Mozambique fintech regulation: BoM oversight under LICSF 2020; VASP registration mandatory
The Bank of Mozambique serves as the primary regulator for fintech and payment services, operating under the comprehensive framework of Law No. 20/2020 and its 2024 Regulation. This regime mandates licensing for credit institutions, financial companies, and electronic money institutions, with strict capital and governance requirements.
Virtual Asset Service Providers (VASPs) are explicitly regulated through a mandatory registration process established by Notice No. 4/GBM/2023, requiring all entities conducting virtual asset exchanges or custody to register with the central bank. The regulatory environment is further defined by specific notices governing instant payments (SPIM), e-money transaction limits, and non-banking agents.
Recent regulatory direction emphasizes the modernization of payment infrastructure, including the establishment of the Mozambique Instant Payment System (SPIM) and the alignment of clearing systems with international standards. The regulator actively enforces compliance through revocation of authorizations for non-compliant entities and the imposition of strict reporting and transaction limits.
Bank of Mozambique (Banco de Moçambique)
Primary supervisor for credit institutions, financial companies, electronic money institutions, payment service providers, and VASPs.
[1][2][3][4][5][6][7][8][9][10][11][12][13][14][15][16][17][18][19][20][21][22][23][24][25][26][27][28][29][30][31][32][33][34][35][36][37]Law No. 20/2020 on Credit Institutions and Financial Companies (LICSF) (2020)
Establishes the comprehensive legal framework for the establishment, supervision, and resolution of credit institutions and financial companies, strengthening licensing and corporate governance.
[19]Decree No. 50/2024 (2024)
Approves the Regulation of the LICSF, detailing procedures for authorization, registration, qualified participations, and branch management.
[6]Law No. 28/2022 (Exchange Control Law) (2022)
Governs exchange control rules, with its regulation (Decree No. 56/2023) defining procedures for partial foreign exchange trade by payment service providers.
[13]Credit Institutions and Financial Companies
Requires prior authorization from the Bank of Mozambique under the LICSF and its 2024 Regulation, with specific procedures for establishment and qualified participations. Capital: 5% (referenced in Decree No. 50/2024 summary, likely referring to a specific ratio or requirement, but exact floor amount not explicitly stated in provided text)
[6][19]Electronic Money Institutions
Subject to licensing and strict transactional limits to strengthen AML/CFT compliance, including customer risk classification.
[7][27]Virtual Asset Service Providers (VASPs)
Mandatory registration required for entities conducting virtual asset exchanges, transfers, custody, or related activities.
[14]Non-Banking Agents
Eligible entities must meet specific investment, licensing, and suitability criteria to operate as agents for payment service companies.
[15]Unified annual limit of six million meticais for foreign payments made through bank cards by residents and non-residents.
[5]Mandatory segregation of customer funds received in exchange for electronic money into fiduciary accounts at licensed credit banks.
[27]Mandatory biometric customer identification and specific frameworks for remote, minor, and entity accounts.
[8]All credit institutions, financial societies, and authorized payment service providers must connect to the National Single Electronic Payments Network (SIMO-rede).
[32][31]Regulatory focus is on modernizing payment infrastructure with the launch of the Mozambique Instant Payment System (SPIM) and aligning clearing systems with international best practices.
[3][9][10]The regulator continues to enforce strict compliance, evidenced by the revocation of authorizations for non-compliant entities and the establishment of detailed reporting requirements.
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