The National Bank of Rwanda ( "the Central Bank"), on 17 September 2025, issued the new directive no. 4230/2025-00042 [613] governing persons authorized to transact in foreign currencies and the requirements for obtaining authorization to that effect ("the Directive"). The Directive is aimed at streamlining the enforcement of the regulation n° 42 /2022 of 13/04/2022 governing foreign exchange operations as amended ("the FX Regulation") which had prompted a mixed bag of reaction from various stakeholders.
This Directive reiterates the general rule that all monetary obligations or transactions entered or made in the Republic of Rwanda must be transacted in Rwandan franc ("FRW") as a sole legal tender in Rwanda. Unlike its predecessor (i.e. Directive no 0520/2023-00041 [613.1.4] of 22/02/2023), the Directive expands the list of the persons permitted to transaction in foreign currency without having to obtain prior authorisation from the Central Bank (referred to under the Directive as "deemed authorised dealers").
The list includes the following persons:
i. real estate companies that hold a valid investment certificate
and are approved by the Rwanda Development Board to transact in
foreign currency;
ii. tourism entities and travel agencies that hold a valid tourism
operating license from the Rwanda Development Board;
iii. entities registered or licensed by a competent authority and
operating under the Kigali International Financial Centre regime,
as recommended by Rwanda Finance Limited;
iv. Kigali International Arbitration Centre;
v. mining operators dealing in minerals trading;
vi. aviation and related logistics service providers;
vii. air ticketing agencies;
viii. land and water cross border transport and related
logistics;
ix. duty-free shops;
x. casinos;
xi. international schools, universities and higher learning
institutions;
xii. suppliers or service providers to diplomatic missions,
including embassies, consulates, UN missions, and international
(similar) organisations accredited to Rwanda;
xiii. expatriates authorised to work in Rwanda, or any person
employed or providing service to an entity that uses foreign
currency sourced from outside Rwanda; and
xiv. suppliers or service providers of expatriates and persons who
receive or get income in foreign currency sourced from outside
Rwanda.
The list does not include other persons, who were otherwise expected to be included, such as independent power producers ("IPPs") whose contracts with the national utility and other off-takers are (for the obvious reasons) generally denominated in foreign currencies. It is however believed, these players may be able to obtain authorisation from the Central Bank on case by case basis.
The Directive specifies that authorised dealers (whether deemed or not) shall not require a person dealing with them to pay in foreign currency, and such person is free to pay the FRW equivalent of the price/consideration in foreign currency. The Directive states that in such case, the average exchange rate of the Central Bank shall apply.
Under the Directive, the persons not listed as deemed authorised dealers may apply (to the Central Bank) for the authorisation to transact in foreign currency. The Central Bank shall have the maximum period of 25 working days (which may be extended by another 10 working days) to decide on such application failing which the application will be deemed to have been accepted.
The Directive also imposes record keeping obligations whereby the persons authorised to transact in foreign currencies whether as deemed authorised dealers or after obtaining the authorisation of the Central Bank to that effect are required to keep records pertaining to their transactions for a period of 10 years.
A moratorium of six (6) months has (under the Directive) been provided for the persons with ongoing contracts denominated in foreign currencies to comply with the Directive either by applying for the authorisation to transact in foreign currency or amending such contracts.
In a word, businesses transacting or intending to transact in foreign currencies should first confirm whether they are deemed authorised dealers under the Directive. If they are not, they may consider applying (to the Central Bank) for authorisation to transact in foreign currencies. Those listed, but whose status of "deemed authorised dealers" is subject to the approval and/or recommendations of other institutions, they need to secure such approvals and/or recommendations to start and/or continue transacting in foreign currencies. Equally important, businesses currently having contracts denominated in foreign currencies, but not listed as deemed authorised dealers, must either amend such contracts within six months or promptly apply for authorisation to transact in foreign currency, and specifically, to maintain their contracts in foreign currency.
* Reviewed by Dieudonné Nzafashwanayo, Partner in Rwanda
The content of this article is intended to provide a general guide to the subject matter. Specialist advice should be sought about your specific circumstances.
