Fintech & payments regulation in Botswana (2026)

The Banking Act 2023 formally commenced, introducing risk-based prudential regulation, mandatory board governance committees, a new bank-resolution regime, and alignment with Basel and IFRS standards. It prohibits foreign bank branches and extends oversight to cross-border entities, modernising the institutional framework within which payment-bank and fintech licences sit.

The revised Non-Bank Financial Institutions Regulatory Authority Act took effect, broadening NBFIRA's powers to license and supervise fintech firms, virtual asset service providers, and financial conglomerates under a 'same activity, same risk, same regulation' principle. It added provisions for key-person approvals and conglomerate-level supervision.

The Bank of Botswana launched a formal regulatory sandbox allowing innovators to trial new payment products and fintech services under supervised conditions. The sandbox operationalised the Digitalisation and Innovation Hub's mandate and gave non-bank applicants a pathway to test products before seeking full EPS licences.

The central bank created a dedicated unit to monitor local and global fintech developments and initiated development of a National Fintech Strategy targeted for completion by end-2024. This marked a shift from reactive licensing to proactive ecosystem engagement, including fintech landscape mapping surveys.

Parliament enacted the Virtual Assets Act, requiring every cryptocurrency exchange and virtual asset service provider targeting Botswana residents to obtain an NBFIRA licence regardless of where they are domiciled. Unlicensed operators face fines up to P250,000 or five years imprisonment; the Act directly addressed the VASP gap flagged by FATF at Botswana's 2021 exit review.

The Bank of Botswana issued its first comprehensive operational guidelines for EPS licence applicants, detailing incorporation, P2 million minimum capital, fit-and-proper tests, AML/CFT obligations, and security-vetting procedures. The guidelines made the 2019 EPS regulatory framework fully actionable and triggered the first wave of non-bank EPS licences.

FATF's Paris plenary removed Botswana from enhanced monitoring after the country completed key action items, risk-based AML/CFT supervision, improved financial-intelligence dissemination, and stricter cross-border payment controls. Removal reduced compliance friction for international digital payment operators and restored Botswana's access to normal correspondent-banking terms.

The Bank of Botswana released its first dedicated NPS strategy setting targets for interoperability, financial inclusion, and real-time retail payment infrastructure. The strategy provided the roadmap for enforcing EPS licences, developing instant payment rails, and ultimately establishing the Digitalisation and Innovation Hub.

The Bank of Botswana issued Statutory Instrument No. 2 of 2019, creating the first dedicated licensing regime for electronic payment service providers and money/value transfer services, covering mobile money operators such as Orange Money, MyZaka and Smega. Providers were required to separately incorporate, hold P2 million minimum capital, and comply with AML provisions. This is the foundational legal instrument for Botswana's digital payments sector.

The foundational statute mandated the Bank of Botswana to recognise, regulate, and oversee all clearing and settlement systems, establishing the legal basis for the Botswana Interbank Settlement System (BISS) and the Botswana Automated Clearing House (BACH). It remains the primary legislation governing systemically important payment infrastructure and the Bank's oversight authority over all subsequent payment-system participants.