Uganda (UG)

Key facts

Last Run Type

baseline

Key facts

W1A

Uganda's payments licensing regime is anchored in the NPSA 2020 and NPS Regulations 2021, vesting BoU with sole licensing authority across PSO/PSP/IPI categories; first Class-A licences issued to MTN/Airtel mobile-money subsidiaries May 2021.

W1B

100%-backed trust/special-account safeguarding model under NPSA, layered with 2022 Consumer Protection Regulations and 2021 Agents Regulations.

W2

No licensed stablecoin regime; crypto banned and judicially upheld; CBDC pilot claims are vendor-sourced and not independently BoU-confirmed.

W3

Mandatory Cyber and Technology Risk Management Guidelines (eff. 1 Dec 2024) layered on 24-hour breach notification; Jan-2026 election blackout disrupted mobile money ~1 week.

W4

Card-scheme compliance via international rulebooks/local acquirers; mobile money dominant proprietary rail; National Payments Switch tender cancelled post-preferred-bidder stage.

W5

Cross-border rails via RTGS-integrated EAPS (EAC) and COMESA REPSS (USD/EUR); PAPSS direct connectivity unconfirmed; informal KE-wallet corridor emerged during Jan-2026 blackout.

W6

Concentrated banking sector (top-10 ~81% assets) atop a fragmented 170+-player payments layer; Agent Banking Company platform facilitates most cash-in/out activity.

W7

Crypto-ban precedent settled (2023); consolidating Quincecare-style digital-fraud liability case law; 2026 FIA account-freeze judicial review pending.

W8

Bank + agent/aggregator acquiring split; high-risk verticals pushed offshore; merchant infrastructure fragmentation persists pending switch resolution.

W9

CBDC pilot/tokenisation drive, NPSA sandbox, new CMA fintech sandbox (Oct 2025), and cash-lite cheque/cash migration policy (in force Jan 2027).

W10

2022 Consumer Protection Regulations, April-2024 national-ID verification mandate, and persistent SIM-swap/insider-collusion mobile-money fraud risk with case-law-driven loss allocation.

W11

ESAAMLG-assessed FATF mutual-evaluation history, grey-list exit (exact date absent), and Sept-2025 FIA virtual-asset ML/TF risk assessment.

W12

UNIS/RTGS open to banks and non-bank FIs (MDIs indirectly); foreign-owned banks (Stanbic/Absa) remain principal correspondent conduits; no specific de-risking evidence found.

W13

Trailing-12-month commercial intelligence dominated by BoU/CMA Small Systems RTGS modernisation, GSN/Diacente CBDC-tokenisation partnership (vendor-led, unconfirmed by BoU), stalled switch procurement, and modest fintech equity funding uptick.

