--- title: "Zambia Payments Regulation Monitor | World Payments Monitor" canonical: https://payments.gi/jurisdictions/zambia/ source_html: /jurisdictions/zambia/index.html description: "Zambia payments and e-money regulation: 14 modules, 72 sourced findings, updated 2026-10-26. Licensing, safeguarding, stablecoins, AML/CFT." generated_at: 2026-10-26T19:20:26Z content_sha256: dee3b91161fa0cfc682475284d75098220df07b3ff8218c3f23b1519412fdcce generator: "fe-fleet/md-twin@1.0" --- # Zambia ZM schema world-payments-v1 trajectory: not yet assessed Last updated 2026-10-26 · 14 modules · 72 sourced findings · 122 sources in the cumulative register Download report (PDF) Expand all 14 Modules 1 Moved this cycle 2 Key judgments 3 Open gaps 72 Findings 45 Tier-1 sources Confidence mix 2 confirmed 12 unpopulated (sums to 14 rendered modules; click to filter) 1 module moved this cycle ## Jurisdiction brief Jurisdiction lead brief 1,328 Full executive summary 197 Jurisdiction sub-brief 2 522 ###### Latest update · 25 October 2026 #### Lead Signal Zambia's payments-licensing architecture is undergoing a structural rebuild rather than an incremental update. Two statutes, the National Payment System Act, 2026 and the Banking and Financial Services Act, 2026, were both published to the Government Gazette on 8 April 2026 and assented in March 2026, but neither has commenced. Parliament's own committee report on the National Payment System Bill records that the prior 2007-era system-focused Act did not specify in detail licensing requirements for individual payment service providers, electronic-money issuers, payment aggregation, market conduct or governance standards, a gap the new Act is designed to close once it is brought into force. The Banking and Financial Services Act, 2026 works in parallel, repealing and replacing the prior Banking and Financial Services Act and consolidating oversight of banks, microfinance institutions, moneylenders, fintechs and e-money issuers under a single Bank of Zambia supervisory framework. The practical effect is a transition period: market participants, including an already sizeable non-bank payment-services sector, operate under the outdated system-focused framework while a detailed licensing, governance and market-conduct regime sits enacted but dormant, awaiting a ministerial commencement date for each Act. #### Other Developments Zambia's non-bank payments sector has grown substantially under the outgoing framework. The Bank of Zambia's own June 2026 Open Finance position paper records that the number of licensed payment service providers and fintechs rose from 37 in 2016 to 84 in 2024, alongside mobile-money transaction value of K486.3 billion and 12.3 million active mobile-money accounts in 2024. This scale of activity under a system-focused regulatory framework that itself lacked detailed provider-level licensing rules is the commercial backdrop against which the new legislative detail is arriving, and explains the pressure toward a more granular licensing architecture rather than an incident that caused it. Mobile-money and bank infrastructure continue to interconnect commercially. A partnership between Airtel Money and Stanbic Bank, reported in mid-2026, introduced Airtel Money payments on Stanbic's point-of-sale machines, enabling mobile-wallet payments to be made directly at the point of sale, an example of the kind of bank-mobile money interoperability that Zambia's large active mobile-money base makes commercially attractive. #### Cross-Monitor Connections The Banking and Financial Services Act, 2026 is the same instrument that consolidates anti-money-laundering supervision of banks, moneylenders, fintechs and e-money issuers under the Bank of Zambia, a change of direct interest to financial-crime-focused monitoring of Zambia, since the same commencement question that determines payments-licensing timing also determines when the consolidated anti-money-laundering supervisory perimeter becomes operative. #### Outlook The central variable for Zambia's payments market over the coming periods is commencement: both the National Payment System Act, 2026 and the Banking and Financial Services Act, 2026 are enacted but await a ministerial commencement order, and the detailed licensing, governance, market-conduct and resolution provisions they introduce for payment service providers, e-money issuers and fintechs have no legal effect until that step occurs. Current estimates place commencement in the first quarter of 2027, though this is treated as uncertain pending a formal government announcement, and the scale already reached by Zambia's non-bank payments sector means the transition, once triggered, will apply to a materially larger and more commercially active market than existed when the prior system-focused Act was drafted. 4 earlier updates not shown here. ###### Standing brief · as of 8 July 2026 Written before the update above. Where they differ, the update is the more recent position. #### Lead Signal Zambia's Cyber Security Act, 2025 designates banking and finance—including payment gateways and core banking systems—as critical information infrastructure subject to registration, data localisation, annual audits and incident-reporting to the new Zambia Cyber Security Agency; non-compliance penalties up to ZMW1,200,000 and/or 10 years' imprisonment. The law's companion Cyber Crimes Act 2025 was enacted alongside it, and this pairing is assessed as the single most material operational-resilience development to emerge from this cycle's review. Zambia's central bank has direct experience of the risks the new framework targets: Bank of Zambia was hit by a Hive ransomware attack in 2022, in which it declined to pay the ransom and reported minimal system damage, and suffered a Facebook account hack in July 2023. Civil-society and legal-sector voices have already begun contesting how the new architecture is governed: the Law Association of Zambia and a wider civil-society coalition criticised the Cyber Security Agency's placement under the Office of the President as lacking independent governance and parliamentary oversight, a concern with direct bearing on how critical-payments-infrastructure oversight will be exercised in practice. #### Other Developments Zambia's payments-licensing architecture is itself mid-transition. The National Payment System Act, 2026 was enacted 8 April 2026, repealing and replacing the National Payment Systems Act 2007, but it awaits ministerial commencement via statutory instrument; the 2007 Act framework remains operative pending that instrument, and this cycle's review could not independently verify commencement status against a Gazette instrument as of the 4 July 2026 baseline. Separately, a parliamentary committee reviewing the preceding National Payment System Bill 2025 flagged that its restructuring and insolvency provisions for payment service providers could create procedural uncertainty against the existing Corporate Insolvency Act, and recommended harmonisation. On digital money, Bank of Zambia's plan calls for establishing a CBDC framework between 2024 and 2026, including implementation and supervision regulations plus a pilot exploring possible use cases, though named pilot use-cases have not yet been published. Cryptocurrencies are not legal tender in Zambia, and the Bank of Zambia Act vests exclusive note and coin issuance in the central bank. Corridor dynamics continue to deepen: Zambia joined the SADC-RTGS as a participant in September 2014 via BoZ and nine commercial banks, and the system interlinks with PAPSS and COMESA REPSS; PAPSS itself, launched January 2022, connects ten central banks including Zambia and supports real-time local-currency settlement, though it has not yet disrupted entrenched correspondent-banking pathways. Commercially, MTN Mobile Money Zambia launched a service enabling customers to send money directly from wallets to international bank accounts in the EU, UK and Canada, described as Zambia's first direct wallet-to-bank international transfer offering. Industry structure shows an oligopolistic telecom/mobile-money market—Airtel Zambia holds roughly 48% subscriber share and MTN Zambia 33-35%, with state-owned Zamtel the remainder—and Airtel Networks Zambia Plc surpassed $1 billion market capitalisation on the Lusaka Securities Exchange on 8 June 2026. Standard Chartered is separately reported to be exploring a potential sale of its wealth and retail banking units in Botswana, Uganda and Zambia, an unconfirmed development that would signal a possible market-structure shift among incumbent international banks. On the consumer side, a World Bank diagnostic found Bank of Zambia lacks a dedicated, adequately resourced consumer-protection function—roughly five officers covering both banking and financial consumer protection—even as cybercrime including phishing and social-media fraud has cost the Zambian economy over K111 million, feeding political momentum for the 2025 cyber-law framework; no dedicated APP-fraud mandatory-reimbursement regime exists. #### Cross-Monitor Connections Zambia remains in FATF/ESAAMLG enhanced follow-up: a 2022 follow-up report found progress on some technical-compliance deficiencies but downgraded Recommendations 2, 5 and 7. The Financial Intelligence Centre is the designated AML/CFT supervisor for Virtual Asset Service Providers absent a dedicated VASP licensing regulator, applying FATF Recommendation 