FinTech Comparative Guide

1 Legal and enforcement framework

1.1 In broad terms, which legislative and regulatory provisions govern the fintech space in your jurisdiction?

There is no specific or harmonised body of laws or regulations applicable to all categories of fintechs in Cameroon. Nevertheless, a number of scattered instruments can be identified which:

• in certain cases, apply to fintechs operating within specific industry segments – primarily the payment sector and capital market sectors; and
• in other cases, extend more broadly to the banking and finance, insurance and telecommunications industries.

These laws and regulations notably include:

• Regulation 03/16/CEMAC-UMAC-CM on payment systems, methods and incidents;
• Regulation 04/18/CEMAC/UMAC/COBAC of 21 December 2018 on payment services in the Central African Economic and Monetary Community (CEMAC);
• Central African Banking Commission (COBAC) Regulation R-2019/01 of 23 December 2019 on the approval and modification of the status of payment service providers;
• COBAC Regulation R-2019/02 of 23 September 2019 on prudential standards applicable to payment institutions;
• Order 00000337/MINFI of 28 February 2024 setting out terms for the licensing and cessation of activities of electronic payment service providers in Cameroon;
• Regulation 22/CEMAC/UMAC/CM/COSUMAF of 22 July 2022 on the organisation and functioning of the Central African financial market; and
• General Regulation of the Financial Market Supervisory Commission (COSUMAF) of 23 May 2023.

1.2 Do any special regimes apply to specific areas of the fintech space?

Specific regimes apply to the following areas.

Payment services: These notably include:

• services enabling the deposit and withdrawal of cash into or from a bank or payment account, along with related account management operations;
• execution of payment transactions (direct debits, transfers, transactions carried out using a payment card or similar device) linked to a bank or payment account;
• execution of payment transactions (direct debits, transfers, transactions carried out using a payment card or similar device) linked to a credit facility;
• provision of payment instruments or the acquisition of payment orders;
• money transfer services that do not involve an account held by either the payer, the beneficiary or both; and
• issuance and management of electronic money.

This type of fintech is primarily governed by the following regulations:

• Regulation 03/16/CEMAC-UMAC-CM on payment systems, methods and incidents;
• Regulation 04/18/CEMAC/UMAC/COBAC of 21 December 2018 on payment services in CEMAC;
• COBAC Regulation R-2019/01 of 23 December 2019 on the approval and modification of the status of payment service providers;
• COBAC Regulation R-2019/02 of 23 September 2019 on prudential standards applicable to payment institutions; and
• Order 00000337/MINFI of 28 February 2024, setting out terms for the licensing and cessation of activities of electronic payment service providers in Cameroon.

Financing and lending: The services offered consist of connecting the interests of investors and project owners for the purpose of financing outside traditional institutional financial channels and may involve:

• the facilitation of the granting of loans;
• the placement, without firm commitment, of securities issued by project owners; and
• the receipt and transmission of client orders relating to financial instruments.

These services encompass both crowdfunding and crowdlending (peer-to-peer lending).

Fintechs offering such services qualify as crowdfunding advisers within the meaning of the applicable regulations. They are governed by the same regulatory framework as fintechs engaged in activities relating to digital asset services and investment advisory, as outlined below.

Other lending services provided by fintechs include:

• The option of extending credit in connection with the payment for goods or services.
• The provision of micro‑loans arising from partnerships between fintech companies and banking institutions.

Wealth management and investment: Fintechs within this segment may carry out the following activities:

• Digital asset services: These include:
• • the custody of digital assets on behalf of third parties;
  • the purchase and sale of digital assets against legal tender or other digital assets;
  • the operation of a digital asset trading platform; and
  • other related services, such as:
• • the receipt and transmission of orders on behalf of clients;
  • portfolio management on behalf of clients;
  • advisory services; and
  • placement.

Investment advisory services: These encompass:

• financial management and financial engineering advice provided to legal entities making a public appeal for savings;
• portfolio management advice on financial instruments;
• wealth management and investment advice;
• advisory services in the context of public offerings;
• guidance to companies on initial public offerings (IPOs) and post-listing support; and
• financial solicitation.

These types of fintechs are primarily governed by the following regulations:

• General Regulation of COSUMAF of 23 May 2023; and
• Regulation 22/CEMAC/UMAC/CM/COSUMAF of 22 July 2022 on the organisation and operation of the Central African financial market.

1.3 Which bodies are responsible for enforcing the applicable laws and regulations? What powers do they have?

Bank of Central African States (BEAC): The BEAC serves as the central bank for the six member countries of CEMAC. In line with its core functions, the BEAC establishes regulations on monetary policy and payment system infrastructures that fintechs must comply with.