Weekly Brief

Content

## Lead Signal Uganda's mobile-money infrastructure absorbed its most severe operational shock to date in January 2026, when a government-enforced digital blackout ahead of the 15 January general elections left MTN and Airtel mobile-money platforms fully inoperative for roughly a week before service resumed. The outage forced Ugandans to route funds through Kenyan M-Pesa and Airtel Money wallets, converting Kenyan shillings back into Ugandan currency to ease domestic cash shortages, opening an informal cross-border corridor that persisted for the duration of the shutdown. The episode tested a resilience framework barely a year old: Bank of Uganda's Cyber and Technology Risk Management Guidelines became mandatory for all supervised financial institutions on 1 December 2024, layered on the National Payment Systems Act's 24-hour fraud and breach notification duty. That the disruption originated in a state-directed communications shutdown rather than a cyber intrusion or vendor failure underscores that Uganda's principal payments-resilience exposure now sits outside conventional operational-risk categories, at the intersection of telecom policy and payments infrastructure. ## Other Developments This cycle also establishes Bank of Uganda's first full standing baseline across the World Payments Monitor's fourteen-module spine. The National Payment Systems Act, 2020 and its 2021 Regulations vest Bank of Uganda with sole authority to license payment system operators, payment service providers and payment-instrument issuers through a three-tier PSO/PSP/IPI framework, under which MTN and Airtel's mobile-money units received Payment Service Provider Class A and Electronic Money Systems licences in May 2021, requiring corporate separation from their telecom parents. Conduct and safeguarding sit alongside licensing: e-money issuers must hold 100% of issued electronic money in trust or special accounts in unencumbered liquid assets withdrawable on demand, reinforced by the National Payment Systems (Consumer Protection) Regulations, 2022, which Bank of Uganda is reported to be actively enforcing. Bank of Uganda's prohibition on crypto-currency transactions by NPSA licensees, imposed by an April 2022 circular, was upheld by the High Court on 24 April 2023, which found that cryptocurrency is not an accepted general payment instrument under the current regime. Against that prohibition, a vendor-announced central bank digital currency pilot has surfaced: Global Settlement Network and Diacente Group announced in October 2025 a partnership framed as piloting a "digital shilling" tied to a $5.5 billion tokenisation initiative, and Bank of Uganda published a CBDC-consultant application form in March 2026, but no Tier-1 Bank of Uganda announcement confirms a formal pilot launch. This narrative should be read as vendor-sourced and unconfirmed pending primary regulatory disclosure. Domestic scheme infrastructure remains unresolved. Bank of Uganda's National Payments Switch tender, launched in July 2023 and drawing more than twenty bidders, reached final evaluation with Paylogic S.A. reportedly emerging as preferred bidder before the process was unexpectedly cancelled amid lobbying claims and competing business interests, leaving domestic scheme infrastructure fragmented. MTN Uganda has separately achieved GSMA Mobile Money Certification, an independent assessment covering secure service delivery, consumer-rights protection and AML/CFT capability. Bank of Uganda's April 2024 directive requires national-ID, passport, refugee or alien-ID verification for mobile-money transactions of UGX 1 million or more at agent locations, citing rising fraud and scam usage of mobile-money platforms; a separately reported incident put losses from a SIM-swap-enabled mobile-money fraud scheme at an estimated $3.2 million using roughly 2,000 SIM cards. Litigation is active on multiple fronts beyond the crypto-ban case: in Abacus Parenteral v Stanbic Bank, the High Court split liability for a fraudulent-transaction loss, holding the bank 20% liable for inadequate fraud-detection systems and beneficiary-verification failures. Bank of Uganda also directed banks, credit institutions and MDIs to cut interbank cheque-value limits and cap over-the-counter cash withdrawals from 1 January 2027, part of a broader cash-lite migration strategy, while the Capital Markets Authority's fintech regulatory sandbox, launched October 2025, holds four active applications. Banking-sector concentration remains high, with the top ten banks controlling roughly 81% of industry assets and Stanbic Bank the largest at UGX 10.34 trillion in 2024, even as the Agent Banking Company's shared platform of more than 22,000 agents now handles the large majority of cash-in/cash-out activity across banks, MDIs, MFIs, SACCOs and fintechs. ## Cross-Monitor Connections Uganda's Financial Intelligence Authority published its inaugural National ML/TF Risk Assessment on Virtual Assets in September 2025, quantifying $564 million in virtual-asset inflows and $546 million in outflows between July 2020 and June 2024 despite the standing crypto-transaction ban, against a backdrop of Uganda's ESAAMLG membership and FATF mutual-evaluation history, including a documented prior grey-list membership. The Authority's enforcement powers are themselves under judicial scrutiny: BMS General Trading filed a 2026 judicial review challenging FIA's October 2025 directive freezing its bank account on money-laundering suspicion, arguing the freeze lacked a reasonable basis or a hearing. Illicit-finance analysis of these virtual-asset flows and the FIA's enforcement conduct is a Financial Intelligence Monitor matter; this Monitor notes the payments-regulatory context only. ## Outlook Three items anchor the forward calendar. Bank of Uganda's cheque-value and cash-withdrawal caps take effect 1 January 2027, and compliance planning by banks, credit institutions and MDIs should be watched over the intervening quarters. Whether the GSN/Diacente CBDC narrative converts into a confirmed, Tier-1-sourced Bank of Uganda pilot remains the key open question for Uganda's digital-money trajectory; absent primary confirmation it should continue to be treated as vendor-sourced. Finally, the fate of the cancelled National Payments Switch procurement — and whether Bank of Uganda revives it, re-tenders, or continues to rely on ACH and card-scheme rails — will determine whether Uganda's fragmented merchant-acquiring and scheme-compliance landscape consolidates or persists.

