In brief
- From 2 November 2026 the maximum balance per client and issuer rises from 2 to 4 million FCFA under BCEAO instruction no. 020.
- Domestic person-to-person transfers up to 8,000 FCFA a day per user and institution are free and must run through the PI-SPI platform.
- The same rules will apply to cross-border transfers within the WAEMU from 1 June 2027.
The Euro-American Committee of Digital Law - CEA Digital Law is following a reform that takes effect today, 2 November 2026, in the West African Economic and Monetary Union (WAEMU): the Banque centrale des États de l’Afrique de l’Ouest (BCEAO) is raising mobile money limits and making small domestic transfers free. It matters because it affects eight countries and millions of digital finance users.
Two BCEAO decisions
According to OSIRIS, reporting on 31 October 2026, the changes stem from two decisions. The first is instruction no. 020 of 8 October 2026, which amends the 2015 text governing electronic money issuers. The second is a communiqué of 2 October 2026 revising the pricing conditions of the interoperable PI-SPI platform, one year after its launch.
Higher limits for individuals
The instruction raises the maximum balance a client may hold across all accounts with one issuer from 2 to 4 million FCFA. Cumulative monthly top-ups rise from 10 to 15 million FCFA. Exceeding these thresholds is possible only with the central bank’s prior authorisation, and professional distributors and merchants are outside the caps.
The text also governs how client funds are placed: at least 65% of the backing assets must be held in sight deposits, so that withdrawals can be honoured at any time.
Free transfers and mandatory use of PI-SPI
From today, interoperable electronic money transactions within the WAEMU must go through PI-SPI. Domestic transfers between individuals are free as long as the daily total does not exceed 8,000 FCFA per user and per institution, with no cap on the number of operations. Above that, institutions may charge between 0 and 0.8% of the amount excluding tax. Receiving money remains free. The same rules will apply to cross-border transfers within the WAEMU from 1 June 2027. Cash withdrawals at agents are not covered and operators remain free to price them.
Some issuers, such as MTN Mobile Money in Benin, have already informed their customers. How each operator, in Senegal for instance, will price transfers above the free threshold remains to be seen.
Our view at CEA Digital Law
A single rulebook for eight states reduces fragmentation and is good regulatory practice. Routing payments through a public interoperable platform strengthens competition among operators and eases supervision. We suggest three points to watch:
- Transparency: clear, comparable fees in accessible languages, so users know when charges begin.
- User protection: swift complaint mechanisms and fraud rules, since higher balances mean greater exposure.
- Data and cybersecurity: concentrating flows in PI-SPI calls for robust personal data protection and resilience standards.
Other regions of Africa, Latin America and the Caribbean, and Europe, each with their own instant payment systems, can watch how free micropayments affect financial inclusion and issuers’ business models. Public data will be valuable for assessing the results.
Sources
CEA Digital Law
Boletim
Eventos, notícias e análises sobre direito digital, no seu e-mail. Só quando houver novidades.