COBAC: COBAC is the banking supervisory authority for the CEMAC region. Fintechs offering financial services must comply with COBAC's prudential standards, including:

• minimum capital requirements;
• anti-money laundering (AML) and countering the financing of terrorism (CFT) protocols; and
• data reporting and audit obligations.

These standards are designed to protect users from:

• fraud;
• misuse of funds; and
• systemic risks.

COSUMAF: COSUMAF is the financial market regulator for the CEMAC region. It oversees fintech activities in capital markets, including:

• digital investment platforms;
• crowdfunding and crowdlending;
• tokenised securities; and
• automated investment advice or asset management platforms.

Conférence Interafricaine des Marchés d'Assurances (CIMA): CIMA is the regional insurance regulator for 14 African countries, including Cameroon. Fintechs involved in digital insurance services (insurtech) must comply with CIMA regulations.

Ministry of Finance (MINFI): MINFI plays a central role in shaping the national financial ecosystem:

• setting the legal and fiscal framework within which fintechs operate; and
• collaborating with regional regulators to ensure compliance with national and regional laws.

Ministry of Posts and Telecommunications (MINPOSTEL): MINPOSTEL is responsible for the development and regulation of the digital economy. Fintechs rely on mobile networks, internet access and cloud services – all under MINPOSTEL's oversight – to deliver their services securely and efficiently.

Agence de Régulation des Télécommunications (ART): ART is Cameroon's national telecommunications regulatory authority. ART oversees mobile network operators, which often partner with fintechs to provide mobile payment solutions. It ensures that fintechs have access to reliable mobile and internet infrastructure while enforcing standards to protect users.

National Agency for Information and Communication Technologies (ANTIC): ANTIC is Cameroon's leading information and communications technology governance and cybersecurity institution. ANTIC is essential for:

• securing digital financial platforms;
• authenticating electronic transactions;
• protecting user data and privacy; and
• enabling interoperability through secure infrastructure.

1.4 What is the regulators' general approach to fintech?

Different approaches are applied to the regulatory framework for fintechs within the CEMAC region and in Cameroon:

• Segregation approach: Under this approach, each financial sector is governed by its own set of rules and supervisory authority:
• • COBAC oversees the banking sector;
  • COSUMAF supervises the capital and securities markets; and
  • CIMA regulates the insurance sector.
• In certain cases, given the nature of a fintech's services – which may span multiple financial sectors – the primary regulator may consult with other regulators to ensure proper oversight.
• Hybrid approach: The regulatory framework also integrates elements of both activity-based and entity-based regulation:
• • The entity-based approach establishes rules that apply specifically to licensed fintech entities – covering licensing requirements, governance, prudential standards and conduct rules – with each regulator setting standards relevant to its sector.
  • The activity-based approach addresses areas such as consumer protection, AML/CFT and foreign exchange. Under this approach, any entity, regardless of its licensing, must comply with the laws governing these matters if it engages in activities that fall within the scope of the relevant regulations.

1.5 Are there any trade associations for the fintech sector?

• Cameroon Fintech Association (CFIA): CFIA is the leading voice of fintechs in Cameroon:
• • fostering collaboration;
  • advocating for favourable policies; and
  • promoting financial technology for economic growth.
• It has the largest and most diverse membership base among fintechs and has actively collaborated with both national and regional regulators to support a healthy fintech regulatory framework.
• https://cmrfintech.com/
• Fintech du Cameroun: This association aims to:
• • defend the interests of Cameroonian fintechs;
  • accelerate financial inclusion in Cameroon; and
  • develop a global business network for its members.
• www.fintech.cm
• Fintech and Payments Association of Cameroon: This non-profit trade association is committed to nurturing the growth of the fintech ecosystem in Cameroon. It acts as a central hub for fintech professionals, companies and startups, providing an environment in which local and international players can flourish.
• https://cameroonfintech.com/

2 Fintech market

2.1 Which sub-sectors of the fintech industry have become most embedded in your jurisdiction?

• Payment services and paytech;
• Digital lending;
• Alternative finance;
• Crypto and blockchain;
• Digital banking;
• Wealthtech;
• Regtech; and

2.2 What products and services are offered?

Payment services and paytech: This segment includes the following products and services:

• Mobile money transfers: Allow users to send and receive money, pay bills, buy airtime and make deposits and withdrawals through a vast network of agents.
• Payment gateways: Enable online businesses and e-commerce platforms to accept payments directly from customers' mobile money accounts or bank accounts.
• Merchant payment ntegration: Point-of-sale systems, QR code payments and mobile money integration for merchants.
• Digital payment platforms: Provide a comprehensive suite of digital payment services for businesses, including bulk payments and bill collection.