15 requirements including suspicious-transaction-report filing on attempted transactions. This AML/CFT posture, and any illicit-finance or sanctions-evasion analysis arising from it, is flagged to the Financial Intelligence Monitor rather than assessed here; the Sentinel-fed W11 material is carried in this monitor as provenance only. #### Outlook Two forward markers frame the next review window. Bank of Zambia's CBDC framework and pilot phase are expected to reach completion around 2026-Q4, closing out the 2024-2026 plan period, while the National Financial Inclusion Strategy II runs through 2028-Q4, continuing to set interoperability, agent-exclusivity and inclusion targets. The more immediate marker, however, is procedural: the ministerial commencement instrument for the National Payment System Act 2026 remains outstanding, and Bank of Zambia's Cyber Security Agency compliance-onboarding cycle is now underway following the April 2025 Cyber Security Act enactment, with annual audit and reporting obligations already active for payment gateways and core banking systems. Both threads warrant close tracking into the next cycle. Read full brief · 1328 words Standing brief, as of 8 July 2026. #### Regulatory Status Zambia's payments regime sits mid-transition: the National Payment System Act, 2026 was enacted 8 April 2026 but awaits ministerial commencement, leaving the National Payment Systems Act 2007 operative in the interim. Operational-resilience obligations tightened sharply with the Cyber Security Act, 2025, which designates payment gateways and core banking systems as critical information infrastructure under the new Zambia Cyber Security Agency. Correspondent-banking access remains stable, per the 2025 US Investment Climate Statement, aided by SADC-RTGS, PAPSS and COMESA REPSS regional-rail participation that reduces reliance on traditional correspondent chains. Zambia remains in FATF/ESAAMLG enhanced follow-up following a 2022 follow-up report that downgraded three FATF recommendations. Consumer-protection enforcement capacity is structurally thin at Bank of Zambia, even as commercial activity in mobile-money and fintech, including Lupiya's Series A round and Airtel Zambia's billion-dollar market-capitalisation milestone, continues to expand. #### Outlook The ministerial commencement instrument for the National Payment System Act 2026 and the Cyber Security Agency's compliance-onboarding cycle are the two developments most likely to reshape Zambia's regulatory position before the next review; both sit alongside a continuing CBDC pilot running through 2026 and an NFIS II policy period extending to 2028. Read full brief · 197 words ###### Latest update · 25 October 2026 #### Regulatory Status Zambia's payments regulatory framework is mid-transition. The National Payment System Act, 2026 and the Banking and Financial Services Act, 2026 were both published to the Government Gazette on 8 April 2026, having been assented in March 2026, but neither has commenced as. The outgoing framework, per Parliament's own committee report on the National Payment System Bill, was primarily system-focused and did not specify in detail licensing requirements for individual payment service providers, electronic-money issuers, payment aggregation, market conduct or governance standards. The incoming Banking and Financial Services Act, 2026 repeals and replaces the prior Banking and Financial Services Act, consolidating oversight of banks, microfinance institutions, moneylenders, fintechs and e-money issuers under a single Bank of Zambia supervisory framework. The Bank of Zambia itself confirms it administers four Acts of Parliament, including the National Payment System Act and the Banking and Financial Services Act, as part of its regulatory remit. This legislative transition sits atop a payments market that has already scaled substantially under the outgoing framework: the Bank of Zambia's own June 2026 Open Finance position paper records the number of licensed payment service providers and fintechs rising from 37 in 2016 to 84 in 2024, with mobile-money transaction value of K486.3 billion and 12.3 million active mobile-money accounts in that year. Commercial interoperability between bank and mobile-money infrastructure continues to develop, illustrated by a mid-2026 Airtel Money-Stanbic Bank partnership enabling mobile-wallet payments on point-of-sale machines. #### Outlook Commencement of both the National Payment System Act, 2026 and the Banking and Financial Services Act, 2026 is the central event to track for Zambia's payments regulatory status; current estimates point to the first quarter of 2027, though no formal commencement order had been issued as, so this date should be treated as indicative rather than confirmed. Once commenced, Zambia's already substantial population of licensed payment service providers and fintechs will be assessed against materially more detailed licensing, governance and market-conduct standards than currently apply. 2 earlier updates not shown here. ###### Standing brief · as of 26 August 2026 Written before the update above. Where they differ, the update is the more recent position. #### Regulatory Status Zambia's payments and banking licensing architecture was comprehensively re-founded in April 2026 through the National Payment System Act, 2026 (Act No. 5) and the Banking and Financial Services Act, 2026 (Act No. 9). The former reforms Bank of Zambia payment-service-provider authorisation with a new forty-five-day statutory decision window; the latter consolidates banks, microfinance institutions, moneylenders, fintechs and e-money issuers under one Bank of Zambia licensing, reporting and enforcement regime, backed by penalties of up to three million penalty units and/or thirty years' imprisonment for unlicensed activity. Mobile money, whose transaction value rose to K891.6 billion in 2025 from K105.8 billion in 2020, remains the dominant payments segment this new architecture now governs. #### Outlook Operationalisation of the National Payment System Act's authorisation regime is expected around the third quarter of 2026. How the Bank of Zambia applies the new decision timeline and enforcement ceiling in practice, and how the licensing architecture treats mobile-money-adjacent providers, are the central markers for the next cycle. Read full brief · 522 words × 14 of 14 modules Signal Moved Judgment Gap Density Comfortable Compact Expand all sources Reset all Selections OR within a group, AND across groups. Press / to search. ### W1aLicensing, Authorisation & Market Accessmoved1 judgmentConfirmedconfirmed 2026-07-04▾# Zambia enacted the National Payment System Act, 2026 (repealing and replacing the National Payment Systems Act, Cap. 359 of 2007) and the Banking and Financial Services Act, 2026 (Act No. 9 of 2026, repealing the Money-lenders Act Cap. 398). Both consolidate licensing/authorisation of payment service providers and financial service providers under Bank of Zambia oversight, but neither had a confirmed commencement order as of the most recent available legal commentary. Movement — CHANGED NPSA 2026 and BFSA 2026 both enacted, not commenced. Two new primary-source statutes identified replacing the 2007 payments law and 2017 banking law. Key judgment — Probable · impact HIGH Zambia's payments-licensing architecture is undergoing a structural upgrade: two enacted-but-not-commenced statutes (NPSA 2026 and BFSA 2026) will replace a system-focused 2007 law with detailed PSP, e-money and fintech licensing, governance and resolution rules, though the transition period leaves current market participants in regulatory limbo until commencement. claims: none recorded Horizon · 2026-Q3 (± six months) National Payment System Act 2026 licensing regime operationalisation Adopted · Tier 1 source Horizon · 2027-Q1 (± six months) NPSA 2026 / BFSA 2026 commencement pending Adopted · Tier 1 source Horizon · 2027-Q1 (± a year) National Payment System Act 2026 commencement Adopted · Tier 1 source Horizon · 2027-Q1 (± a year) Banking and Financial Services Act 2026 commencement Adopted · Tier 1 source Horizon · 2027-Q1 (± a year) National Payment System Act, 2026 commencement Adopted · Tier 1 source Horizon · 2027-Q1 (± a year) Banking and Financial Services Act, 2026 commencement Adopted · Tier 1 source Standing sub-brief · as of 8 July 2026 204 words · last cycle 2026-10-25 #### Licensing, Authorisation & Market Access Zambia's payments-licensing regime is in transition. The National Payment System Act, 2026 was enacted 8 April 2026, repealing and replacing the National Payment Systems Act 2007, but it awaits ministerial commencement via statutory instrument; the 2007 Act framework remains operative pending that instrument. This cycle's review flagged that commencement status as of the 4 July 2026 baseline could not be independently verified against a Gazette instrument, holding confidence at High rather than Confirmed. Separately, foreign-owned banks face a $100 million minimum capital requirement versus $20 million for domestic banks, and commercial banks are licensed via the Registrar of Banks, Financial Institutions and Financial Businesses housed at Bank of Zambia. The foreign-PSP licensing pathway is active in practice: Flutterwave, the Nigerian payments company, obtained a Zambian payment licence in early 2025 to facilitate local mobile money and cross-border payments, illustrating