Approved

False

Edited By

Revision Pending

False

Proposed Content

Last Cycle Id

wpm-2026-07-04

Domain Sub Briefs

W1A

{"module_id": "W1a", "module_name": "Licensing, Authorisation & Market Access", "content_tier": null, "limited_signal_flag": false, "content": "## Licensing, Authorisation & Market Access\n\nThe National Payment Systems Act, 2020 and its 2021 Regulations vest Bank of Uganda with sole authority to license payment system operators, payment service providers (including e-money issuers) and payment-instrument issuers, structured around three licence categories: PSO, PSP and IPI. No exemption pathway exists outside this framework. The regime's practical application is illustrated by MTN Mobile Money and Airtel Mobile Commerce, whose newly incorporated mobile-money subsidiaries were issued Payment Service Provider Class A licences and Electronic Money Systems Licences in May 2021; the licensing structure required both operators to corporately separate their mobile-money units from their telecom parents, establishing them as standalone, fully regulated non-bank e-money issuers rather than telecom-embedded services. This bank/non-bank distinction is foundational to Uganda's market-access architecture: banks and non-bank PSPs both operate under the NPSA umbrella, but non-bank e-money issuers such as the MTN and Airtel entities carry additional licensing conditions specific to their non-deposit-taking status.\n\n## Outlook\n\nWith the licensing architecture now over five years old and no signalled legislative amendment, the near-term trajectory for W1a is administrative rather than structural: continued licensing of new PSO/PSP/IPI entrants under the existing three-tier framework, with market-access questions increasingly shifting toward scheme-level infrastructure (see W4) rather than the licensing gateway itself.", "approved": false, "edited_by": null, "revision_pending": false, "proposed_content": null, "last_cycle_id": "wpm-2026-07-04"}

W1B

{"module_id": "W1b", "module_name": "Conduct, Safeguarding & Promotions", "content_tier": null, "limited_signal_flag": false, "content": "## Conduct, Safeguarding & Promotions\n\nE-money issuers in Uganda must hold 100% of issued electronic money in a trust account, if non-bank, or a special account, if a licensed financial institution, in unencumbered liquid assets that are withdrawable on demand. Conduct is governed by the National Payment Systems (Consumer Protection) Regulations, 2022, gazetted 9 September 2022, which Bank of Uganda is reported to be actively enforcing alongside a developing market-conduct supervision framework.\n\n## Outlook\n\nSafeguarding remains the standing conduct anchor; with the 100% trust/special-account rule and active Consumer Protection Regulations enforcement both in place, the near-term W1b watch item is whether enforcement actions become publicly reported on a case-by-case basis, and whether the safeguarding rule is extended as new non-bank instrument categories emerge.", "approved": false, "edited_by": null, "revision_pending": false, "proposed_content": null, "last_cycle_id": "wpm-2026-07-04"}

W2

{"module_id": "W2", "module_name": "Stablecoins & Digital Money", "content_tier": null, "limited_signal_flag": false, "content": "## Stablecoins & Digital Money\n\nBank of Uganda's April 2022 circular barring all NPSA licensees from crypto-currency transactions was upheld by the High Court on 24 April 2023, Justice Ssekaana ruling that cryptocurrency is not an accepted general payment instrument under the current NPS regime. A vendor-led narrative complicates this settled position: Global Settlement Network and Diacente Group announced in October 2025 a partnership piloting a permissioned-blockchain 'digital shilling' CBDC tied to a $5.5bn tokenisation initiative, and Bank of Uganda published a CBDC-consultant application form in March 2026, but no Tier-1 Bank of Uganda announcement confirms a formal pilot launch.\n\n## Outlook\n\nThe crypto prohibition is settled law absent a legislative reversal; the open question is whether the GSN/Diacente CBDC narrative converts into a confirmed, Tier-1-sourced Bank of Uganda pilot, which would represent the first sanctioned digital-money instrument to sit alongside the standing crypto ban.", "approved": false, "edited_by": null, "revision_pending": false, "proposed_content": null, "last_cycle_id": "wpm-2026-07-04"}