Digital lending: This includes peer-to-peer lending and microloans for individuals and small businesses.

Alternative finance: Crowdfunding for entrepreneurship, savings-based solutions and community-based fundraising tools.

Crypto and blockchain: Crypto investing, blockchain-powered remittances, tokenised savings and fractional shares.

Digital banking: This includes the issuance of both virtual and physical debit cards, in Central African francs or other currencies, linked to users' accounts. Users can top up accounts via mobile money or bank transfers. These cards enable payments on various online platforms (e-commerce, streaming, gaming) and support international transactions.

Wealthtech: Technology-driven investment platforms and portfolio management tools.

Regtech: Integration of know-your-customer/anti-money laundering compliance, fraud detection and reporting tools within fintech services.

Insurtech: Microinsurance products aimed at providing affordable insurance solutions to underserved populations.

2.3 How are fintech players generally structured?

In certain cases, fintechs must be incorporated as public limited companies with a board of directors, particularly for payment service providers. However, most fintechs are generally incorporated as:

• public limited companies with board of directors is the required company form required for payment service providers;
• simplified joint stock companies, due to the flexibility of governance under this structure; or
• private limited companies, because of their less rigid governance and operational requirements compared to private limited companies.

2.4 How are they generally financed?

Personal and founders' capital: Many fintech startups initially rely on self-financing or contributions from founders and their close networks due to limited access to institutional funding.

Angel investors and venture capital: Although still emerging, some Cameroonian fintechs attract early-stage investment from African or international angel investors and venture capital firms interested in supporting digital financial inclusion.

Startup accelerators and incubators: These entities often provide non-dilutive funding, mentorship and resources to help Cameroonian fintechs scale and grow.

2.5 How are they positioned within the broader financial services landscape?

Fintechs in Cameroon play a dual role within the financial services ecosystem, serving as both:

• primary providers of financial services directly to consumers; and
• complementary partners to traditional banking institutions.

As primary financial service providers, fintechs offer financial services directly to consumers, including:

• mobile money and digital payments;
• crowdfunding;
• access to cryptocurrencies for trading; and
• fund transfers.

With a significant portion of Cameroon's population still unbanked, fintechs are filling a critical gap by delivering accessible digital financial services, particularly in rural and underserved areas.

As complementary partners to traditional financial institutions, fintechs enhance and extend the capabilities of banks and other traditional financial institutions in several ways:

• Digital infrastructure providers: Some fintechs provide application programming interfaces and payment gateways that enable banks and financial institutions to digitise their operations and reach new customer segments.
• Shared services and co-branding: Certain fintechs operate under bank licences, acting as technical partners or co-branding services with banks notably for micro-loans and micro-savings. This allows for:
• • shared risk;
  • regulatory compliance; and
  • an expanded range of service offerings.

2.6 Do start-ups generally outsource back office functions and is there a developed market for them to access? What are the legal implications of outsourcing?

Fintechs are allowed to outsource back-office functions such as:

• accounting and bookkeeping;
• human resources;
• IT and technical support; and
• customer service.

In Cameroon, the outsourcing ecosystem is still developing, particularly within the tech and finance sectors.

There are no general legal implications of outsourcing applicable to all types of fintechs.

However, for specific licensed entities such as payment service providers, the applicable regulations set out clear rules regarding outsourcing, with a particular emphasis on the outsourcing of essential operational functions. An operational function is considered essential if any anomaly or failure in its execution could seriously impair:

• the payment service provider's ability to comply continuously with applicable regulations;
• its financial performance; or
• the reliability and continuity of its payment services.

Under the applicable regulations:

• a payment service provider may outsource an essential operational function to a technical partner;
• where a function substantially contributes to the provision of payment services or related services, it may be outsourced only to an entity that is authorised to provide those services; and
• activities related to permanent control, internal audit, compliance monitoring and risk management may only be outsourced to an entity within the same corporate group as the payment service provider.

The payment service provider remains responsible for ensuring that the outsourced technical setup complies with regulatory requirements. In addition, it must:

• ensure that its internal control system incorporates outsourced activities;
• implement mechanisms to monitor and control outsourced activities; and
• submit to the Central African Banking Commission, within the prescribed deadlines, information regarding the execution of outsourced essential operational functions.

