What are the licensing requirements for fintech and mobile money providers under BCEAO in Senegal, and what's the typical approval timeline?

Dear ,

Greetings and thank you for your inquiry regarding launching a fintech payment service in Senegal.

License Types Under BCEAO
Under BCEAO's Instruction №001-01-2024, which governs the West African Economic and Monetary Union (WAEMU) including Senegal, you'll need one of two primary licenses depending on your service model:​

Payment Institution (PI) License - Required for offering payment services including cash deposits/withdrawals, account management, payment execution, transfers, payment card transactions, merchant acquiring, and payment initiation services.​

Electronic Money Institution (EMI) License - Required if you plan to issue and distribute electronic money (e-wallets, mobile money). EMIs must segregate customer funds and cannot offer credit or pay interest on balances.​

Capital Requirements
Minimum paid-up share capital varies by service type:​

XOF 10 million (~$16,500) for account aggregation services

XOF 20 million (~$33,000) for payment initiation services

XOF 100 million (~$165,000) for wallet services, transfers, and merchant acquiring

Reporting and Compliance Obligations
Key obligations include:​

Fit-and-proper tests for founders, directors, and major shareholders demonstrating integrity and financial capacity

Board expertise in cybersecurity, anti-money laundering (AML), and payment systems

Business continuity plans and annual security audits

Strict AML/CFT (combating financing of terrorism) compliance

Data localization requirements​

Corporate structure as public limited company, limited liability company, or cooperative with registered office in a WAEMU member state​

Approval Timeline
The regulatory timeline is as follows:​

Applications are submitted to the BCEAO Governor, who reviews and grants authorization specifying which payment services you're approved to provide. While the BCEAO initially provided a 6-month compliance window for existing operators, the actual approval process timeline for new applicants is not explicitly stated in current regulations. However, industry reports suggest delays have occurred, with the regulator having approved only a limited number of applications as enforcement deadlines approached.​

 While I can offer you research-based guidance via WhatsApp on BCEAO regulatory requirements, please note that launching a licensed fintech operation in Senegal will require local legal counsel familiar with WAEMU banking law, as well as on-ground compliance infrastructure.

If you'd like affordable, advisory support to understand these regulations better and prepare your approach, I'm available via WhatsApp for text-based consultations. Feel free to reach out to discuss how I can assist with your preliminary research and planning.

Best regards