that foreign PSPs must obtain Bank of Zambia licensing regardless of physical presence. #### 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. Read full sub-brief · 204 words Periodic update · new data 2026-10-25 #### Licensing, Authorisation & Market Access Zambia's payments-licensing framework stands at a structural inflection point. Two statutes central to market access, the National Payment System Act, 2026 and the Banking and Financial Services Act, 2026, were both published in a supplement to the Government Gazette on 8 April 2026, having been assented earlier in the quarter, but neither has yet commenced. The Act's own gazette record confirms the publication date and its not-commenced status directly. Parliament's own committee report on the preceding National Payment System Bill documents the gap being closed: the existing, system-focused Act did not specify in detail licensing requirements for individual payment service providers, electronic money issuers, payment aggregation, market conduct or governance standards. This gap matters for market access specifically because it has, until now, left the licensing conditions for new or expanding payment service providers comparatively undefined relative to jurisdictions with granular provider-level licensing regimes. The Banking and Financial Services Act, 2026 works as a companion instrument for market access purposes: it repeals and replaces the prior Banking and Financial Services Act and brings fintechs and e-money issuers, previously subject to variable or unclear oversight, under explicit Bank of Zambia licensing and prudential obligations. For a firm seeking payments market access in Zambia, the practical consequence of this pairing is that the licensing pathway each Act establishes, covering authorisation, governance standards and market-conduct rules, has been legislated but is not yet the operative pathway; existing licence-holders and new entrants alike continue to be assessed under the prior framework until a commencement date is set by the responsible minister. This is a market of real scale behind the pending reform. The Bank of Zambia's own June 2026 position paper on Open Finance records that the number of licensed payment service providers and fintechs rose from 37 in 2016 to 84 in 2024, a more than doubling of market participants under the system-focused regime that the new Acts are designed to supersede. That scale of existing market activity is itself a reason the new licensing detail, covering authorisation, designation, governance and conduct standards, carries high stakes for current operators: a commencement date, once set, will require an already substantial population of licensed providers to be assessed against materially more detailed standards than applied when most of them were first authorised. #### Outlook The decisive event for Zambia's payments-licensing landscape is ministerial commencement of both Acts; current indications point to the first quarter of 2027, though this should be treated as an estimate rather than a confirmed date, since no formal commencement order had been issued as. Once triggered, the transition will require existing payment service providers, e-money issuers and fintechs, a population that has grown materially over the past decade, to be brought under detailed licensing, governance and market-conduct standards that do not currently apply to them, a change of degree rather than of kind for the Bank of Zambia's supervisory role, but one with direct consequences for market-access timelines for prospective entrants in the interim. 4 earlier distinct update(s) Periodic update · new data 2026-10-11 #### Licensing, Authorisation & Market Access Zambia's payments and banking licensing architecture moved from a pre-reform, system-level-only framework to an enacted but not-yet-operative individual-licensing regime this cycle. The National Payment System Act, 2026, assented to on 31 March 2026 and gazetted on 8 April 2026, repeals the National Payment Systems Act Cap 359 of 2007, which had governed payment systems principally through designation of systems rather than licensing of individual providers. In its place, the new Act introduces individual licensing for payment service providers and e-money institutions, with each licence carrying AML/CFT duties, cyber-incident-reporting obligations, capital requirements and customer-fund-segregation duties attached directly to the licence rather than imposed at the system level. A National Assembly committee report on the underlying Bill confirms that the legislation sets rules spanning governance, AML/CFT, cyber-incident reporting, capital requirements and segregation of customer funds, indicating the licensing framework was drafted as a comprehensive prudential package rather than a narrow authorisation gate. Alongside it, the Banking and Financial Services Act, 2026 was assented to and gazetted on the same dates. This Act consolidates banks, microfinance institutions, moneylenders, fintechs and e-money issuers under a single Bank of Zambia licensing and supervisory framework, repealing both the prior Banking and Financial Services Act and the Money-lenders Act Cap 398. The practical effect, once the Act commences, is that categories of financial-service provider that previously sat under separate, sometimes lighter-touch regimes, including moneylenders and non-bank fintech credit providers, would move under direct Bank of Zambia prudential supervision alongside banks. Legal commentary on the Act's drafting indicates that its definitions of "financial service" and "financial service provider" are written to explicitly capture issuing and managing means of payment, including e-money, meaning e-money issuance is positioned to fall within the unified Bank of Zambia licence under this Act rather than being carved out to a separate payments-only authorisation track. Both Acts share the same critical procedural feature: enactment without commencement. Each requires a ministerial statutory instrument to bring it into force, and no such instrument had been located in the sourcing reviewed this cycle. This means that, as a matter of current legal effect, payment service providers and financial-service providers operating in Zambia continue to be governed by the pre-reform statutes the 2026 Acts are designed to replace. For market-access planning purposes, however, the legislative destination is now fixed: a firm seeking to enter or expand in the Zambian payments or banking market can plan against the individual-licensing, AML/CFT-and-capital-bearing regime that is now enacted law, even while operating in the interim under the designation-based 2007 framework. #### Outlook The central open question for Zambia's licensing and market-access landscape is the timing of commencement. No commencement statutory instrument has been located for either the National Payment System Act or the Banking and Financial Services Act, and commencement is anticipated, as scheduled, around early 2027, though this estimate carries real uncertainty and should not be treated as confirmed. Firms with existing payment-system designations or banking licences under the pre-reform statutes should expect a transition process once commencement occurs, likely requiring re-licensing or confirmation of continued authorisation under the new individual-licence structure. Non-bank payment providers, e-money issuers, moneylenders and fintech lenders not currently captured by unified prudential supervision represent the segment most affected by the change, since they would newly fall within Bank of Zambia licensing and the associated AML/CFT, capital, cyber-incident-reporting and fund-segregation duties. Monitoring for the commencement instrument itself is therefore the single most consequential near-term signal for market-access planning in this jurisdiction. Periodic update · new data 2026-09-29 #### Licensing, Authorisation & Market Access Zambia's licensing and market-access basis for payments and banking was re-legislated within a single 2026 cycle across two statutes. The National Payment System Act, 2026 (Act No. 5 of 2026) establishes the National Payment System for purposes of regulation and supervision by the Bank of Zambia under the Bank of Zambia Act, 2022, replacing the 2007 National Payment Systems Act as the statutory basis for BoZ's authority over payment system operators and participants. The Banking and Financial Services Act, 2026 (Act No. 9 of 2026) repeals and replaces both the 2017 Banking and Financial Services Act and the Money-lenders Act, consolidating financial-sector regulation under BoZ on an explicit proportionality principle and empowering BoZ to impose a licensing moratorium. Both statutes route licensing and supervisory authority for their respective sectors through the same central bank, and licensing of financial service providers, including fintech and payment-service-provider entities that sit in the bank-PSP versus non-bank-PI/EMI space, continues under the new consolidated Banking and Financial Services Act framework rather than under any separate PI/EMI-specific licensing statute. The proportionality principle written into the Banking and Financial Services Act, 2026 is notable for the bank-PSP versus non-bank-PI/EMI distinction specifically, since a proportionality-based licensing approach typically signals differentiated capital and conduct requirements according