W3

{"module_id": "W3", "module_name": "Operational Resilience & Critical Infrastructure", "content_tier": null, "limited_signal_flag": false, "content": "## Operational Resilience & Critical Infrastructure\n\nBank of Uganda's Cyber and Technology Risk Management Guidelines became mandatory for all supervised financial institutions effective 1 December 2024, layered on the National Payment Systems Act's existing 24-hour fraud and breach notification duty. That framework faced its sharpest test in January 2026, when MTN and Airtel mobile-money platforms were fully inoperative for about a week during a government-enforced digital blackout ahead of the 15 January general elections, before service resumed.\n\n## Outlook\n\nHaving weathered a state-directed shutdown rather than a conventional cyber incident, Bank of Uganda's resilience framework faces a broader test: whether guidance is extended to cover telecom-dependency risk specifically, not solely cyber and technology failure modes.", "approved": false, "edited_by": null, "revision_pending": false, "proposed_content": null, "last_cycle_id": "wpm-2026-07-04"}

W4

{"module_id": "W4", "module_name": "Scheme & Network Compliance", "content_tier": null, "limited_signal_flag": false, "content": "## Scheme & Network Compliance\n\nMTN Uganda has attained GSMA Mobile Money Certification, an independent scheme-level assessment of secure and reliable service delivery, consumer-rights protection, and AML/CFT capability \u2014 distinct from card-scheme rulebooks such as Visa, Mastercard or PCI-DSS. Scheme-level infrastructure for domestic switching remains unresolved: Bank of Uganda's National Payments Switch tender, launched July 2023 with more than twenty bidders, reached final evaluation with Paylogic S.A. reportedly the preferred bidder, before the process was unexpectedly cancelled amid lobbying claims and competing business interests, leaving domestic scheme infrastructure fragmented.\n\n## Outlook\n\nWhether Bank of Uganda revives, re-tenders, or abandons the National Payments Switch procurement will determine if Uganda's scheme layer consolidates around a domestic switch or continues to rely on card-scheme and mobile-money-scheme certification as parallel, fragmented compliance tracks.", "approved": false, "edited_by": null, "revision_pending": false, "proposed_content": null, "last_cycle_id": "wpm-2026-07-04"}

W5

{"module_id": "W5", "module_name": "Payment Corridor Dynamics", "content_tier": null, "limited_signal_flag": false, "content": "## Payment Corridor Dynamics\n\nUganda's cross-border settlement runs through RTGS-integrated channels: the East African Payment System (EAPS) for EAC-currency transfers, and COMESA's REPSS, which settles in USD/EUR, alongside conventional SWIFT correspondent-banking channels. During the January 2026 telecom blackout, Ugandans routed MTN and Airtel mobile-money funds through Kenyan M-Pesa and Airtel Money wallets, converting Kenyan shillings back into Ugandan currency to ease domestic cash shortages, opening a fragile informal cross-border corridor.\n\n## Outlook\n\nThe informal UG-KE corridor that opened during the blackout is expected to close as domestic mobile money normalises, but it has demonstrated a fragile dependency that regional-rail resilience planning (EAPS/REPSS) does not yet address; PAPSS connectivity status remains an open sourcing gap.", "approved": false, "edited_by": null, "revision_pending": false, "proposed_content": null, "last_cycle_id": "wpm-2026-07-04"}

W6

{"module_id": "W6", "module_name": "Industry Structure & Commercial Dynamics", "content_tier": null, "limited_signal_flag": false, "content": "## Industry Structure & Commercial Dynamics\n\nUganda's banking sector is highly concentrated: the top ten banks control roughly 81% of industry assets, with Stanbic Bank the largest at UGX 10.34 trillion in 2024, approximately 19.52% of the industry total. That bank-centred concentration coexists with a fragmented, agent-driven distribution layer: the Agent Banking Company's shared platform supports more than 22,000 agents across banks, MDIs, MFIs, SACCOs and fintechs, now facilitating the large majority of cash-in/cash-out activity nationally.\n\n## Outlook\n\nIndustry structure is likely to remain bifurcated \u2014 concentrated banking, fragmented payments \u2014 absent resolution of the National Payments Switch question; agent-banking's dominance of cash-in/cash-out activity is expected to deepen further.", "approved": false, "edited_by": null, "revision_pending": false, "proposed_content": null, "last_cycle_id": "wpm-2026-07-04"}