3 Technologies

3.1 How are the following key technologies in the fintech space regulated and what specific legal issues are associated with each? (a) Internet (e-commerce); (b) Mobile (m-commerce); (c) Big data (mining); (d) Cloud computing; (e) Artificial intelligence; and (f) Distributed ledger technology (Blockchain, cryptocurrencies)

(a) Internet (e-commerce)

The legal framework for e-commerce in Cameroon is shaped by several laws and regulations aimed at ensuring the safe and secure conduct of online transactions.

A key piece of legislation is Law 2010/021 of 21 December 2010 on Electronic Commerce, which was adopted to promote digital transformation and regulate all activities related to the online economy. This law establishes the foundation for e-commerce by defining the rights and obligations of parties engaged in electronic transactions. It addresses issues such as:

• electronic advertising;
• the conclusion of contracts via electronic means;
• the information obligations of service providers toward consumers;
• the execution of contracts concluded electronically;
• the storage, preservation and transmission of consumer data; and
• the security of electronic documents through electronic certificates and signatures.

Another relevant statute is Law 2010/012 of 21 December 2010 on Cybersecurity and Cybercrime, which addresses:

• data protection;
• privacy; and
• the prevention of online fraud.

Additional requirements are set out in Decision 00000039/MINPOSTEL/CAM of 4 April 2025, which establishes the modalities for public digital platforms to access the National Aggregation Platform for Electronic Communications. Under this decision:

• any digital platform open to the public for information dissemination, communication or electronic transactions must be integrated with the national aggregation platform to ensure interoperability across networks; and
• digital platforms must:
• • be approved by the Agence de Régulation des Télécommunications (ART);
  • obtain a certificate of compliance from the National Agency for Information and Communication Technologies; and
  • submit a prior declaration to ART.

The regulatory landscape for e-commerce in Cameroon faces several challenges:

• Enforcement of regulations: Existing laws often struggle to keep pace with the rapid evolution of digital commerce. Limited resources and technological infrastructure can hinder effective enforcement, potentially affecting consumer protection and fair competition.
• Electronic contracts and signatures: While legally recognised, challenges remain in verifying authenticity and ensuring the enforceability of electronic contracts and signatures.
• Taxation of e-commerce transactions: Although Cameroonian tax law clearly determines the tax applicable to online consumption, there is a lack of clarity regarding the responsibility for value-added tax compliance on sales of goods and services through electronic platforms. This creates potential inequities between local and foreign digital platform operators.

(b) Mobile (m-commerce)

The legal framework for m-commerce and related matters in Cameroon is largely similar to that governing e-commerce.

With respect to mobile money services, these fall under banking and financial regulations supervised by the Central African Banking Commission (COBAC). Mobile money service providers must be licensed as payment institutions.

A key challenge facing mobile money services is the limited interoperability between platforms, which hinders financial inclusion.

(c) Big data (mining)

The regulation of big data is governed by Law 2024/017 on Personal Data Protection. This law establishes a comprehensive framework for the collection, processing and use of personal data. It:

• defines the rights of data subjects;
• requires opt-in consent;
• mandates the maintenance of processing records;
• obliges data controllers to register with the Data Protection Authority; and
• requires authorisation for all cross-border data transfers.

A key legal challenge arises from the requirement to obtain approval from the Data Protection Authority for both the processing of personal data and all cross-border transfers, as the procedural rules for obtaining such approval have not yet been adopted by the competent authorities. This regulatory gap may:

• hinder the operations of both national and international companies; and
• complicate global data processing activities.

(d) Cloud computing

Cameroon does not yet have a dedicated cloud computing law. Cloud services are currently regulated under the 2010 Electronic Communications Law, which governs the transmission of data over electronic networks, including cloud-based services.

Other relevant legislation includes:

• the Cybersecurity and Cybercrime Law, which provides a legal framework for securing digital infrastructure; and
• the Personal Data Protection Law, which imposes obligations on cloud providers regarding:
• • user consent;
  • data security;
  • territorial scope; and
  • cross-border data transfers.

A key challenge for cloud computing services relates to requirements or pressures to host data within Cameroon, which may conflict with global cloud architecture and operational models.

(e) Artificial intelligence

Cameroon does not yet have a dedicated legal framework for artificial intelligence (AI). Discussions are currently underway to establish national legislation addressing AI.

However, existing laws on data protection, cybersecurity and consumer rights apply indirectly to AI systems.

The absence of specific AI legislation creates challenges in determining legal liability when an AI system causes harm or produces discriminatory outcomes. Additionally, there is no legal clarity regarding the ownership of intellectual property generated by AI, which may hinder innovation and investment in AI development.

(f) Distributed ledger technology (Blockchain, cryptocurrencies)

There is no specific legal framework for distributed ledger technology, including blockchain technology.

