Interoperability Between Cameroon Mobile Money & Banking Rails: Regulatory & Contract Considerations

As fintechs push for cross-wallet payments, lawyers must closely track regulatory guidance on interoperability, licensing implications, and the structuring of interbank–telecom partnerships. In Cameroon, where mobile money has become a dominant retail payment channel, interoperability is no longer a technological aspiration—it is a regulatory and commercial imperative.

1.⁠ ⁠The Context: From Parallel Systems to Connected Rails

For over a decade, Cameroon’s payment ecosystem has operated through two largely parallel rails:

• Banking rails, supervised under the CEMAC monetary framework by BEAC and COBAC, supporting traditional accounts, card systems, and interbank transfers.
• Mobile money rails, operated primarily by telecom-affiliated electronic money issuers, enabling wallet-based transactions for millions of users.

While both systems have expanded financial inclusion, fragmentation persists. Limited interoperability between wallets, and between wallets and bank accounts, creates friction for SMEs, e-commerce operators, and cross-border traders within CEMAC.

The next phase of fintech growth depends on connecting these rails securely, competitively, and in compliance with regional regulation.

2.⁠ ⁠Regulatory Framework: Key Legal Considerations

Interoperability in Cameroon sits at the intersection of banking regulation, electronic money rules, and payment system oversight.

(a) BEAC Oversight and Payment System Regulation

BEAC, as the regional central bank, regulates payment systems and electronic money issuance in the CEMAC zone. Any interoperability mechanism whether through a central switch, API-based integration, or bilateral clearing arrangement must align with:

• Electronic money regulations
• Payment system authorization requirements
• Settlement and clearing rules
• Prudential safeguards for float accounts

Fintechs that are not licensed banks or approved electronic money institutions cannot independently operate clearing systems without regulatory approval.

(b) COBAC and Prudential Implications

Where banks are involved in wallet-bank integrations, COBAC rules on:

• Risk management
• Capital adequacy
• AML/CTF compliance
• Outsourcing and third-party risk become central.

Interoperability arrangements may qualify as material outsourcing or strategic partnerships, triggering enhanced oversight.

(c) AML/CTF and KYC Alignment

Cross-wallet and wallet-to-bank transfers increase transaction velocity and complexity. Legal advisors must assess:

• Harmonization of KYC tiers between banks and mobile money operators
• Suspicious transaction reporting responsibilities
• Data-sharing protocols compliant with AML obligations

Regulatory arbitrage risks arise if one platform maintains weaker onboarding controls than the other.

(d) Data Protection and Cybersecurity

Interoperability necessarily involves API integrations and data exchange. Contractual frameworks must reflect:

• Data protection compliance (where applicable under national frameworks)
• Liability allocation for data breaches
• Incident reporting procedures
• Cybersecurity audit rights

3.⁠ ⁠Licensing Implications for Fintechs

As fintech startups advocate for cross-wallet solutions and aggregation platforms, a core question arises:

Is the fintech merely a technical service provider, or is it performing a regulated payment function?

Depending on structure, a fintech facilitating interoperability may be viewed as:

• A technical switch operator
• A payment service provider
• An electronic money distributor
• A regulated financial intermediary

Each classification carries different licensing consequences under BEAC/COBAC rules. Structuring the model properly at the outset is critical to avoid enforcement exposure.

 4.⁠ ⁠Contractual Architecture: Negotiating Interbank–Telecom Partnerships

Interoperability is ultimately implemented through contracts. Lawyers advising banks, telecom operators, or fintech aggregators should pay particular attention to:

 (a) Revenue-Sharing and Fee Allocation

• Interchange fees
• Transaction processing fees
• Float management revenue
• FX margins for cross-border transactions

The economics must reflect operational risk allocation and regulatory capital costs.

(b) Risk Allocation and Indemnities

Key questions include:

• Who bears liability for failed transactions?
• Who absorbs fraud losses?
• How are chargebacks handled?
• What happens in case of regulatory sanctions triggered by one party’s non-compliance?

 (c) Governance and Dispute Resolution

Given the systemic importance of payment infrastructure, contracts should clearly define:

• Operational service levels (SLAs)
• Escalation procedures
• Audit rights
• Termination triggers linked to regulatory breaches

(d) Regulatory Change Clauses

Because CEMAC payment regulation continues to evolve, agreements must anticipate:

• Changes in licensing requirements
• Mandatory interoperability directives
• Centralized switching mandates

Flexibility clauses can prevent costly renegotiations.

5.⁠ ⁠Competition Law and Market Structure

Interoperability can promote financial inclusion but poorly structured arrangements may raise competition concerns.

Exclusive arrangements between dominant telecom operators and specific banks may restrict market access for smaller fintech players. Regulators may scrutinize:

• Anti-competitive exclusivity clauses
• Discriminatory access pricing
• Refusal to deal in essential infrastructure contexts

Lawyers should therefore integrate competition risk assessments into partnership negotiations.

6.⁠ ⁠The Strategic Outlook

Interoperability is essential to unlocking:

• SME access to digital finance
• Seamless merchant payments
• Cross-border trade within CEMAC and under AfCFTA
• Digital public service payments

For Cameroon to consolidate its position as a fintech leader in Central Africa, regulatory clarity and balanced contractual frameworks will be key.

As fintechs push for cross-wallet payments, legal advisors must remain proactive, monitoring regulatory guidance, anticipating licensing implications, and structuring bank–telecom partnerships that are compliant, bankable, and future-proof.

Interoperability is not merely a technical integration. It is a legal architecture that will shape the next phase of Cameroon’s digital financial ecosystem.