LogoRegulatory Alerts

Madagascar: fintech & payments regulation

Regulated

Madagascar fintech regulated under 2016 EMI Law; CSBF/BFM dual oversight

Lead regulator:
Banky Foiben'i Madagasikara (BFM) / Commission de Supervision Bancaire et Financière (CSBF)
Key law:
Law No. 2016-056 on Electronic Money and Electronic Money Institutions
Last updated:
2026-07-12

Madagascar maintains a regulated fintech and payments sector governed primarily by Law No. 2016-056, which establishes a comprehensive legal framework for electronic money and the institutions that issue it. The Banking and Financial Supervision Commission (CSBF), operating under the Central Bank (BFM), is the primary supervisor responsible for licensing and prudential oversight of Electronic Money Institutions (EMIs), credit institutions, and microfinance entities.

To operate as an EMI, entities must obtain specific approval from the CSBF and maintain a minimum paid-up capital of 500 million Ariary. The regulatory framework mandates strict governance standards, including the maintenance of global safeguard accounts with authorized depositary banks to protect customer funds. Recent regulatory updates have focused on operational efficiency, including the launch of an Instant Payment System and the modernization of clearing and settlement infrastructures.

The sector is further supported by Law No. 2020-011 for banking services and Law No. 2017-026 for microfinance, creating a tiered supervisory environment. While the legal basis for electronic transactions and digital signatures is established under Law No. 2014-024, the operational landscape is defined by the CSBF's detailed instructions on licensing, agent networks, and anti-money laundering due diligence.

Who regulates

  • Banky Foiben'i Madagasikara (BFM)

    Central Bank and monetary authority; issues instructions on payment systems and clearing.

    [1][2]

  • Commission de Supervision Bancaire et Financière (CSBF)

    Prudential supervisor; grants licenses and approves EMIs, banks, and microfinance institutions.

    [1][3][4]

Core laws & rules

  • Law No. 2016-056 (2016)

    Establishes the legal framework for electronic money, defining it as a cash-equivalent claim and mandating licensing for institutions issuing it.

    [1][5]

  • Law No. 2020-011 (2020)

    Comprehensive operating and supervisory framework for banking services and credit institutions.

    [6][7]

  • Law No. 2017-026 (2017)

    Overhauls the microfinance sector, classifying institutions and modulating supervision according to risk levels.

    [8][9]

  • Law No. 2014-024 (2014)

    Establishes the legal framework for electronic transactions, contracts, and payments.

Licensing & registration

  • Electronic Money Institution (EMI)

    Requires CSBF approval, demonstration of financial/technical capacity, and maintenance of global safeguard accounts. Capital: 500,000,000 Ariary Timeline: Application fee of 15,000,000 Ariary; rigorous review process.

    [10][11][12]

  • Credit Institution / Bank

    Requires CSBF approval under a rigorous six-month review process demonstrating promoter capability. Timeline: Six-month review process.

    [3]

  • Microfinance Institution (MFI)

    Classified into deposit-taking and credit-only categories; requires CSBF approval and adherence to tiered capital requirements. Timeline: Approval contingent on fulfilling suspensive conditions.

    [8][13]

Restrictions & warnings

  • EMIs must maintain global accounts with authorized depositary banks to safeguard funds; authorized credit institutions are limited in their ability to hold these accounts.

    [4][14]

  • Distribution agents appointed by EMIs must adhere to strict selection, supervision, and reporting obligations.

    [15]

Direction of travel

  • Regulators are actively modernizing payment infrastructure, evidenced by the 2024 launch of an Instant Payment System (IPS) mandating 24/7 real-time transfers.

    [2]

  • Supervisory focus remains on enhancing governance standards and ensuring the technical and financial robustness of licensed entities.

    [16][3]

Sources

  1. Law No. 2016-056 on Electronic Money and Electronic Money Institutions · 2026-01-06
  2. Instruction No. 001/2024-DSP of 1 October 2024 on the Operation of Madagascar's Instant Payment System · 2024-10-03
  3. Instruction No. 001-2025-CSBF on the Approval of Banks and Financial Institutions · 2025-04-25
  4. Instruction No. 001/2021-CSBF Amending Instruction No. 003/2017-CSBF of 29 September 2017 on the Global Account of Electronic Money Institutions · 2021-05-04
  5. Law No. 2016-056 on Electronic Money and Electronic Money Institutions · 2017-02-02
  6. Banking Law No. 2020-011 · 2026-01-06
  7. Law No. 2020-011 on Banking Law · 2021-03-11
  8. Law No. 2017-026 on Microfinance · 2026-01-06
  9. Law No. 2017-026 on Microfinance · 2018-02-16
  10. Decree No. 2017-851 Implementing Law No. 2016-056 of February 2, 2017 on Electronic Money and Electronic Money Institutions · 2017-09-26
  11. Order No. 16,658 of June 20, 2018 Fixing the Application Fees for Electronic Money Institutions · 2018-06-20
  12. Instruction No. 002/2017-CSBF on the Approval of Electronic Money Institutions · 2017-09-29
  13. Instruction No. 001/2019-CSBF on the Approval of Microfinance Institutions (MFIs) · 2019-10-17
  14. Instruction No. 003/2017-CSBF on the Global Account of Electronic Money Institutions · 2017-09-29
  15. Instruction No. 002/2018-CSBF on Electronic Money Distribution Agents · 2018-04-12
  16. Instruction No. 003/2018-CSBF on the Governance and Control of Electronic Money Institutions · 2018-04-12

Email alerts for Madagascar updates

New circulars, rules and guidance — a digest in your inbox, same day.

This guide is compiled automatically from 16 primary-source documents published by Madagascar's regulators, reviewed by RegAlert, and refreshed monthly (last updated 2026-07-12). It is not legal advice — always confirm requirements with the regulator or local counsel before acting.