Regarding cryptocurrency, it is not recognised as legal tender within the Economic and Monetary Community of Central Africa (CEMAC) region. However, the regulators – COBAC and the Financial Market Supervisory Commission (COSUMAF) – have adopted two distinct approaches concerning the circulation of cryptocurrency in the CEMAC zone.

On one hand, COBAC has expressly prohibited regulated institutions from engaging in any transactions involving cryptocurrencies. The Bank of Central African States (BEAC), however, plans to introduce a digital currency, which would be a digital form of fiat money issued, controlled and regulated by the BEAC.

On the other hand, in recent regulations, COSUMAF has incorporated the concept of 'digital assets', which includes cryptocurrencies among other instruments. It also recognises digital asset service providers as market intermediaries, allowing them to offer one or more services or operations related to digital assets.

The legal texts governing the licensing of digital asset service providers have been pending since 2023, creating a fragile regulatory environment for fintechs involved in cryptocurrency transactions.

4 Activities

4.1 How are the following key activities in the fintech space regulated and what specific legal issues are associated with each? (a) Crowdfunding, peer-to-peer lending; (b) Online lending and other forms of alternative finance; (c) Payment services (including marketplaces that route payments from customers to suppliers (eg, Uber and AirBnb); (d) Forex; (e) Trading; (f) Investment and asset management; (g) Risk management; (h) Roboadvice; and (i) Insurtech.

(a) Crowdfunding, peer-to-peer lending

Fintechs offering crowdfunding or peer-to-peer lending services qualify as crowdfunding advisers under the regulations applicable to the capital markets sector. The licensing procedure for this type of market intermediary is clearly established by the applicable legal texts.

(b) Online lending and other forms of alternative finance

In principle, the provision of credit is reserved for credit institutions and microfinance institutions. Therefore, fintechs that operate as payment service providers cannot grant online credit unless they:

• obtain a credit or microfinance licence; or
• act in partnership with such institutions notably to offer micro-loans.

However, payment institutions may extend credit under the following conditions:

• Funds must come exclusively from the payment institution's own resources;
• Credit may be authorised only for payment transactions of goods or services;
• The total credit amount must not exceed XAF 100,000; and
• The repayment period must not exceed three months.

In the course of their lending operations, payment institutions must comply with the rules governing the effective interest rate and the usury rate applicable to financial institutions.

(c) Payment services (including marketplaces that route payments from customers to suppliers (eg, Uber and AirBnb)

Fintechs providing the following payment services must be licensed as payment service providers under Regulation 04/18/CEMAC/UMAC/COBAC of 21 December 2018 on payment services:

• services allowing the deposit and withdrawal of cash into/from a bank or payment account and related account management operations;
• execution of payment transactions (direct debits, transfers, operations carried out using a payment card or a similar device) linked to a bank account or a payment account;
• execution of payment transactions (direct debits, transfers, operations carried out using a payment card or a similar device) linked to a loan;
• provision of a payment instrument or acquisition of payment orders;
• fund transfer services not involving either the payer's account, the beneficiary's account or both; and
• issuance and management of electronic money.

Decision 00000337/MINFI, setting out the conditions for the authorisation and cessation of electronic payment service activities in Cameroon, broadened the definition of 'payment services' to include electronic payment services. This includes the provision of application programming interface communication platforms that facilitate payment operations between two payment institutions.

Payment institutions are limited in their operations, which are confined within the CEMAC region. However, they may receive, on behalf of their clients, funds originating from outside the CEMAC zone.

(d) Forex

Under the applicable regulations, payment service providers may carry out foreign exchange activities provided that such activities do not exceed 20% of their overall operations.

In the course of their activities, they must ensure compliance with CEMAC foreign exchange regulations, particularly regarding obligations to remit foreign currency to the Central Bank.

(e) Trading

Securities trading is reserved for entities licensed by the Financial Market Supervisory Commission (COSUMAF) in accordance with Regulation 01/22/CEMAC/UMAC/CM/COSUMAF of 23 July 2022 on the organisation and functioning of the Central African financial market. Trading fintechs must therefore obtain this licence in order to conduct their activities.

The trading of digital assets is reserved for entities that are licensed as digital asset service providers under Regulation 01/22/CEMAC/UMAC/CM/COSUMAF.

(f) Investment and asset management

There are no specific laws applicable to fintechs offering investment or portfolio management services. Therefore, they must comply with Regulation 01/22/CEMAC/UMAC/CM/COSUMAF of 23 July 2022 on the organisation and functioning of the Central African financial market.