to institution type and risk profile rather than a single uniform bank-grade licensing bar applied to every regulated entity. The licensing moratorium power granted to BoZ under the Banking and Financial Services Act, 2026 is a market-access lever distinct from ordinary licensing criteria: it allows BoZ to pause new licensing activity across the sector at its discretion, which is a structural market-access control mechanism rather than an entry-criteria change. #### Outlook No implementing regulations specifying licensing criteria, capital thresholds, or the practical application of the proportionality principle under the Banking and Financial Services Act, 2026 were identified this cycle. The next dated event to watch is the publication of any such implementing instrument or BoZ guidance clarifying how the proportionality principle differentiates licensing requirements across bank, non-bank PSP, and PI/EMI-type entities. Periodic update · new data 2026-09-22 #### Licensing, Authorisation & Market Access Zambia's payments market-access architecture underwent a significant statutory overhaul in 2026 with the enactment of the National Payment System Act, which repeals and replaces the National Payment Systems Act, Cap. 359 of 2007. The new Act introduces licensing, designation and authorisation provisions specifically for payment service providers, alongside insolvency and receivership rules that did not exist in equivalent form under the prior framework. This runs in parallel with the Banking and Financial Services Act, 2026 (Act No. 9 of 2026), which consolidates banks, microfinance institutions, moneylenders, fintechs and e-money issuers under a single Bank of Zambia licensing and supervisory regime, expressly repealing the Money-lenders Act, Cap. 398. Both instruments were sourced from Tier-1 parliamentary primary text and both carry an elevated impact assessment for market-access architecture. The critical qualifier on both instruments is commencement status. Legal commentary tracking the ZambiaLII consolidated legal database recorded the Banking and Financial Services Act as uncommenced as of 5 August 2026, pending a ministerial statutory instrument; this sourcing carries a lower confidence tier than the primary parliamentary text itself, since it rests on a single Tier-3 corroboration rather than a Tier-1 confirmation of non-commencement. The practical effect is that Zambia currently has an adopted, but not yet operative, consolidated licensing architecture spanning both payment service providers specifically and the wider population of banks, microfinance institutions, moneylenders, fintechs and e-money issuers under the companion Act. This consolidation is significant precisely because it collapses what was previously a more fragmented licensing landscape into unified Bank of Zambia oversight. Under the prior regime, moneylenders were governed by a dedicated Money-lenders Act now repealed by the Banking and Financial Services Act, while payment service providers operated under the now-superseded National Payment Systems Act, Cap. 359. The 2026 consolidation brings bank and non-bank payment institution regulation into closer alignment under common statutory instruments, though the degree to which prudential requirements will differ between bank-PSP and non-bank-PI/EMI categories under the new regime is not yet detailed in the sources available this cycle. The distinction between bank and non-bank payment institution treatment remains analytically important to track once implementing regulations or licensing guidelines are published, since consolidation under a single Act does not necessarily imply identical prudential treatment across entity types. #### Outlook The central item to track for Zambia's market-access architecture is the ministerial commencement order for both the National Payment System Act and the Banking and Financial Services Act, 2026, expected in the region of the first quarter of 2027 on current legal-commentary estimates, though this carries a half-year uncertainty band given the reliance on a single Tier-3 source for commencement timing. Once gazetted, the consolidated licensing, designation and authorisation perimeter will apply directly to payment service providers, and the interaction between this regime and the parallel banking consolidation will determine whether bank-affiliated payment providers face a materially different licensing pathway than standalone non-bank payment institutions and e-money issuers. Firms currently operating under the pre-existing National Payment Systems Act, Cap. 359 framework continue to do so pending that commencement order. Periodic update · new data 2026-09-08 #### 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. Evidence 6 Sources and findings (6) - T1[https://www.boz.zm/national-payment-systems-act.htm](https://www.boz.zm/national-payment-systems-act.htm)retrieved 2026-07-04 - T1[https://zambialii.org/akn/zm/act/2026/5/eng@2026-04-08](https://zambialii.org/akn/zm/act/2026/5/eng@2026-04-08)retrieved 2026-07-04 - T2[https://www.afriwise.com/blog/regulation-of-fintech-in-zambia---a-legal-guide](https://www.afriwise.com/blog/regulation-of-fintech-in-zambia---a-legal-guide)retrieved 2026-07-04 - T1[https://www.boz.zm/sites/default/files/2026-04/Requirements%20for%20Designation%20of%20Payment%20System.pdf](https://www.boz.zm/sites/default/files/2026-04/Requirements%20for%20Designation%20of%20Payment%20System.pdf)retrieved 2026-07-04 - T3[https://blog.useaccrue.com/the-future-of-cross-african-payments-opportunities-and-regulatory-pinch-points/](https://blog.useaccrue.com/the-future-of-cross-african-payments-opportunities-and-regulatory-pinch-points/)retrieved 2026-07-04 - T1[https://www.state.gov/reports/2025-investment-climate-statements/zambia](https://www.state.gov/reports/2025-investment-climate-statements/zambia)retrieved 2026-07-04 ### W1bConduct, Safeguarding & PromotionsProbableconfirmed 2026-07-04▾# Conduct/safeguarding rules sit in BoZ directives under BFSA s.167 and NPSA-derived e-money directives, supplemented by a weak voluntary Bankers Association Code; BoZ consumer-protection capacity remains thin. Standing sub-brief · as of 8 July 2026 105 words · last cycle 2026-07-08 #### Conduct, Safeguarding & Financial Promotions Bank of Zambia's 2024 update to the unwarranted-charges regime for electronic money services prohibits wallet deposit fees, merchant/bill-payment surcharges, failed-transaction charges, balance-inquiry fees, and wallet opening/closing/reactivation fees. Yet a World Bank diagnostic found Bank of Zambia lacks a dedicated, adequately resourced consumer-protection function, with roughly five officers covering both banking and financial consumer protection, and found the voluntary Bankers' Code of Practice has limited enforcement mechanisms. #### Outlook The gap between an increasingly detailed conduct-rulebook and thin supervisory capacity is the module's defining tension; safeguarding specifics for e-money customer funds remain undetailed in available sources and are a standing research gap. Read full sub-brief · 105 words no periodic updates on record for this sub-brief Evidence 5 Sources and findings (5) - T1[https://www.boz.zm/financial-stability/bank-charges](https://www.boz.zm/financial-stability/bank-charges)retrieved 2026-07-04 - T3[https://www.zambiamonitor.com/bank-of-zambia-cracks-down-on-unwarranted-charges-for-electronic-money-services/](https://www.zambiamonitor.com/bank-of-zambia-cracks-down-on-unwarranted-charges-for-electronic-money-services/)retrieved 2026-07-04 - T1[https://www.boz.zm/BankofZambiaCustomerComplaintsHandlingandResolutionDirectives1.pdf](https://www.boz.zm/BankofZambiaCustomerComplaintsHandlingandResolutionDirectives1.pdf)retrieved 2026-07-04 - T2[https://responsiblefinance.worldbank.org/content/dam/documents/responsible-finance/Zambia-Diagnostic-Review-V-II.pdf](https://responsiblefinance.worldbank.org/content/dam/documents/responsible-finance/Zambia-Diagnostic-Review-V-II.pdf) Applies beyond this jurisdiction (World Bank)retrieved 2026-07-04 - T2[https://epar.evans.uw.edu/wp-content/uploads/2024/08/EPAR_UW_324_DFS-Consumer-Protection_3.31.16.pdf](https://epar.evans.uw.edu/wp-content/uploads/2024/08/EPAR_UW_324_DFS-Consumer-Protection_3.31.16.pdf)retrieved 2026-07-04 ### W2Stablecoins & Digital Money1 gapProbableconfirmed 2026-07-04▾# No stablecoin-specific statute; crypto not legal tender; BoZ CBDC plan runs 2024-2026 including a pilot; Currency Directives 2025 reaffirm Kwacha as sole legal tender. Open gap — wpm-int-1 No W2 stablecoin/digital-money regime development was located for Zambia this cycle. no under-indexing note recorded Horizon · 2026 (± a year) Bank of Zambia CBDC framework and pilot phase (2024-2026 plan) Proposed · Tier 3 source Standing sub-brief · as of 8 July 2026 133 words · last cycle 2026-07-08 #### Stablecoins & Digital Money Zambia has no stablecoin-specific statute. Cryptocurrencies are not legal tender in Zambia; the Bank of Zambia Act vests exclusive note and coin issuance in the central bank, and Bank of Zambia has not issued any form of cryptocurrency to date. Bank of Zambia's plan calls for establishing a CBDC framework between 2024 and 2026, including implementation and supervision regulations plus a pilot exploring possible use cases, though named pilot use-cases have not yet been published. The Directive on Electronic Money Issuance, dated 14 July 