Regulatory AlertsComoros: lending & credit regulation
Partially regulatedComoros: Banking-centric credit regulation; non-bank lending unregulated
- Lead regulator
- Banque Centrale des Comores (BCC)
- Also involved
- —
- Core law
- Law No. 12-011/AU on Leasing (2012)
- Entry capital
- —
- Approval timeline
- —
- Customer assets
- BCC-regulated credit institutions only
- Data protection
- —
- Sandbox
- No
The Comoros financial sector is tightly regulated, with the Banque Centrale des Comores (BCC) exercising exclusive authority over credit institutions. The regulatory framework focuses on traditional banking, leasing, and usury caps. There is no specific legislation governing non-bank consumer lending, P2P platforms, or fintech credit activities, leaving these sectors in a regulatory vacuum or implicitly prohibited as unauthorized banking activities.
Which licence do you need?
| Your activity | Requirement | Capital | Timeline | Authority |
|---|---|---|---|---|
| Consumer lending | Uncertainverify with regulator No specific regime; likely requires banking license | — | — | — |
| SME / commercial lending | Uncertainverify with regulator No specific regime; likely requires banking license | — | — | — |
| Microfinance | Uncertainverify with regulator No specific regime; likely requires banking license | — | — | — |
| Buy-now-pay-later | Uncertainverify with regulator No specific regime; likely requires banking license | — | — | — |
| P2P lending platform | Uncertainverify with regulator No specific regime; likely requires banking license | — | — | — |
| Credit bureau / scoring | Uncertain[1]verify with regulator CdRIP exists for institutions, not public bureaus | — | — | — |
| Debt collection | Uncertainverify with regulator No specific regime identified | — | — | — |
New — what changed recently
- 2025-01-01Regulation No. 2025/BCC/DESM-DRRB — Established and enforced an usury rate cap for all credit operations by credit institutions and other residents.[2]
- 2023-01-01Regulatory Decision No. 01-2023/BCC/DSBR — Established rules for calculating and disclosing the Effective Global Rate (TEG) for all credit operations.[3]
Market-entry checklist
- 1Verify banking license requirementConfirm if non-bank lending is prohibited under general banking laws without a BCC license.
- 2Check usury rate complianceEnsure any credit operations comply with the TEG cap set by Regulation 2025/BCC/DESM-DRRB.
- 3Review leasing regulationsIf offering asset-backed credit, adhere to Law No. 12-011/AU on leasing formalities.
- 4Assess credit registry obligationsDetermine if operations require joining the CdRIP registry if classified as credit institutions.
Sources
- Regulation No. 013/2015/BCC/DSBR on the Operation of the Credit and Payment Incident Central Registry · 2015-02-03
- Regulation No. 2025/BCC/DESM-DRRB on the Establishment of an Usury Rate for Credit Operations · 2025-01-20
- Regulatory Decision No. 01-2023/BCC/DSBR on the Implementation of the Effective Global Rate (TEG) for Credit Operations · 2023-04-01