KM

Licensing, Authorisation & Market Access

Banking and payments licensing in Comoros is a Union-exclusive competence: the Banque Centrale des Comores holds sole authority to authorise banks and financial institutions under Article 7 of Legislation No. 80-7 (1980). Non-bank e-money issuance runs through a separate, dedicated route: three non-bank Electronic Money Institutions are currently licensed under Regulation 01/2017, distinct from bank-issued payment products. In February 2026 the BCC extended this non-bank track further, issuing Axian Group a new 'IFDD' (decentralised digital financial institution) licence enabling a fully digital, centrally-supervised entity that offers nano and micro loans by mobile phone, alongside Axian's existing MVola mobile-money platform. Set against this Union-level licensing regime, island-level bodies calling themselves the Anjouan Offshore Finance Authority and the Mwali International Services Authority carry zero legal recognition: Organic Law 05-003/AU and Article 9 of the Constitution reserve licensing to the Union, and BCC, IMF, World Bank and FATF sources confirm the island bodies have no standing to authorise banks or financial institutions.

Conduct, Safeguarding & Promotions

Comoros has no codified conduct or promotions rulebook comparable to a CASS-style safeguarding regime. The observed enforcement mechanism is direct: the Banque Centrale des Comores publishes public communiqués, most recently in 2022-2023, warning that no island entity is authorised to issue banking or financial licences. This positions BCC's public messaging, rather than a formal codified rulebook, as the operative conduct-and-promotions control for the non-bank e-money sector.

Stablecoins & Digital Money

Comoros has no standalone crypto or stablecoin licensing framework. Virtual-asset activity is captured only via the general financial-institution 'agrément' authorisation route, the same route used for other financial-institution licensing; the BCC had issued no dedicated crypto guidance as of 2026, and adoption remains low, with peer-to-peer activity funded via mobile-money on-ramps.

Operational Resilience & Critical Infrastructure

Manual cheque-clearing through the SYCOCO system, processing around 5,000 cheques a month worth KMF 19.7 billion, remains the sole formal interbank clearing mechanism, pending absorption into a planned ATS+ (RTGS/ACH/instant funds transfer) system with no confirmed go-live date. That legacy mechanism now sits alongside a new layer of interoperability: a National Interoperable Payment Switch went live on 25 August 2025, connecting banks, microfinance institutions and mobile-money operators under the World Bank-backed PADSF programme, replacing historically closed-loop ATM and POS networks. Separately, the BCC and the Central Bank of Tunisia signed an institutional cooperation agreement in April 2026 covering payment-system modernisation and cybersecurity strengthening.

Scheme & Network Compliance

Comoros' retail card infrastructure remains nascent: only 37 ATMs and 28 point-of-sale devices operate nationally, with roughly 34,000 cards in circulation, and networks have historically been closed-loop and non-interoperable. No Comoros-specific interchange regulation, surcharging rule, or PCI DSS mandate has been identified; the 2025 Payment Switch is the first material step toward domestic scheme standardisation.

Payment Corridor Dynamics

Remittance inflows exceed 20% of GDP, up from 12.1% of GDP in 2018, and Western Union and MoneyGram internet-channel transfers on the France-Comoros corridor cost approximately 3.5% to 9% in total, with payout still made predominantly in cash. Comoros participates in the SADC-RTGS regional multicurrency settlement system alongside fifteen other SADC member states; its participation status in the Pan-African Payment and Settlement System remains unconfirmed from available public sources.

Industry Structure & Commercial Dynamics

The Comorian state holds a significant capital stake in two private banks, keeping it involved in the financial sector beyond pure regulatory oversight. The sector remains small and bank/microfinance-dominated, with no stock exchange, while the competitive mobile-money segment, including MVola, Holo Money and Huri Money, continues to grow.

Outlook

Continued growth in mobile-money competition alongside a still-concentrated, state-linked banking sector is the structural dynamic to track.

Legal & Litigation

A 2010 IMF/ESAAMLG assessment found that a BCC-filed complaint against unknown parties remained unprosecuted, and that the offshore legal framework created in Anjouan remained legally in effect absent formal invalidation. That historical enforcement-capacity gap continues to contextualise the ongoing AOFA/MISA legitimacy dispute, the dominant payments-relevant legal contest in the jurisdiction.

Outlook

Whether the AOFA/MISA dispute produces a formal judicial or administrative invalidation, rather than continued reliance on public communiqués, remains the central legal watch item.

Merchant Acquiring & Risk

The National Payment Switch is positioned to provide faster merchant settlement and expand rural payment access, an expected improvement against a backdrop of low point-of-sale penetration. No dedicated acquiring regulation, chargeback or dispute framework, or high-risk-MCC treatment regime has been identified for Comoros.

Outlook

Whether merchant-facing rules follow the Switch's infrastructure gains, in the same way scheme compliance may eventually follow it, is the open question for this module.

Product Innovation & Market Development

Comoros adopted its first-ever National Financial Inclusion Strategy for 2025-2030 on 8 October 2025, chaired by the BCC through a newly created National Financial Inclusion Council. The strategy sets financial-inclusion targets through 2030 and provides the strategic backdrop for payment-switch and agent-network rollouts; no CBDC pilot has been confirmed for Comoros.

Consumer Protection & APP Fraud

BCC public communiqués warn that AOFA paperwork triggers enhanced due diligence and is commonly declined by banks and payment service providers, functioning as a de facto consumer-protection mechanism in the absence of a dedicated ombudsman scheme or APP-fraud reimbursement regime.

Outlook

Whether Comoros develops a dedicated financial ombudsman or APP-fraud reimbursement framework, rather than continuing to rely on communiqué-based warnings, remains unconfirmed.

AML/CFT & Financial Crime

This module is sourced from the Sentinel.gi feed; the analysis below reflects Sentinel's payments-context summary rather than independent WPM illicit-finance analysis. Comoros underwent a Mutual Evaluation, published May 2024 and endorsed by FATF, confirming the jurisdiction is not currently on the FATF black or grey list. The same evaluation found that the BCC lacks adequate resources to effectively monitor AML/CFT obligations across supervised institutions, and that DNFBP AML/CFT supervisory authorities remain undesignated under AML/CFT Law No. 12-008/AU, Article 24(1). For deeper illicit-finance risk assessment of the DNFBP supervisory gap, see the linked Sentinel.gi feed and the FIM cross-reference.

Correspondent Banking, Settlement & Access

Access to correspondent banking in Comoros runs through locally licensed banks rather than through any dedicated non-bank correspondent channel, the asymmetry that defines this module: cross-border settlement access runs via SADC-RTGS and correspondent relationships held by those banks, including Exim Bank Comoros, a subsidiary of Exim Bank Tanzania. No Comoros-specific de-risking incident was independently confirmed this cycle; generic frontier-market de-risking pressure is relevant context only.

Commercial Intelligence

Axian Group secured a Banque Centrale des Comores IFDD licence (24 February 2026) to launch a branchless digital financial institution offering nano and micro loans via mobile phone; deal value was not publicly disclosed. The Banque Centrale des Comores and the Central Bank of Tunisia signed an institutional cooperation agreement (7 April 2026) covering monetary policy, financial stability, supervision, payment-system modernisation, fintech and cybersecurity; deal value was not publicly disclosed. The African Development Bank and Axian Group launched a digital finance programme (announced 2 September 2026) leveraging Mixx and MVola to support 34,000 women-led businesses across five countries including Comoros, building on AfDB's earlier financing to Axian Telecom; deal value was not publicly disclosed.