositor’s entitlement must be transparently disclosed in advance and applied consistently; (3) The FSP does not impose charges or penalties on early withdrawal unless such charges are duly approved, reasonable, and explicitly communicated to the consumer prior to account activation or product enrolment; (4) The penalty for early withdrawal is applied to the accrued interest, not the principal. CHAPTER V: MARKET CONDUCT AND CONSUMER PROTECTION Article 28: Financial service consumer education and financial literacy obligations (1) The FSPs ensure that the consumers are equipped with clear, accessible, and timely information to make informed financial decisions. This includes simplified explanations of how digital savings and credit products operate, including terms, conditions, risks, and benefits. (2) The FSP develop and disseminate financial education materials through their platforms and other appropriate channels. (3) The design and delivery of consumer education initiatives must be inclusive, considering diverse literacy levels, digital access, and language preferences. Article 29: Disclosure, notification, and consumer consent mechanisms (1) The FSPs provide the consumers with timely and clear notifications of any changes to interest rates, fees, or terms and conditions related to digital credit or savings products. Such changes are communicated at least 15 calendar days prior to their effective date. (2) Notifications are delivered through secure and accessible channels, including SMS, email, or mobile application alerts, in line with the consumer’s preferred mode of communication. Monthly interest in earnings on savings is also communicated through the same channels at the time of crediting. (3) Where applicable, FSPs obtain prior and informed consent from the consumers before implementing any material changes to contractual terms. Records of such notifications and consent must be maintained in accordance with regulatory requirements.

12 (4) Where a product is offered in partnership with a FinTech provider, the FSP remains fully responsible and liable for the FinTech provider’s actions. The FSP must clearly disclose, in the terms and conditions, the identity of engaged FinTech providers and the activities they perform and remain solely responsible for handling all related consumer complaints. CHAPTER VI: FINAL PROVISIONS Article 30: Administrative Faults and Sanctions In line with the provisions of Regulation N° 55/2022 relating to the consumer protection, the Central Bank imposes on the financial service provider any of the following sanctions for non-compliance with the provisions of this Directive or decisions depending on the seriousness and gravity of the violation: (a) Written warning; (b) Suspension from operations (c) Pecuniary sanction as per annex I of this Directive (d) Suspension or withdrawal order for financial product/service or advert materials. Article 31: Compliance with this Directive Existing FSPs offering digital credit and savings services prior to the issuance of this Directive, have a period of 12 months from signing date, to align their operations, systems, and procedures with the requirements of this Directive. Article 32: Repealing Provision Any prior provisions of a Directive contrary to this Directive is repealed. Article 33: Entry into Force This Directive enters into force on the date of its signature. Done at Kigali, December 17, 2025 Nick BARIGYE Deputy Governor and Acting Governor

13 APPENDIX I: VIOLATIONS AND THEIR CORRESPONDING PECUNIARY SANCTIONS S/N Violation Penalty (FRW) Banks Microfinance Institution Deposit taking cooperative, Non-Deposit Taking Institutions (1). Failure to comply with the language requirements for the platform and digital documents. 500,000 200,000 50,000 (2). Failure to assess the debt-to-income ratio during the digital loan approval process. 500,000 200,000 50,000 (3). Failure to provide digital contract. 500,000 200,000 50,000 (4). Failure to provide digital KFS. 300,000 150,000 50,000 (5). Failure to provide Digital Repayment Plan. 300,000 150,000 50,000 (6). Failure to inform the the consumer of the outcome of their request, whether accepted or rejected. 300,000 150,000 50,000 (7). Failure to conduct periodic re-assessments of the consumer’s profiles to adjust credit limits accordingly. 300,000 150,000 50,000 (8). Failure to update the consumer’s Credit Reference Bureau report within the prescribed timeframe. 300,000 and 20,000 per day delayed 150,000 and 10,000 per day delayed 50,000 and 5,000 per day delayed (9). Failure to inform the consumer, upon registration or after any change in their CRB status. 300,000 150,000 50,000

14 (10). Failure of the platform to enable daily interest computation and to allow consumers to repay loans early by paying interest accrued only up to the date of repayment. 500,000 200,000 50,000 (11). Failure to promptly credit interest accrued on savings 300,000 and 20,000 per day delayed.

150,000 and 10,000 per day delayed. 50,000 and 5,000 per day delayed. (12). Imposing penalties on early withdrawals based on the principal amount rather than the interest accrued. 500,000 200,000 50,000 (13). Violation of any other provision of this Directive, whether by action or omission. 300,000 for each violation 200,000 for each for each violation. 50,000 for each for each violation. Seen to be annexed to Directive no 43/2025 of 08/12/2025 on Digital Credit, Digital Account Opening, and Digital Savings Done at Kigali, December 17, 2025 Nick BARIGYE Deputy Governor and Acting Governor