Accordingly, these fintechs must obtain licences as either brokerage firms or portfolio management companies (as applicable), which will allow them, depending on the licence, to offer the following services:

• the receipt and transmission of orders relating to financial instruments for execution on the market;
• the execution of buy or sell orders on behalf of third parties;
• individual discretionary management; and
• collective management, including within the framework of collective investment schemes.

(g) Risk management

There are no specific laws applicable to fintechs offering risk management services.

However, depending on the sector in which these fintechs operate (banking, insurance or financial markets), they must ensure compliance with the laws and regulations applicable to the relevant sector.

(h) Roboadvice

There are no specific laws applicable to fintechs offering robo-advisory services.

Any fintech providing robo-advisory services must comply with Regulation 01/22/CEMAC/UMAC/CM/COSUMAF of 23 July 2022 on the organisation and functioning of the Central African financial market, which requires licensing for investment advisory services authorised to provide personalised recommendations to a client regarding one or more transactions involving financial instruments.

(i) Insurtech

There are no regulations that are specifically applicable to insurtech companies.

However, depending on whether they develop and offer insurance products directly to end consumers, distribute insurance products to end consumers on behalf of an insurance company in partnership with that company or provide solutions to digitalise underwriting processes, claims reporting and the initiation and handling of claims procedures, insurtech companies must comply with the Conférence Interafricaine des Marchés d'Assurances Insurance Code. Compliance may relate to:

• obtaining the necessary authorisation;
• ensuring the conformity of procedures or products; and
• safeguarding consumer protection.

5 Data security and cybersecurity

5.1 What is the applicable data protection regime in your jurisdiction and what specific implications does this have for fintech companies?

Cameroon's data protection framework is now governed by the Personal Data Protection Law (2024/017).

This framework applies to all personal data processing activities carried out by both public and private actors established in Cameroon within territories in which Cameroonian law applies.

The law sets out the following key requirements:

• Data subjects' consent to the processing of their personal data must be:
• • explicit;
  • informed;
  • freely given; and
  • revocable at any time.
• Data must be collected for specific and lawful purposes.
• Only data that is strictly necessary for the intended purpose may be collected and processed.
• Data controllers must ensure the confidentiality and protection of personal data against breaches.
• The processing of the data of individuals under 18 requires parental consent.
• Transfers of personal data outside Cameroon are subject to the approval of the Data Protection Authority.

The law establishes a Data Protection Authority which is responsible for:

• approving data processing activities;
• monitoring compliance; and
• enforcing penalties for violations.

Fintech companies are expected to comply with this law like all other entities. If cloud services are used, they must:

• ensure compliance with local hosting requirements; and
• observe restrictions on cross-border data transfers.

Fintech services should also be designed to minimise data collection.

5.2 What is the applicable cybersecurity regime in your jurisdiction and what specific implications does this have for fintech companies?

Cameroon's cybersecurity framework is anchored in Law 2010/012 of 21 December 2010 on Cybersecurity and Cybercrime. It establishes the legal and institutional framework for the security of information and communication technology (ICT). The law defines and criminalises various cyber offences, including:

• unauthorised access;
• data interference;
• system interference;
• computer-related fraud; and
• child pornography.

It also provides the basis for:

• digital evidence;
• electronic certification; and
• the protection of personal data and privacy in the digital space.

In addition to the national legislative framework, regional regulatory frameworks have been adopted – notably by:

• the Central African Banking Commission (COBAC Regulation R-2024/01 on IT risk management in entities supervised by COBAC); and
• the Conférence Interafricaine des Marchés d'Assurances (Regulation 010/CIMA/PCMA/CE/SG/2024 on IT security, governance and business continuity planning for insurance and reinsurance companies).

Although these two regulations apply to distinct sectors – payment services and insurance respectively – they are essentially similar.

Under these regulations, fintechs operating in these sectors must adequately manage ICT and information security risks. This includes:

• having internal and external expertise;
• allocating sufficient resources to address these needs;
• conducting periodic IT and security risk audits;
• establishing a response plan for potential cyberattacks; and
• managing any other IT-related risks.

6 Financial crime

6.1 What provisions govern money laundering and other forms of financial crime in your jurisdiction and what specific implications do these have for fintech companies?

The prevention of money laundering in Cameroon is primarily governed by regional instruments – notably:

• Regulation 01/CEMAC/UMAC/CM on the prevention and repression of money laundering, terrorism financing and proliferation in Central Africa; and
• Central African Banking Commission Regulation R-2023/01 on the due diligence obligations of entities supervised regarding the fight against money laundering, terrorism financing and proliferation.

