Fintech & digital payments rules in Madagascar (2026)

Law n°2016-056 of 2 February 2017 establishes the legal concept of electronic money and requires e-money institutions (EMIs) to be incorporated in Madagascar and meet minimum capital requirements set by decree. EMIs are explicitly prohibited from extending credit.

CSBF Instruction n°002/2017-CSBF governs the agrément (license) process for EMIs; CSBF Instruction n°003/2017 regulates global trust accounts used to safeguard e-money float. The CSBF is the prudential supervisor for all banks and EMIs.

MVola, Orange Money Madagascar, and Airtel Money operate as licensed EMIs and achieved full interoperability under a GSMA-supported agreement. Together they serve the majority of the country's financially included population. A proposed 0.5% transaction tax announced in November 2024 was strongly contested by all three operators.

BFM launched the eAriary CBDC pilot in May 2025 using eCurrency DSC3 technology in partnership with PayLogic SA. BFM retains sole issuance authority; distribution is handled by commercial banks, EMIs, microfinance institutions, and fintechs. The project aims to reduce cash reliance and broaden financial inclusion.

As of 2023, no specific regulation governs digital credit providers or BNPL in Madagascar. Legal analysis by John W. Ffooks & Co finds no dedicated licensing rules or precedent; the Central Bank and CSBF are the recommended points of contact for pre-licensing clarity.

Madagascar has no open banking mandate or API framework. The broader fintech ecosystem numbers approximately 20 providers, primarily in payments. The World Bank and IFC have highlighted regulatory gaps and called for further reform to support financial inclusion and fintech growth.