2023, updates the 2018 National Payment Systems Directives on Electronic Money Issuance, governing e-money issuer authorisation and conduct. #### Outlook The CBDC pilot's named use-cases and the underlying customer-fund safeguarding mechanism for e-money issuers are the two clearest disclosure gaps to watch into the next cycle. Read full sub-brief · 133 words no periodic updates on record for this sub-brief Evidence 5 Sources and findings (5) - T1[https://www.boz.zm/faq.htm](https://www.boz.zm/faq.htm)retrieved 2026-07-04 - T1[https://www.boz.zm/directives.htm](https://www.boz.zm/directives.htm)retrieved 2026-07-04 - T1[https://fic.gov.zm/component/attachments/download/125](https://fic.gov.zm/component/attachments/download/125)retrieved 2026-07-04 - T3[https://cbdctracker.hrf.org/currency/zambia](https://cbdctracker.hrf.org/currency/zambia)retrieved 2026-07-04 - T1[https://www.boz.zm/Explanatory-Notes-on-the-Currency-Directives-2025.pdf](https://www.boz.zm/Explanatory-Notes-on-the-Currency-Directives-2025.pdf)retrieved 2026-07-04 ### W3Operational Resilience & Critical InfraProbableconfirmed 2026-07-04▾# Operational resilience now sits substantially under the Cyber Security Act 2025 and Cyber Crimes Act 2025, designating payment gateways/core banking as critical infrastructure with registration, localisation, audit and incident-reporting duties. Kept on Dataprotection.gi, not restated here: data and cloud switching obligations on service providers, including notice periods and charges. [Open this jurisdiction's page on Dataprotection.gi →](https://dataprotection.gi/jurisdictions/zambia/) Standing sub-brief · as of 8 July 2026 149 words · last cycle 2026-07-08 #### Operational Resilience & Critical Infrastructure Zambia's Cyber Security Act, 2025 designates banking and finance, including payment gateways and core banking systems, as critical information infrastructure subject to registration, data localisation, annual audits and incident-reporting to the new Zambia Cyber Security Agency, with non-compliance penalties up to ZMW1,200,000 and/or 10 years' imprisonment. Bank of Zambia was hit by a Hive ransomware attack in 2022, declining to pay the ransom and reporting minimal system damage, and suffered a Facebook account hack in July 2023. Following losses of over K111 million to online scammers, ZM-CIRT piloted a *707# short-code allowing citizens to report suspicious numbers, resulting in over 10,000 SIM deactivations in Q1 2025. #### Outlook Compliance-onboarding against the new critical-infrastructure regime is the immediate operational marker; how the Zambia Cyber Security Agency exercises its registration, localisation and audit powers over payment-gateway operators will be the clearest test of the law's practical bite. Read full sub-brief · 149 words no periodic updates on record for this sub-brief Evidence 6 Sources and findings (6) - T1[https://zambialii.org/akn/zm/act/2025/3/eng@2025-04-15](https://zambialii.org/akn/zm/act/2025/3/eng@2025-04-15)retrieved 2026-07-04 - T2[https://bowmanslaw.com/insights/zambia-new-laws-to-strengthen-cybersecurity-and-cybercrime-capacities/](https://bowmanslaw.com/insights/zambia-new-laws-to-strengthen-cybersecurity-and-cybercrime-capacities/)retrieved 2026-07-04 - T3[https://mpelembe.net/index.php/securing-the-cyberspace-the-impact-of-zambias-2025-cyber-laws-on-security-and-civil-liberties/](https://mpelembe.net/index.php/securing-the-cyberspace-the-impact-of-zambias-2025-cyber-laws-on-security-and-civil-liberties/)retrieved 2026-07-04 - T3[https://www.icnl.org/wp-content/uploads/Zambia-Five-Things-Cyber-Security-Act-2025-final.pdf](https://www.icnl.org/wp-content/uploads/Zambia-Five-Things-Cyber-Security-Act-2025-final.pdf)retrieved 2026-07-04 - T3[https://en.wikipedia.org/wiki/Bank_of_Zambia](https://en.wikipedia.org/wiki/Bank_of_Zambia)retrieved 2026-07-04 - T3[https://mpelembe.net/index.php/securing-the-cyberspace-the-impact-of-zambias-2025-cyber-laws-on-security-and-civil-liberties/](https://mpelembe.net/index.php/securing-the-cyberspace-the-impact-of-zambias-2025-cyber-laws-on-security-and-civil-liberties/)retrieved 2026-07-04 ### W4Scheme & Network ComplianceProbableconfirmed 2026-07-04▾# Domestic switch/directive framework governs ATM/POS/mobile transactions; ZIPSS modernised to ISO 20022 in 2023; international scheme compliance runs via global Visa/Mastercard rulebooks absent a bespoke domestic interchange statute. Standing sub-brief · as of 8 July 2026 108 words · last cycle 2026-07-08 #### Scheme & Network Compliance ZIPSS, Zambia's RTGS system, was upgraded and went live on 14 October 2023, transitioning to ISO 20022 messaging and changing system topology from Y-Copy to V-Mode. Debit-card industry participants must undergo PCI DSS certification before Visa or Mastercard will admit them to the network; the National Financial Switch at ZECHL, Visa and Mastercard are the major interconnecting payment companies. No dedicated Zambian interchange-fee statute distinct from these global scheme rulebooks was located. #### Outlook Scheme compliance in Zambia continues to run primarily through international Visa/Mastercard rulebooks rather than a bespoke domestic interchange statute; that structural gap is unlikely to close without a distinct legislative initiative. Read full sub-brief · 108 words no periodic updates on record for this sub-brief Evidence 4 Sources and findings (4) - T1[https://www.boz.zm/directives.htm](https://www.boz.zm/directives.htm)retrieved 2026-07-04 - T3[https://www.paymentcomponents.com/all-about-payments-in-africa/](https://www.paymentcomponents.com/all-about-payments-in-africa/)retrieved 2026-07-04 - T3[http://article.sapub.org/10.5923.j.rjbt.20240101.01.html](http://article.sapub.org/10.5923.j.rjbt.20240101.01.html)retrieved 2026-07-04 - T3[https://blog.miden.co/card-issuing-in-zambia](https://blog.miden.co/card-issuing-in-zambia)retrieved 2026-07-04 ### W5Payment Corridor DynamicsProbableconfirmed 2026-07-04▾# Principal cross-border rails are SADC-RTGS, COMESA REPSS, PAPSS and SADC TCIB; MNOs are opening new direct international mobile-money corridors. Standing sub-brief · as of 8 July 2026 115 words · last cycle 2026-09-21 #### Payment Corridor Dynamics Zambia joined the SADC-RTGS as a participant in September 2014, via BoZ and nine commercial banks, and the system interlinks with PAPSS and COMESA REPSS. PAPSS, launched January 2022, connects ten central banks including Zambia, supporting real-time local-currency settlement, though it has not yet disrupted entrenched correspondent-banking pathways. MTN Mobile Money Zambia launched a service enabling customers to send money directly from wallets to international bank accounts in the EU, UK and Canada, described as Zambia's first direct wallet-to-bank international transfer offering. #### Outlook The corridor picture is one of deepening regional-rail access alongside a newly opened mobile-money international channel; whether other mobile-network operators follow MTN's wallet-to-bank model is the marker to watch. Read full sub-brief · 115 words Periodic update · new data 2026-09-22 #### Payment Corridor Dynamics Zambia's mobile-money corridor has expanded sharply over the past five years, with transaction value growing from K105.8 billion in 2020 to K891.6 billion in 2025, an increase of more than eight times. This growth figure, sourced from an ITU workshop presentation delivered by a Bank of Zambia representative, is a Tier-3-sourced statistic without independent corroboration this cycle, and should be read as indicative of a strong growth trend rather than a precisely verified figure. The scale of the increase nonetheless signals continued deepening of mobile-money usage as a core domestic payment corridor in Zambia, running independently of the pending legislative consolidation under the National Payment System Act and the Banking and Financial Services Act, 2026, both of which remain uncommenced as of the most recent legal commentary available. The designated mobile-money issuers anchoring this corridor are Airtel, MTN and Zamtel, which continue to operate under designation provisions carried over from the prior National Payment Systems Act, Cap. 359 framework. The persistence of this three-issuer structure suggests that Zambia's mobile-money market has reached a degree of concentration among established telecom-affiliated issuers, a market structure that predates the 2026 legislative consolidation and is not itself altered by the still-uncommenced new Act. The corridor-growth figure and the underlying legislative consolidation are best read as two independent but potentially converging developments: market growth is proceeding at pace under the existing legal framework, and a wider licensing and market-access architecture is queued to apply once the National Payment System Act's provisions for payment service providers take effect. Whether the new licensing, designation and authorisation provisions will alter the competitive dynamics among the existing three designated issuers, or open space for additional entrants under the new authorisation categories, is not addressed in the sources available this cycle and remains an open question for the corridor's future development. #### Outlook The growth trajectory in Zambia's mobile-money transaction value is worth monitoring for continuation into 2026 and 2027 figures once published, and for whether the pending commencement of the National