Digital Payments & Fintech · Togo
Fintech & digital payments rules in Togo (2026)
Togo shaded by its digital payments & fintech status
Digital payments and fintech in Togo are governed by a clear, in-force licensing regime set by the regional central bank (BCEAO) rather than by purely national law. Payment service providers must hold a BCEAO Payment Institution (PI) licence under Instruction 001-01-2024 (in force; transition period ended 31 August 2025, with only licensed entities permitted from 1 September 2025), while e-money issuers require an EMI authorisation under Instruction 008-05-2015. Togolese fintechs have been licensed under this regime (e.g., InTouch Togo received an EMI licence in June 2025 and Semoa obtained a 'full-service' payment licence), and Togo participates in the BCEAO's interoperable instant-payment system (PI-SPI).
Key points
Togo applies the BCEAO regional regime; payment services are licensed under Instruction No. 001-01-2024 (effective 23 Jan 2024), which requires all payment service providers (banks, e-money institutions, microfinance institutions and standalone payment institutions) to obtain BCEAO authorisation.
Issuing electronic money requires a BCEAO authorisation/approval under Instruction No. 008-05-2015; banks and payment financial institutions may issue after notifying the Central Bank, while non-bank issuers must obtain prior approval. Issuers must hold at least 75% of outstanding e-money in sight deposits.
PI licences cover services such as cash deposit/withdrawal, account management, transfers, card transactions, merchant acquiring, payment initiation and account aggregation; minimum share capital ranges from XOF 10 million to 100 million depending on the service. Account aggregation requires prior registration; credit and account remuneration are prohibited for payment institutions.
Enforcement was initially set for 1 May 2025 but the compliance transition period was extended to 31 August 2025; from 1 September 2025 only BCEAO-licensed entities may offer payment services in WAEMU, confirmed by BCEAO Avis No. 004-03-2025.
The BCEAO operates a regional interoperable instant-payment system (PI-SPI), launched following Instruction 001-01-2024 and rolled out from late September 2025, enabling 24/7 transfers across banks, EMIs, microfinance and payment institutions; Togolese banks and institutions have joined the platform.
Togolese fintechs are being licensed under the regime: InTouch Togo obtained an electronic money institution licence in June 2025, Semoa became the first Togo company to receive a BCEAO 'full-service' payment licence, and Ollo Africa was the first Togolese fintech to obtain regional banking approval from the BCEAO. BNPL and open banking are not separately regulated and fall under the general payment/credit and account-aggregation provisions of the BCEAO framework and the new uniform banking law.
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