Madagascar lending regulated under 2020 Banking Law; CSBF/BFM oversight of banks and MFIs
Lending and consumer credit activities in Madagascar are strictly regulated, with the primary legal framework established by Law No. 2020-011 on Banking Law, which defines credit institutions and operational rules. The Central Bank of Madagascar (BFM) and its supervisory arm, the CSBF, oversee commercial banks and microfinance institutions (MFIs) respectively, ensuring compliance with prudential standards.
MFIs must obtain specific authorization to operate and are subject to detailed governance, risk management, and reporting requirements, including participation in the central credit registry (Risk Central). The regulatory environment distinguishes between traditional banking services and microfinance operations, with the latter governed by additional specific orders and laws such as Law No. 2017-026.
Recent regulatory direction emphasizes financial stability and consumer protection, evidenced by strict refinancing eligibility criteria for MFIs and mandatory credit information sharing. The system requires explicit client consent for data usage and mandates robust provisioning for distressed loans to mitigate systemic risk.
Banky Foiben'i Madagasikara (BFM)
Central bank issuing banking laws, refinancing facilities, and credit bureau approvals
[1][2][3][4][5][6][7][8][9][10][11][12][13][14][15]Commission de Supervision Bancaire et Financière (CSBF)
Supervisory commission overseeing MFIs, approving licenses, and setting prudential rules
[16][17][18][19][20]Ministry of Economy and Finance
Issues orders on microfinance operational conditions and legal forms
[21][22]Law No. 2020-011 on Banking Law (2020)
Regulates banking services, defines credit institutions, and establishes comprehensive operational rules including public funding and credit provision.
[1]Law No. 2017-026 on Microfinance (2017)
Governs microfinance operations, requiring authorization for private associations and NGOs conducting regular microcredit activities.
[21]Law No. 2017-045 on Credit Information Bureaus (2017)
Establishes the framework for CIBs, mandating approval, data collection, and supervision to protect consumers and prevent debt overhang.
[13]Credit Institutions (Banks)
Authorization required under Law No. 2020-011; subject to BFM supervision and mandatory reserve requirements.
[1][9]Microfinance Institutions (MFIs)
Must be approved by CSBF; private associations/NGOs need authorization under Law No. 2017-026; must register with Trade and Companies Register.
[21][19][22]Credit Information Bureaus (CIBs)
Require BFM approval to operate; must meet legal, financial, and technical requirements.
[12][13]MFIs refinancing with peers must satisfy strict eligibility criteria and procedural requirements under Instruction No. 001/2024-CSBF.
[16]Supervised entities must obtain free, informed, and explicit client consent before collecting, sharing, or using personal and credit data.
[11]MFIs must implement defined governance bodies including general assemblies, boards of directors, and executive management.
[20]Mandatory rules exist for classifying, provisioning, and accounting for distressed loans within MFIs.
[18]Email alerts for Madagascar updates
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