Payment System Act's licensing and authorisation provisions for payment service providers introduces any change to the current three-issuer designated structure anchored by Airtel, MTN and Zamtel. A Tier-1 or Tier-2 corroboration of the transaction-value growth figures reported via the ITU/Bank of Zambia presentation would materially strengthen confidence in the scale of this corridor's expansion beyond the current Uncertain confidence tier. Evidence 6 Sources and findings (6) - T1[https://www.boz.zm/regional-payment-systems](https://www.boz.zm/regional-payment-systems) - T1[https://www.boz.zm/regional-payment-systems.htm](https://www.boz.zm/regional-payment-systems.htm)retrieved 2026-07-04 - T3[https://blog.useaccrue.com/the-future-of-cross-african-payments-opportunities-and-regulatory-pinch-points/](https://blog.useaccrue.com/the-future-of-cross-african-payments-opportunities-and-regulatory-pinch-points/)retrieved 2026-07-04 - T3[https://www.paymentcomponents.com/all-about-payments-in-africa/](https://www.paymentcomponents.com/all-about-payments-in-africa/)retrieved 2026-07-04 - T3[https://developingtelecoms.com/telecom-technology/financial-services/19699-two-zambian-operators-announce-mobile-money-initiatives.html](https://developingtelecoms.com/telecom-technology/financial-services/19699-two-zambian-operators-announce-mobile-money-initiatives.html)retrieved 2026-07-04 - T3[https://blog.useaccrue.com/the-future-of-cross-african-payments-opportunities-and-regulatory-pinch-points/](https://blog.useaccrue.com/the-future-of-cross-african-payments-opportunities-and-regulatory-pinch-points/)retrieved 2026-07-04 ### W6Industry Structure & Commercial1 judgmentProbableconfirmed 2026-07-04▾# Oligopolistic mobile/telecom market layered on a concentrated 19-bank sector; ~50-69 active fintechs; Airtel Zambia crossed $1bn market cap June 2026. Key judgment — Probable · impact ELEVATED Zambia's payments market continues to grow materially (84 licensed PSPs/fintechs in 2024 versus 37 in 2016, K486.3bn mobile-money transaction value), suggesting commercial pressure for the new licensing framework to accommodate an already-large non-bank PSP sector. claims: none recorded Standing sub-brief · as of 8 July 2026 131 words · last cycle 2026-10-25 #### Industry Structure & Commercial Dynamics Zambia's mobile-money market is oligopolistic: Airtel Zambia holds roughly 48% subscriber share and MTN Zambia 33-35%, with state-owned Zamtel the remainder, and both major incumbents extend mobile-money ecosystems into savings, loans and insurance. Airtel Networks Zambia Plc surpassed $1 billion market capitalisation on the Lusaka Securities Exchange on 8 June 2026, reflecting investor confidence in its data and mobile-money portfolio. Standard Chartered is reported to be exploring a potential sale of its wealth and retail banking units in Botswana, Uganda and Zambia, signalling a possible market-structure shift among incumbent international banks; the report is unconfirmed and deal terms are undisclosed. #### Outlook Whether the rumoured Standard Chartered divestiture materialises is the clearest market-structure marker for the next cycle, set against continuing mobile-money-led consolidation among the incumbent telecoms. Read full sub-brief · 131 words Periodic update · new data 2026-10-25 #### Industry Structure & Commercial Dynamics Zambia's payments industry has expanded substantially in scale even as its governing legal framework has remained largely unchanged in detail until the recent legislative moves. The Bank of Zambia's own June 2026 position paper on Open Finance records that the number of licensed payment service providers and fintechs rose from 37 in 2016 to 84 in 2024, more than doubling over an eight-year period. The same paper records mobile-money transaction value of K486.3 billion and 12.3 million active mobile-money accounts in 2024, figures that place Zambia among the more mobile-money-intensive markets in the region on an active-account basis. This growth occurred under a National Payment System Act that, per Parliament's own committee report on its successor Bill, was primarily system-focused and did not specify in detail licensing requirements, market-conduct rules or governance standards for individual providers, meaning the sector's structural expansion outpaced the granularity of its governing statute. Commercial interconnection between bank and non-bank payment infrastructure continues to develop. A mid-2026 partnership between Airtel Money and Stanbic Bank introduced Airtel Money payments on Stanbic's point-of-sale machines, allowing customers to pay directly from mobile wallets at physical points of sale. This kind of bank-mobile money interoperability is a natural commercial response to a market where mobile-money account penetration is already high, since it extends mobile-wallet balances into a wider set of physical commercial transactions without requiring a cash conversion step. The structural significance of the forthcoming Banking and Financial Services Act, 2026 and National Payment System Act, 2026 for industry structure lies in how they will formalise oversight of an already-large non-bank payments sector. Consolidating banks, microfinance institutions, moneylenders, fintechs and e-money issuers under a single Bank of Zambia supervisory framework, once commenced, will apply uniform governance and conduct standards across a sector that has to date grown under comparatively light-touch, system-level rather than provider-level regulation. For an industry that has already reached 84 licensed providers and a mobile-money user base in the low double-digit millions, this represents a formalisation of market structure rather than a contraction or consolidation of participants. #### Outlook The commercial trajectory for Zambia's payments industry remains one of continued non-bank-led growth, with mobile-money transaction value and active-account figures from 2024 indicating a mature and high-penetration market even ahead of the more detailed licensing regime's commencement. Bank-mobile money interoperability partnerships of the kind seen between Airtel Money and Stanbic Bank are likely to continue as a competitive response to this market structure, extending mobile-wallet utility into physical commerce. Once the National Payment System Act, 2026 and Banking and Financial Services Act, 2026 commence, expected around the first quarter of 2027 on current estimates, the formalisation of governance and conduct standards across this already-large provider population will be the primary structural event to track, rather than any near-term change in the number or type of market participants. Evidence 5 Sources and findings (5) - T3[https://www.mordorintelligence.com/industry-reports/zambia-telecom-mno-market](https://www.mordorintelligence.com/industry-reports/zambia-telecom-mno-market)retrieved 2026-07-04 - T3[https://innovation-village.com/airtel-zambia-crosses-the-1-billion-market-capitalisation-mark-powered-by-data-and-mobile-money/](https://innovation-village.com/airtel-zambia-crosses-the-1-billion-market-capitalisation-mark-powered-by-data-and-mobile-money/)retrieved 2026-07-04 - T3[https://www.zambiainvest.com/finance/banking/](https://www.zambiainvest.com/finance/banking/)retrieved 2026-07-04 - T3[https://fintechnews.africa/46245/fintechzambia/fintech-in-zambia-2026-market-overview/](https://fintechnews.africa/46245/fintechzambia/fintech-in-zambia-2026-market-overview/)retrieved 2026-07-04 - T3[https://www.fintechfutures.com/keyword/zambia](https://www.fintechfutures.com/keyword/zambia)retrieved 2026-07-04 ### W7Legal & LitigationProbableconfirmed 2026-07-04▾# Payments-legal infrastructure defined by BoZ Act 2022 penalty powers rather than developed litigation; parliamentary scrutiny flagged NPS Bill 2025/Corporate Insolvency Act overlap; civil society criticised Cyber Security Agency oversight. Standing sub-brief · as of 8 July 2026 125 words · last cycle 2026-07-08 #### Legal & Litigation A parliamentary committee reviewing the National Payment System Bill 2025 flagged that its restructuring and insolvency provisions for payment service providers could create procedural uncertainty against the existing Corporate Insolvency Act, and recommended harmonisation. No private enforcement actions are available in Zambia's AML/CFT space; only the Financial Intelligence Centre, Drug Enforcement Commission, Anti-Corruption Commission and Police hold enforcement powers. The Law Association of Zambia and a wider civil-society coalition criticised the Cyber Security Agency's placement under the Office of the President as lacking independent governance and parliamentary oversight. #### Outlook Named payments-specific court-case citations remain absent from available sources, a standing research gap; how the insolvency-harmonisation recommendation is handled during the National Payment System Act 2026 commencement process is the marker to watch. Read full sub-brief · 125 words no periodic updates on record for this sub-brief Evidence 5 Sources and findings (5) - T1[https://zambialii.org/akn/zm/act/2022/5](https://zambialii.org/akn/zm/act/2022/5)retrieved 2026-07-04 - T2[https://www.mondaq.com/government-public-sector/1373122/anti-money-laundering-comparative-guide](https://www.mondaq.com/government-public-sector/1373122/anti-money-laundering-comparative-guide)retrieved 2026-07-04 - T1[https://www.parliament.gov.zm/sites/default/files/documents/committee_reports/REPORT%20OF%20THE%20COMMITTEE%20ON%20NATIONAL%20ECONOMY,%20TRADE%20AND%20LABOUR%20MATTERS%20ON%20THE%20NATIONAL%20PAYMENT%20SYSTEM%20BILL,%20N.A.B%20NO.