W7

{"module_id": "W7", "module_name": "Legal & Litigation", "content_tier": null, "limited_signal_flag": false, "content": "## Legal & Litigation\n\nJustice Musa Ssekaana of the High Court ruled on 24 April 2023 that cryptocurrencies under the current NPS regime are illegal, unlawful and not accepted as a general payment instrument, dismissing the challenge to Bank of Uganda's crypto-transaction circular. In Abacus Parenteral v Stanbic Bank, the High Court split liability for a fraudulent-transaction loss, holding the bank 20% liable given inadequate fraud-detection systems and beneficiary-verification failures, with the customer bearing the remainder. Separately, BMS General Trading filed a 2026 judicial review challenging the Financial Intelligence Authority's October 2025 directive freezing its bank account on money-laundering suspicion, for lack of a reasonable basis or a hearing, testing the limits of the Authority's enforcement powers.\n\n## Outlook\n\nLitigation activity is expected to continue across three tracks: crypto-ban enforcement (settled), digital-fraud liability allocation between banks and customers (developing), and the limits of FIA's account-freezing powers (pending judicial review).", "approved": false, "edited_by": null, "revision_pending": false, "proposed_content": null, "last_cycle_id": "wpm-2026-07-04"}

W8

{"module_id": "W8", "module_name": "Merchant Acquiring & Risk", "content_tier": null, "limited_signal_flag": false, "content": "## Merchant Acquiring & Risk\n\nHigh-risk merchants \u2014 gaming, crypto and adult content \u2014 face limited local acquiring options given regulatory scrutiny and PSP risk policies, typically necessitating offshore payment facilitators. Standard Ugandan bank merchant agreements, such as Stanbic Bank's, permit acquirer payments to be reversed post-settlement if subject to a chargeback or claim, even after goods or services have already been provided.\n\n## Outlook\n\nMerchant acquiring is expected to remain constrained for high-risk verticals absent a change to the crypto prohibition or a dedicated high-risk-merchant licensing track; standard chargeback terms are unlikely to change materially.", "approved": false, "edited_by": null, "revision_pending": false, "proposed_content": null, "last_cycle_id": "wpm-2026-07-04"}

W9

{"module_id": "W9", "module_name": "Product Innovation & Market Development", "content_tier": null, "limited_signal_flag": false, "content": "## Product Innovation & Market Development\n\nThe Capital Markets Authority's fintech regulatory sandbox launched in October 2025 and holds four active applications as of reporting, operating alongside \u2014 and distinct from \u2014 the pre-existing Bank of Uganda NPSA sandbox track. Bank of Uganda has separately directed banks, credit institutions and MDIs to implement new interbank cheque-value limits and over-the-counter cash-withdrawal caps from 1 January 2027, part of a broader cash-lite digital-migration strategy.\n\n## Outlook\n\nThe cash-lite cheque/withdrawal directive entering into force 1 January 2027 will be the principal near-term product-innovation watch item, alongside whether the CMA sandbox's four active applications convert into licensed products.", "approved": false, "edited_by": null, "revision_pending": false, "proposed_content": null, "last_cycle_id": "wpm-2026-07-04"}

W10

{"module_id": "W10", "module_name": "Consumer Protection & APP Fraud", "content_tier": null, "limited_signal_flag": false, "content": "## Consumer Protection & APP Fraud\n\nBank of Uganda's April 2024 directive requires national-ID, passport, refugee or alien-ID verification for mobile-money transactions of UGX 1 million or more conducted at agent locations, citing rising fraud and scam usage of mobile-money platforms. The persistent fraud risk was illustrated by a significant SIM-swap-enabled mobile-money fraud incident resulting in an estimated $3.2 million loss, using approximately 2,000 SIM cards to infiltrate the payment system and instruct transfers dispersed across those cards.\n\n## Outlook\n\nConsumer-protection tightening is likely to continue via threshold-based ID verification and enforcement of the 2022 Consumer Protection Regulations, though SIM-swap and insider-collusion fraud typologies remain a persistent, only partially addressed risk.", "approved": false, "edited_by": null, "revision_pending": false, "proposed_content": null, "last_cycle_id": "wpm-2026-07-04"}