These regulations require that supervised entities:

• take appropriate measures to assess the risks of money laundering, terrorism financing and proliferation to which they are exposed;
• implement policies, procedures and controls to mitigate and manage money-laundering risks;
• identify clients and, where applicable, the beneficial owners of business relationships using appropriate means;
• maintain ongoing monitoring of all client transactions to ensure consistency with clients' information, activities, risk profile and source of funds; and
• establish risk management systems to determine whether a client is a politically exposed person.

These regulations also govern the procedures for filing suspicious activity reports by supervised entities.

Among the supervised entities are payment institutions, as well as their sub-distributors and distributors. The rules also apply more generally to any company providing services.

Like all supervised entities, fintechs must ensure compliance with the prevention, monitoring and reporting obligations established under these regulation. Fintechs that are payment institutions are subject to specific due diligence requirements in addition to the general obligations.

7 Competition

7.1 Does the fintech sector present any specific challenges or concerns from a competition perspective? Are there any pro-competition measures that are targeted specifically at fintech companies?

The following challenges can be identified with regard to the competitiveness of the fintech sector:

• Dominance of telecoms operators/mobile money providers: Mobile money operators dominate the digital payments landscape. These companies control both the infrastructure and distribution networks, giving them significant market power. Fintech startups often rely on these platforms to reach customers, but they may face:
• • high integration costs;
  • limited bargaining power over terms; and
  • interoperability issues that can restrict broader access.
• This vertical integration can stifle innovation and make it difficult for new or smaller players to compete.
• High capital requirement for obtaining a payment institution licence: The legislation governing payment institutions requires a minimum share capital of XAF 500 million to obtain a licence to operate. To date, such licences have primarily been granted to mobile money operators, which are subsidiaries of telecoms operators. The high capital requirement limits market entry for smaller fintechs with fewer financial resources.

There are currently no specific measures to promote competition targeted at fintech companies. However, the sector remains subject to general rules against anti-competitive practices established in Cameroon and within the Economic and Monetary Community of Central Africa region, which notably prohibit:

• anti-competitive agreements;
• abuse of dominant position; and
• mergers or acquisitions that significantly reduce competition within a given sector.

8 Innovation

8.1 How is innovation in the fintech space protected in your jurisdiction?

Cameroon is a member of the African Intellectual Property Organization, which manages IP rights for 17 Francophone African countries. Under this system, innovation in the fintech sector can be protected through the following rights:

• Patents: To protect inventions.
• Copyrights: To safeguard original intellectual creations in the scientific domain, including computer programs.
• Industrial designs: To protect the visual features of physical products such as payment cards, devices and accessories, as well as graphical user interfaces associated with computer or mobile applications.
• Trademarks: To protect words, logos and sounds through which a fintech can distinguish its products or services from those of others.

8.2 How is innovation in the fintech space incentivised in your jurisdiction?

Several initiatives, particularly in the private sector, have been implemented to promote innovation in the fintech space. Notably, the Ecobank Fintech Challenge identifies and partners with fintechs ready to scale, providing them with support and access to Ecobank's 33 African markets. Other examples include incubators such as Enovation Factory, which offer incubation and acceleration programmes for startups.

9 Talent acquisition

9.1 What is the applicable employment regime in your jurisdiction and what specific implications does this have for fintech companies?

Cameroon recognises different types of employment contracts, primarily distinguished by their duration. The two main types are:

• indefinite-term (open-ended) contracts; and
• fixed-term (closed-ended) contracts.

The choice of contract type depends on the nature and the expected duration of the work:

• Open-ended contracts are the standard form of employment and are presumed unless otherwise specified and justified. Termination of such contracts requires:
• • specific grounds; and
  • adherence to prescribed procedures.
• Closed-ended contracts are generally used for specific, temporary tasks or projects. Their duration is typically limited (eg, a maximum of two years, renewable once for certain employees). Specific conditions govern renewal and conversion to indefinite-term contracts.

Employment contracts may also include a probationary period at the start of the employment relationship, which may not exceed six months.

Companies may additionally make use of seconded personnel or independent contractors, in compliance with applicable labour legislation.

Confidentiality and non-compete clauses are common, particularly for roles involving sensitive information or specialised knowledge.

There are no specific employment law provisions that are uniquely applicable to fintech companies. However, depending on their stage of development or operational policies, fintechs should ensure compliance with the relevant provisions of the national labour regime.

9.2 How can fintech companies attract specialist talent from overseas where necessary?

Fintech companies can attract talent from overseas by ensuring, wherever possible, a smooth immigration process for foreign workers. To do so, fintechs should:

• apply for temporary work permits through the Ministry of Labour and Social Security;
• utilise long-term residence permits for senior hires; and
• seek assistance from local legal firms to streamline visa processing.