%2032%200F%202025%20FOR%20THE%205TH%20SESSION%20OF%20THE%2013TH%20NATIONAL%20ASSEMBLY.pdf](https://www.parliament.gov.zm/sites/default/files/documents/committee_reports/REPORT%20OF%20THE%20COMMITTEE%20ON%20NATIONAL%20ECONOMY,%20TRADE%20AND%20LABOUR%20MATTERS%20ON%20THE%20NATIONAL%20PAYMENT%20SYSTEM%20BILL,%20N.A.B%20NO.%2032%200F%202025%20FOR%20THE%205TH%20SESSION%20OF%20THE%2013TH%20NATIONAL%20ASSEMBLY.pdf)retrieved 2026-07-04 - T3[https://payatlas.com/regulator/boz-4606](https://payatlas.com/regulator/boz-4606)retrieved 2026-07-04 - T3[https://globalnetworkinitiative.org/gni-statement-on-zambias-new-cyber-laws-a-blow-to-freedom-of-expression-and-privacy/](https://globalnetworkinitiative.org/gni-statement-on-zambias-new-cyber-laws-a-blow-to-freedom-of-expression-and-privacy/)retrieved 2026-07-04 ### W8Merchant Acquiring & RiskProbableconfirmed 2026-07-04▾# Card acquiring/issuing restricted to BoZ-licensed banks; fintechs access rails via BIN-sponsorship; POS share of card transactions growing; acceptance concentrated in urban/tourist centres. Standing sub-brief · as of 8 July 2026 85 words · last cycle 2026-07-08 #### Merchant Acquiring & Risk Only Bank of Zambia-licensed banks are authorised to issue payment cards in Zambia; fintechs such as Union54 access card rails via bank BIN-sponsorship arrangements. POS transactions represented 64% of all card transactions in 2022, up from 51% in 2021, though acceptance remains concentrated in urban and tourist centres with cash dominant elsewhere. #### Outlook Continued POS-share growth alongside a persistently bank-only issuing structure suggests fintech card products will keep depending on sponsorship arrangements rather than direct issuing licences in the near term. Read full sub-brief · 85 words no periodic updates on record for this sub-brief Evidence 4 Sources and findings (4) - T3[https://blog.miden.co/card-issuing-in-zambia](https://blog.miden.co/card-issuing-in-zambia)retrieved 2026-07-04 - T3[https://visa.co.za/partner-with-us/pci-dss-compliance-information.html](https://visa.co.za/partner-with-us/pci-dss-compliance-information.html)retrieved 2026-07-04 - T3[https://www.transfi.com/blog/popular-local-payment-methods-and-solutions-in-zambia](https://www.transfi.com/blog/popular-local-payment-methods-and-solutions-in-zambia)retrieved 2026-07-04 - T3[https://www.safari-memories.com/en/destinations/zambia/explore/introduction-to-currency-and-payment-methods-in-zambia](https://www.safari-memories.com/en/destinations/zambia/explore/introduction-to-currency-and-payment-methods-in-zambia)retrieved 2026-07-04 ### W9Product Innovation & Market Development1 gapProbableconfirmed 2026-07-04▾# Innovation architecture rests on BoZ Regulatory Sandbox (2021) and SEC sandbox, NFIS interoperability push, BoZ CBDC plan, and product launches from MTN, Airtel Money, Union54 and Lupiya. Open gap — wpm-int-2 No W9 product-innovation-specific in-window change was located; awaiting primary source. no under-indexing note recorded Horizon · 2028-Q4 (± more than a year) National Financial Inclusion Strategy II (NFIS II) policy-period completion In force · Tier 3 source Horizon · 2028 (± more than a year) National Financial Inclusion Strategy II (NFIS II 2024-2028) completion horizon In force · Tier 3 source Standing sub-brief · as of 8 July 2026 110 words · last cycle 2026-08-25 #### Product Innovation & Market Development Bank of Zambia's Guidelines for Conducting Regulatory Sandbox, effective 1 April 2021, allow fintech companies to test products under regulatory supervision, complemented by a parallel SEC capital-markets sandbox. Union54, founded 2020 in Lusaka, provides a debit-card-issuing API allowing software companies to issue debit cards without needing a bank or card processor directly. Airtel Money Zambia launched a digital community-savings-group product allowing groups to handle deposits, withdrawals and member contributions with real-time transaction tracking. #### Outlook The sandbox architecture and steady product launches from telco-affiliated and independent fintechs point to continued innovation activity, running alongside the National Financial Inclusion Strategy II's interoperability and inclusion targets through 2028. Read full sub-brief · 110 words Periodic update · new data 2026-09-08 #### Product Innovation & Market Development Zambia's mobile money market continues to grow sharply: transaction value reached K891.6 billion in 2025, up from K105.8 billion in 2020, an approximately eight-and-a-half-fold increase over five years. This trajectory, evidenced through a Bank of Zambia presentation at an ITU workshop, underscores mobile money's centrality to Zambia's payments infrastructure. The finding is assessed at Assessed confidence on a Tier-2 source; no further product-innovation-specific development was evidenced this cycle. #### Outlook The open question is how the new National Payment System Act's authorisation regime, and the Banking and Financial Services Act's broader consolidation, will interact with the mobile-money segment specifically, given its outsized share of transaction value. Whether Bank of Zambia guidance addresses mobile-money-adjacent payment service providers as a distinct category under the new licensing architecture is the marker to watch next cycle. Evidence 6 Sources and findings (6) - T1[https://www.boz.zm/directives.htm](https://www.boz.zm/directives.htm)retrieved 2026-07-04 - T2[https://www.afriwise.com/blog/regulation-of-fintech-in-zambia---a-legal-guide](https://www.afriwise.com/blog/regulation-of-fintech-in-zambia---a-legal-guide)retrieved 2026-07-04 - T3[https://fintechnews.africa/46245/fintechzambia/fintech-in-zambia-2026-market-overview/](https://fintechnews.africa/46245/fintechzambia/fintech-in-zambia-2026-market-overview/)retrieved 2026-07-04 - T3[https://cbdctracker.hrf.org/currency/zambia](https://cbdctracker.hrf.org/currency/zambia)retrieved 2026-07-04 - T3[https://developingtelecoms.com/telecom-technology/financial-services/19699-two-zambian-operators-announce-mobile-money-initiatives.html](https://developingtelecoms.com/telecom-technology/financial-services/19699-two-zambian-operators-announce-mobile-money-initiatives.html)retrieved 2026-07-04 - T3[https://www.startupblink.com/top-startups/zambia](https://www.startupblink.com/top-startups/zambia)retrieved 2026-07-04 ### W10Consumer Protection & APP FraudProbableconfirmed 2026-07-04▾# Consumer protection runs through BoZ unwarranted-charges/complaints directives, backstopped by a weak voluntary code and underused CCPC/Small Claims routes; APP-style fraud risk politically salient but with no dedicated reimbursement regime. Standing sub-brief · as of 8 July 2026 139 words · last cycle 2026-07-08 #### Consumer Protection & APP Fraud Consumers levied an unwarranted charge should first raise the matter with their financial service provider, and if unresolved, escalate directly to Bank of Zambia, under the framework set by the Customer Complaints Handling and Resolution Directives. The Small Claims Court has jurisdiction over consumer complaints on banking and financial services but is understood not to be used in practice for such complaints; the World Bank recommends an independent external dispute-resolution scheme. Cybercrime including phishing and social-media fraud has cost the Zambian economy over K111 million, providing political momentum for the 2025 cyber-law framework, though no dedicated APP-fraud mandatory-reimbursement regime exists. #### Outlook The absence of a UK-PSR-style mandatory reimbursement regime, set against a politically salient scam wave and thin consumer-protection resourcing, is the clearest structural vulnerability in this module to track into the next cycle. Read full sub-brief · 139 words no periodic updates on record for this sub-brief Evidence 5 Sources and findings (5) - T1[https://www.boz.zm/financial-stability/bank-charges](https://www.boz.zm/financial-stability/bank-charges)retrieved 2026-07-04 - T1[https://www.boz.zm/faq.htm](https://www.boz.zm/faq.htm)retrieved 2026-07-04 - T2[https://responsiblefinance.worldbank.org/content/dam/documents/responsible-finance/Zambia-Diagnostic-Review-V-II.pdf](https://responsiblefinance.worldbank.org/content/dam/documents/responsible-finance/Zambia-Diagnostic-Review-V-II.pdf) Applies beyond this jurisdiction (World Bank)retrieved 2026-07-04 - T3[https://www.fnbzambia.co.zm/contact-us/ComplimentsAndComplaints.html](https://www.fnbzambia.co.zm/contact-us/ComplimentsAndComplaints.html)retrieved 2026-07-04 - T3[https://mpelembe.net/index.php/securing-the-cyberspace-the-impact-of-zambias-2025-cyber-laws-on-security-and-civil-liberties/](https://mpelembe.net/index.php/securing-the-cyberspace-the-impact-of-zambias-2025-cyber-laws-on-security-and-civil-liberties/)retrieved 2026-07-04 ### W11AML/CFT & Financial CrimeSourced from Sentinel.gi ↗Confirmedconfirmed 2026-07-04▾# AML/CFT posture carried via the FIC-centred framework, PPMLA, Anti-Terrorism/Proliferation legislation and BoZ 2017 AML/CFT/PF Directives; Zambia is an ESAAMLG member remaining in FATF enhanced follow-up. Standing sub-brief · as of 8 July 2026 156 words · last cycle 2026-07-08 #### AML/CFT & Financial Crime This module is Sentinel-fed; the Financial Intelligence