W11

{"module_id": "W11", "module_name": "AML/CFT & Financial Crime (Sentinel.gi-fed)", "content_tier": null, "limited_signal_flag": false, "content": "## AML/CFT & Financial Crime (Sentinel.gi-fed)\n\nsentinel.gi position: Uganda is an ESAAMLG member assessed under the FATF framework, with a documented history of grey-list membership tied to its 2016 mutual evaluation. The Financial Intelligence Authority's inaugural National ML/TF Risk Assessment on Virtual Assets, published September 2025, found $564 million in virtual-asset inflows and $546 million in outflows between July 2020 and June 2024, despite the standing crypto-transaction ban \u2014 intelligence this Monitor carries as payments-context only, per Sentinel.gi feed attribution, with illicit-finance analysis routed to the Financial Intelligence Monitor.\n\n## Outlook\n\nThis module is Sentinel.gi-fed; ongoing monitoring of Uganda's ESAAMLG/FATF standing and FIA enforcement activity should be tracked through the Sentinel feed rather than re-analysed here.", "approved": false, "edited_by": null, "revision_pending": false, "proposed_content": null, "last_cycle_id": "wpm-2026-07-04"}

W12

{"module_id": "W12", "module_name": "Correspondent Banking, Settlement & Access", "content_tier": null, "limited_signal_flag": false, "content": "## Correspondent Banking, Settlement & Access\n\nHigh-value payments in Uganda settle via the Uganda National Interbank Settlement (UNIS) RTGS System, which has 26 registered participants and is open to both banks and non-bank financial institutions. The bank/non-bank asymmetry that defines this module is structural rather than prohibitive: Uganda's five microfinance deposit-taking institutions are not restricted from direct RTGS participation as non-banks, but in practice participate indirectly via commercial-bank settlement services, leaving foreign-owned banks as the principal correspondent conduits.\n\n## Outlook\n\nCorrespondent-access dynamics for Uganda's foreign-owned banks and indirect non-bank RTGS participation warrant continued sourcing attention; no de-risking evidence specific to Uganda has yet been found, a gap flagged for the next cycle.", "approved": false, "edited_by": null, "revision_pending": false, "proposed_content": null, "last_cycle_id": "wpm-2026-07-04"}

W13

{"module_id": "W13", "module_name": "Commercial Intelligence (M&A, Investment & Product)", "content_tier": null, "limited_signal_flag": false, "content": "## Commercial Intelligence (M&A, Investment & Product)\n\nBank of Uganda partnered with Swedish vendor CMA Small Systems to migrate the UNIS RTGS platform to the CMA RTS/X system, a completed product release supporting ISO 20022 messaging, real-time multi-currency settlement, and delivery-versus-payment / payment-versus-payment functionality; contract value was not publicly disclosed. Global Settlement Network and Diacente Group announced, in October 2025, a partnership framed around a Uganda CBDC pilot tied to a broader $5.5 billion tokenisation initiative; the announcement is vendor-sourced and not yet confirmed by any Tier-1 Bank of Uganda publication. The Bank of Uganda National Payments Switch tender was terminated after Paylogic S.A. reportedly emerged as preferred bidder, amid lobbying claims and competing business interests \u2014 the same underlying procurement event tracked separately in W4. The Capital Markets Authority separately launched its Fintech Regulatory Sandbox product in October 2025, now holding four active applications \u2014 a regulatory-sandbox product launch distinct from the pre-existing Bank of Uganda NPSA sandbox track.\n\n## Outlook\n\nThe trailing-twelve-month commercial calendar \u2014 RTGS modernisation, the vendor-led CBDC announcement, the cancelled Switch tender, and the CMA sandbox launch \u2014 will likely be joined by further switch-related developments once Bank of Uganda signals a path forward.", "approved": false, "edited_by": null, "revision_pending": false, "proposed_content": null, "last_cycle_id": "wpm-2026-07-04"}

Jurisdiction Sub Briefs

• UG