Fintechs can also offer competitive and purpose-driven packages in compliance with employment legislation, including:

• equity or profit-sharing for senior roles;
• relocation support, such as housing, schooling and cultural orientation;
• flexible work arrangements, including hybrid or remote-first models; and
• clear career growth paths in an emerging market.

These fintechs can further emphasise the opportunity to shape the future of finance in Africa, which is particularly attractive for impact-driven professionals.

10 Trends and predictions

10.1 How would you describe the current fintech landscape and prevailing trends in your jurisdiction? Are any new developments anticipated in the next 12 months, including any proposed legislative reforms?

Cameroon's fintech landscape in 2025 is vibrant, fast evolving and increasingly central to the country's financial transformation. While still emerging compared to global hubs, the sector is gaining momentum through mobile innovation, digital payments and government-backed digitalisation initiatives.

The Cameroonian fintech market currently comprises at least 87 active fintechs, with strong growth concentrated in Douala and Yaoundé.

While fewer than 30% of Cameroonians hold traditional bank accounts, mobile money penetration exceeds 76% of the population, highlighting the pivotal role of digital financial services.

Key segments of the fintech industry in Cameroon include:

• payments;
• credit and lending;
• insurtech;
• savings; and

Regarding digital payments and mobile wallets, there has been rapid adoption of:

• QR code payments;
• merchant integration; and
• cross-border transfer capabilities.

Several fintech companies have partnered with banks, benefiting from:

• expanded reach;
• operational efficiency; and
• regulatory coverage.

Anticipated developments over the next 12 months include the following:

• Enforcement actions by the Ministry of Finance: Cameroon's Ministry of Finance has set a strict deadline for fintech players providing electronic payment services to obtain formal licensing by August 2025 or cease operations. Non-compliant entities will face shutdowns and potential legal action. Investigations and sanctions by the ministry are expected to enforce this measure.
• Implementation of regtech and emerging tools: To meet regulatory requirements, fintech firms are expected to adopt regtech solutions such as AI-driven fraud detection and compliance automation.
• Comprehensive digital law reform: A major overhaul of Cameroon's digital legal framework, including the Personal Data Protection Law, has been initiated. This reform will also update legislation on:
• • electronic communications;
  • cybersecurity and cybercrime;
  • e-commerce; and
  • electronic transactions.

11 Tips and traps

11.1 What are your top tips for fintech players seeking to enter your jurisdiction and what potential sticking points would you highlight?

Our top tips for fintech players for entering the Cameroonian fintech market are as follows:

• Understand the regulatory landscape: Fintech promoters should map out where their business model fits. Different fintech models – such as mobile payments, e-money issuance, lending, crowdfunding, investment and asset management or crypto-asset trading – trigger distinct licensing requirements.
• Identify and engage early with regulators: Depending on the fintech sector, various regulators may have oversight. It is important to identify the relevant regulator early and engage in a transparent dialogue to clarify expectations. Some regulators offer informal guidance or pre-licensing consultations, which can help to prevent missteps.
• Prioritise compliance and risk management from the start: Anti-money laundering/know-your-customer, data protection and cybersecurity are typically under strict scrutiny. Fintechs should integrate compliance frameworks into their operations from inception rather than as an afterthought.
• Focus on financial inclusion: Cameroon has low formal banking penetration. Fintechs should design products or services that bridge the unbanked gap, such as payments, loans or insurance solutions.
• Choose the appropriate market entry strategy: Options include:
• • obtaining a direct licence; or
  • partnering with licensed banks or microfinance institutions, which allows fintechs to:
  • • leverage existing infrastructure;
    • bypass certain licensing hurdles; and
    • build credibility.
• Join the ecosystem: Connect with trade associations, such as the Cameroon Fintech Association, which fosters collaboration and advocates for the fintech sector.

Potential sticking points to watch out for include the following:

• Tight and complex regulatory requirements: Licensing can be lengthy, capital intensive and complex, particularly for small or foreign fintech entrants. Multiple regulations, authorities and sector-specific rules must be considered.
• Regulatory uncertainty: Emerging models such as decentralised finance and AI-driven finance involve legal ambiguities, adding compliance risks. Engaging a local law firm is essential to navigate these complexities and streamline processes.
• Limited interoperability: Although regulators and market participants are seeking solutions to enable interoperability between platforms, full operational interoperability is not yet achieved. This can fragment payment rails and limit operational scalability.

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.