Centre, established under the FIC Act No.46 of 2010, is the sole designated agency for receiving, analysing and disseminating suspicious transaction reports, with reporting entities including commercial banks, non-bank financial institutions and DNFBPs. A 2022 FATF/ESAAMLG follow-up report found progress on some technical-compliance deficiencies but downgraded Recommendations 2, 5 and 7, and Zambia remains in enhanced follow-up. The Financial Intelligence Centre is the designated AML/CFT supervisor for Virtual Asset Service Providers absent a dedicated VASP licensing regulator, applying FATF Recommendation 15 requirements including suspicious-transaction-report filing on attempted transactions. Per methodology, this monitor carries the Sentinel feed as provenance and does not perform original illicit-finance analysis; see the Financial Intelligence Monitor for that assessment. #### Outlook Zambia's enhanced-follow-up status under FATF/ESAAMLG, and the absence of a dedicated VASP licensing regulator, are the two AML/CFT markers to watch, both routed to the Financial Intelligence Monitor for substantive analysis. Read full sub-brief · 156 words no periodic updates on record for this sub-brief Evidence 5 Sources and findings (5) - T1sentinel.fic.gov.zm/component/attachments/download/125 - T?FIM (sentinel.gi) per-JID baseline profile — Zambia — Zambia's AML/CFT regime rests on the FIC Act and 2017 Companies Act, assessed by ESAAMLG's 2019 MER and follow-up reports (2022, 2024). Zambia is not FATF grey-listed but remains in enhanced follow-up with unresolved technical-compliance gaps on beneficial ownership, DNFBP supervision, and TF/PF targeted financial sanctions implementation. - T?FIM (sentinel.gi) gaps_register_cumulative (issue FIM-BASE-GAP-005) — Gap: sourcing-thinness - T?FIM (sentinel.gi) gaps_register_cumulative (issue FIM-BASE-GAP-004) — Gap: absent-field-provenance - T?FIM (sentinel.gi) gaps_register_cumulative (issue FIM-BASE-GAP-001) — Gap: political-constraint ### W12Correspondent Banking, Settlement & AccessProbableconfirmed 2026-07-04▾# Correspondent banking access appears stable; no lost relationships in 3 years per 2025 US ICS; SADC-RTGS/PAPSS reduce reliance on traditional correspondent chains; all banks incorporate locally. Standing sub-brief · as of 8 July 2026 129 words · last cycle 2026-09-28 #### Correspondent Banking, Settlement & Access The US Embassy reports no lost correspondent banking relationships over the past three years and none currently in jeopardy, with many Zambian banks maintaining active correspondent relationships. All banks operating in Zambia must incorporate locally; there are no local retail branches of foreign banks, and Citibank Zambia Limited, a wholly-owned Citicorp New York subsidiary, provides correspondent banking services domestically. Regional settlement-system participation across SADC-RTGS, PAPSS and COMESA REPSS interlinking reduces Zambian banks' reliance on correspondent banking for regional cross-border settlement, lowering transaction costs and settlement times. #### Outlook The bank-versus-non-bank access asymmetry is this module's analytical spine: correspondent banking remains a bank-only channel in Zambia, while regional rails increasingly substitute for correspondent chains on intra-African corridors, a trend likely to continue through the next cycle. Read full sub-brief · 129 words Periodic update · new data 2026-09-29 #### Correspondent Banking, Settlement & Access The National Payment System Act, 2026 (Act No. 5 of 2026) recasts the statutory basis on which the Bank of Zambia regulates and supervises the National Payment System as a whole, replacing the 2007 National Payment Systems Act. Because this Act governs the statutory basis for payment-system participation itself, it bears directly on the settlement-access question that is this module's analytical spine: the bank-versus-non-bank access asymmetry in the national payment system now sits under a re-legislated supervisory framework rather than the prior 2007-era statute. The Banking and Financial Services Act, 2026's parallel consolidation of financial-sector regulation under Bank of Zambia oversight, on a proportionality principle, is relevant here because settlement and correspondent access questions in Zambia are ultimately mediated through the same central bank that now holds consolidated authority over both the payment-system statute and the banking statute. A proportionality-based licensing approach across both statutes could, in principle, affect how non-bank payment participants access settlement relative to bank participants, though no implementing detail establishing the practical shape of that access asymmetry was identified this cycle. No specific correspondent-banking relationship change, de-risking event, or settlement-mechanism change was identified this cycle; the material development is the re-legislation of the statutory basis itself rather than any change to a specific settlement arrangement or corridor. #### Outlook Watch for BoZ implementing regulations under the National Payment System Act, 2026 that would specify participation criteria for the national payment system, since these would be the first concrete indication of how the bank-versus-non-bank settlement-access asymmetry is treated under the recast statutory basis. Evidence 5 Sources and findings (5) - T1[https://www.state.gov/reports/2025-investment-climate-statements/zambia](https://www.state.gov/reports/2025-investment-climate-statements/zambia)retrieved 2026-07-04 - T2[https://www.trade.gov/country-commercial-guides/zambia-trade-financing](https://www.trade.gov/country-commercial-guides/zambia-trade-financing)retrieved 2026-07-04 - T1[https://www.bis.org/cpmi/paysys/Zambia.pdf](https://www.bis.org/cpmi/paysys/Zambia.pdf) Applies beyond this jurisdiction (Basel Committee)retrieved 2026-07-04 - T1[https://www.boz.zm/regional-payment-systems](https://www.boz.zm/regional-payment-systems) - T1[https://www.state.gov/reports/2025-investment-climate-statements/zambia](https://www.state.gov/reports/2025-investment-climate-statements/zambia)retrieved 2026-07-04 ### W13Commercial Intelligence (M&A, Investment & Product)1 gapProbableconfirmed 2026-07-04▾# Trailing-12-month activity led by Lupiya's Series A, Airtel Zambia's LuSE market-cap milestone, a Western Union/Zoona/Chipper Cash partnership, MTN MoMo's new international-transfer product, and a rumoured Standard Chartered Zambia-unit divestiture. Open gap — wpm-int-3 No W13 commercial event dated within the 2026-10-11 to 2026-10-25 window was located for Zambian payment/fintech companies. no under-indexing note recorded Standing sub-brief · as of 8 July 2026 199 words · last cycle 2026-07-08 #### Commercial Intelligence Digital bank Lupiya secured US$11.25 million in a Series A round, reported around 27 February 2026, to broaden its product offering, strengthen technology infrastructure, and support expansion into Southern and East Africa. Airtel Networks Zambia Plc surpassed $1 billion market capitalisation on the Lusaka Securities Exchange on 8 June 2026, driven partly by its mobile-money and digital-financial-services business; this milestone is logged here as a market event rather than as a scheme commercial_event, since it does not fit the closed event-type taxonomy. Western Union, Zoona and Chipper Cash launched a partnership for international money-transfer services covering Zambia, announced around 30-31 July 2025, with deal value not publicly disclosed. MTN Mobile Money Zambia launched a wallet-to-international-bank-account transfer service covering the EU, UK and Canada, reported in early February 2026. Standard Chartered is reported to be exploring a potential sale of its wealth and retail banking units in Botswana, Uganda and Zambia; deal value and timing are not publicly disclosed as of this baseline. #### Outlook Trailing-twelve-month commercial activity is dominated by mobile-money and telco-linked expansion rather than traditional bank mergers and acquisitions, though the rumoured Standard Chartered divestiture bears watching as the one potential bank-sector deal in the pipeline. Read full sub-brief · 199 words no periodic updates on record for this sub-brief Evidence 5 Sources and findings (5) - T3[https://fintechnews.africa/46245/fintechzambia/fintech-in-zambia-2026-market-overview/](https://fintechnews.africa/46245/fintechzambia/fintech-in-zambia-2026-market-overview/)retrieved 2026-07-04 - T3[https://innovation-village.com/airtel-zambia-crosses-the-1-billion-market-capitalisation-mark-powered-by-data-and-mobile-money/](https://innovation-village.com/airtel-zambia-crosses-the-1-billion-market-capitalisation-mark-powered-by-data-and-mobile-money/)retrieved 2026-07-04 - T3[https://tracxn.com/d/geographies/zambia/__aRcH8lYOC74CSa9mr7vgyLFQ7-kjiAhbM4KLW-bhH3A](https://tracxn.com/d/geographies/zambia/__aRcH8lYOC74CSa9mr7vgyLFQ7-kjiAhbM4KLW-bhH3A)retrieved 2026-07-04 - T3[https://developingtelecoms.com/telecom-technology/financial-services/19699-two-zambian-operators-announce-mobile-money-initiatives.html](https://developingtelecoms.com/telecom-technology/financial-services/19699-two-zambian-operators-announce-mobile-money-initiatives.html)retrieved 2026-07-04 - T3[https://www.fintechfutures.com/keyword/zambia](https://www.fintechfutures.com/keyword/zambia)retrieved 2026-07-04 No modules match. 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