Uganda#
Uganda's payments licensing regime is anchored in the National Payment Systems Act, 2020 (NPSA) and the National Payment Systems Regulations, 2021, which vest the Bank of Uganda (BoU) with sole authority to license operators of payment systems, payment service providers (including electronic money issuers) and issuers of payment instruments. Three licence categories exist (PSO, PSP, IPI) with tiered minimum capital, and BoU issued the first Class-A PSP and e-money licences to MTN and Airtel's newly incorporated mobile-money subsidiaries in May 2021.
Bank of Uganda maintains a primary Acts and Regulations register confirming its statutory role as licensing and supervisory authority for payments and deposit-taking.
This licensing perimeter draws a clear line between deposit-taking banks supervised under the Financial Institutions Act and the growing population of non-bank payment service providers and electronic money issuers now brought under direct Bank of Uganda oversight for the first time.
Outlook
No further licensing-perimeter changes are expected imminently, but the NPS Act 2020 framework remains the active governing basis against which subsequent Bank of Uganda conduct, safeguarding and product-innovation measures will continue to be assessed.
Licensing, Authorisation & Market Access
Bank of Uganda has initiated a review of the National Payment Systems Regulations, following feedback from the fintech industry concerning licensing timelines, regulatory clarity and interoperability. Fragmented payment systems were cited as a contributing factor behind elevated transaction fees, forming part of the stated rationale for undertaking the review, though no primary instrument text, consultation close date, or expected timeline for an outcome has been disclosed. Separately, the central bank disclosed in its Annual Report that it licensed ten institutions as payment service providers or payment system operators during the 2025/26 financial year, a baseline that spans both bank and non-bank applicants. The review and the licensing disclosure were reported together via secondary trade coverage; no primary Bank of Uganda document — whether the Annual Report itself or any consultation paper on the regulations review — was directly located this period, leaving the precise scope of what the review will address, and any proposed amendment to the National Payment Systems Act, 2020 framework underneath it, unconfirmed.
Outlook
The review's stated triggers — licensing timelines and interoperability — point toward those two areas as the most likely focus of any eventual amendment, but this is a direction of travel inferred from the stated rationale rather than a scoped proposal. The FY2025/26 figure of ten PSP/PSO licences granted provides a baseline against which to measure whether the pace of licensing accelerates, slows, or changes composition between bank and non-bank applicants once the regulatory review reaches a decision stage.
2 earlier distinct update(s)
Licensing, Authorisation & Market Access
The National Payment Systems Act, Cap 59, designates Bank of Uganda as the licensing, supervisory and enforcement authority for payment service providers, including mobile money operators and payment gateways. This confirmed statutory architecture applies across both bank-PSP and non-bank payment-institution/e-money-institution categories, and it forms the legal basis for the two most significant developments this cycle: the incoming cash-withdrawal caps and the mobile-money agent identity-verification requirement.
Effective 1 January 2027, Bank of Uganda will impose over-the-counter cash-withdrawal caps of UGX 50 million per day for individuals and UGX 500 million per day for corporates. This measure is exercised under the Bank's authority pursuant to the Financial Institutions Act, Cap 57, and the National Payment Systems Act, Cap 59. The caps are currently sourced only at a lower evidentiary tier this cycle, pending independent retrieval of the underlying Bank of Uganda circular text, and should be treated as confirmed in direction but awaiting stronger primary-source corroboration on precise mechanics and any applicable exemptions.
Separately, the National Payment Systems (Agents) Regulations, 2021, a confirmed Tier 1 instrument directly retrieved from the Bank of Uganda's own regulatory publications, governs mobile money agent conduct including identity-verification thresholds, providing the regulatory-instrument backbone for the agent-level ID-verification requirement addressed under Consumer Protection & APP Fraud.
Outlook
The implementation of the 2027 cash-withdrawal caps is the primary licensing and market-access development to track going forward. Independent retrieval of the underlying Bank of Uganda circular would materially strengthen confidence in the precise cap mechanics, any sectoral exemptions, and the treatment of agent-network cash operations, which interact directly with the licensing perimeter this module tracks.
Licensing, Authorisation & Market Access
The National Payment Systems Act, Cap 59 designates the Bank of Uganda as the licensing, supervisory and enforcement authority across Uganda's digital payments landscape, with jurisdiction covering both payment service providers and e-money issuers. This standing authority structure is unchanged this cycle, but BoU has signalled it intends to turn that authority inward on its own governing framework: the Deputy Governor's February 2026 remarks confirmed BoU is conducting an end-of-term evaluation of the National E-Payments Strategy 2021-2026 and is simultaneously developing a Second National E-Payments Strategy covering 2026-2031, with a stated priority within that successor strategy to review the NPS Act regulatory framework itself.
This is a materially different signal than routine guidance-level adjustment. A strategy-level commitment to review the primary licensing statute suggests BoU sees the current framework as potentially insufficient for the scale and pace of market growth it is now supervising, rather than merely in need of updated implementing regulations. For payment service providers and e-money issuers operating under the current NPS Act licensing regime, this represents a live watch item: the substance of any resulting framework change is not yet specified, but the direction of travel — a fundamental review rather than incremental guidance — has been stated as a strategic priority.
The bank-PSP versus non-bank PI/EMI distinction is relevant context for how any resulting framework change might land: a review of the NPS Act's core licensing architecture would need to address how obligations differ between bank-affiliated payment service providers and non-bank payment institutions and e-money issuers, a distinction inherent to the existing licensing categories the Act already recognises.
Outlook
The near-term signal to watch is the publication timeline and content of BoU's Second National E-Payments Strategy (2026-2031), expected around the fourth quarter of 2026. Whether the stated NPS Act review priority translates into a concrete legislative amendment process, or remains a strategic aspiration within the strategy document, will determine whether this becomes a binding market-access change or remains a watch-list item for a future cycle.
Sources and findings (6)
- T1https://ulii.org/akn/ug/act/2020/15/eng@2020-09-04/source
- T3https://aln.africa/insight/the-regulatory-framework-for-fintechs/
- T3https://www.theworldlawgroup.com/membership/news/key-features-of-ugandas-national-payment-systems-act
- T3https://www.tadvocates.com/blog-single.php?id=28
- T3https://www.kaa.co.ug/an-overview-of-the-national-payment-systems-act-2020/
- T3https://cepiluganda.org/cepil-legal-briefs/the-national-payment-systems-act-2020/