Madagascar: lending & credit regulation

Regulated

Madagascar lending regulated under 2020 Banking Law; CSBF/BFM oversight of banks and MFIs

Lead regulator:
Banky Foiben'i Madagasikara (BFM) / Commission de Supervision Bancaire et Financière (CSBF)
Key law:
Law No. 2020-011 on Banking Law
Last updated:
2026-07-12

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.

Who regulates

  • 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]

Core laws & rules

  • 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]

Licensing & registration

  • 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]

Restrictions & warnings

  • 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]

Direction of travel

  • Regulators are actively updating refinancing frameworks and risk central reporting to enhance financial stability and credit access.

    [16][17]
  • The regulatory focus remains on protecting consumers through data privacy rules and ensuring robust credit information systems.

    [11][13]

Sources

  1. Law No. 2020-011 on Banking Law · 2021-03-11
  2. Instruction No. 001-DDI/2021 Setting the Procedures for the Approval of Tariff Grids for Credit Information Bureaus (CIBs) · 2021-03-05
  3. Instruction No. 0003-DDI/2018 Amending Certain Provisions of Instruction No. 001-DCR/2010 of 08/11/10 on the Procedures for Declaring, Processing, and Exploiting Information Regarding Payment Incidents on Cheques · 2020-12-29
  4. Instruction No. 008-DOM/20 of 04 November 2020 on the Establishment of an Exceptional Refinancing Instrument Dedicated to Gold Sector Operators · 2020-11-04
  5. Instruction No. 006-DOM/20 of September 18, 2020 on the establishment of an exceptional refinancing instrument to support the activities of Microfinance Institutions (MFIs) · 2020-09-18
  6. Instruction No. 005-DOM/20 of September 18, 2020 on the establishment of an exceptional refinancing instrument to support the activities of certain enterprises · 2020-09-18
  7. Instruction No. 004-DOM/20 amending certain provisions of Instruction No. 003-DOM/20 on an exceptional refinancing instrument to support MSME activities · 2020-07-21
  8. Instruction No. 003-DOM/20 annulling and replacing the provisions of Instruction No. 002-DOM/20 of April 10, 2020 on the establishment of an exceptional refinancing instrument to support SME activities · 2020-05-28
  9. Instruction No. 001-DOM/20 on Specific Provisions Applicable to Banks Regarding the Mandatory Reserve System · 2020-04-16
  10. Instruction No. 002-DOM/20 on the Establishment of an Exceptional Refinancing Instrument to Support MPME Activities · 2020-04-16
  11. Instruction No. 001-DDI/2020 amending and supplementing certain provisions of Instruction No. 001-DDI/2019 of October 2, 2019 implementing Law No. 2017-045 of February 15, 2018 governing Credit Information Bureaus · 2020-02-28
  12. Decision No. 001/2018-DDI Approving CRIF Madagascar as a Credit Information Bureau · 2018-12-04
  13. Law No. 2017-045 Governing the Activity and Supervision of Credit Information Bureaus · 2018-02-15
  14. Instruction No. 001-DDI/2016 on the Risk Central · 2016-11-24
  15. Ordinance No 73-008 of March 13, 1973 on the Global Mobilization of Bank Credits · 1973-03-13
  16. Instruction No. 001/2024-CSBF on the Refinancing Conditions for Microfinance Institutions · 2025-02-26
  17. Instruction No. 002-DDI/2021 Amending Certain Provisions of Instruction No. 001-DDI/2016 of November 24, 2016 on the Risk Central · 2021-10-01
  18. Instruction No. 002/2019-CSBF on Distressed Loans of Microfinance Institutions · 2019-09-06
  19. Decision No. 002/2019-CSBF Approving Caisse d'Epargne de Madagascar as a Deposit and Credit Microfinance Institution · 2019-03-01
  20. Instruction No. 007/2007-CSBF of December 7, 2007 Establishing the Operating and Control Structures of Microfinance Institutions · 2007-12-07
  21. Order No. 9777-2019 on the Conditions for Exercise and Supervision of Microfinance Operations under Article 2.3 of Law No. 2017-026 on Microfinance · 2019-05-13
  22. Decree No. 2007-012 Establishing the Legal Forms of Microfinance Institutions and Their Registration Procedures with the Trade and Companies Register · 2007-01-09

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This guide is compiled automatically from 22 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.