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Zambia's payment-services and banking licensing regime was fundamentally reformed in 2026: the National Payment System Act 2026 (Act No. 5) and the Banking and Financial Services Act 2026 (Act No. 9) consolidate licensing of banks, microfinance, moneylenders, fintechs and e-money issuers under Bank of Zambia supervision.
Outlook
The pending ministerial commencement instrument for the National Payment System Act 2026 is the key marker to watch; until it is gazetted, the 2007 Act continues to govern licensing and designation, creating a transition window in which both regimes are referenced but only one is operative.
Licensing, Authorisation & Market Access
Zambia's National Payment System Act, 2026 (Act No. 5) repeals and replaces the 2007 National Payment Systems Act, providing for licensing, designation and authorisation of payment service providers, and introducing a statutory forty-five-day decision window for the Bank of Zambia to determine authorisation applications, with applicants notified within a further seven days. Alongside it, the Banking and Financial Services Act, 2026 (Act No. 9) consolidates banks, microfinance institutions, moneylenders, fintechs and e-money issuers under a single Bank of Zambia licensing, reporting and enforcement regime, replacing the fragmented 2017 Banking and Financial Services Act and Money-lenders Act patchwork. Both instruments are Tier-1 sourced and assessed at High confidence.
The practical market-access effect is twofold. First, the bank-versus-non-bank distinction is now explicit in statute: non-bank payment institutions and e-money issuers sit within the same Bank of Zambia-administered perimeter as banks rather than in a separate or ambiguous space, and face the same forty-five-day statutory decision window as any other applicant. Second, the cost of remaining outside that perimeter has risen sharply — the Banking and Financial Services Act imposes penalties of up to three million penalty units and/or up to thirty years' imprisonment for conducting banking business or providing a financial service, including payment services and e-money issuance, without a licence.
Outlook
The National Payment System Act's authorisation regime is expected to reach fuller operationalisation around the third quarter of 2026. Whether the Bank of Zambia honours the forty-five-day decision window in practice, and how the steep unlicensed-activity penalty ceiling is applied in the initial enforcement period, are the two central markers to watch next cycle.
Sources and findings (6)
- T1https://www.boz.zm/national-payment-systems-act.htm
- T1https://zambialii.org/akn/zm/act/2026/5/eng@2026-04-08
- T2https://www.afriwise.com/blog/regulation-of-fintech-in-zambia---a-legal-guide
- T1https://www.boz.zm/sites/default/files/2026-04/Requirements%20for%20Designation%20of%20Payment%20System.pdf
- T3https://blog.useaccrue.com/the-future-of-cross-african-payments-opportunities-and-regulatory-pinch-points/
- T1https://www.state.gov/reports/2025-investment-climate-statements/zambia