With three weeks to go until the 30 June 2026 deadline, the BCEAO is imposing mandatory integration into the Instant Payment System (PI-SPI) platform, which went live on 30 September 2025. This mandatory roll-out is legally based on legislation relating to payment services, which enshrines the principle of interoperability and non-discriminatory access to market infrastructure throughout the Union.<\/p>\n\n\n\n
This connection requirement applies by right to all financial actors in the region. This includes banks, Electronic Money Institutions (EMIs), Payment Institutions and microfinance institutions. These entities have a legal obligation to finalise their technical integrations by the deadline.<\/p>\n\n\n\n
This regulatory shift fundamentally redefines regional compliance in line with FATF standards. Institutions must apply a risk-based approach to ensure the real-time processing of transactions and appoint a compliance officer reporting to senior management, as required by the UMOA Banking Commission\u2019s Circulars. At the same time, the transparency of fund flows is being strengthened by legislation relating to the fight against money laundering, terrorist financing and the proliferation of weapons of mass destruction, which governs vigilance regarding electronic transfers, and by the reporting threshold for the physical transport of cash.<\/p>\n\n\n\n
Faced with the risk of financial penalties or suspension of authorisation, the Legal Departments must finalise three urgent projects. These involve signing the agreements to join the BCEAO\u2019s PI-SPI, clarifying the liability regime in the event of a technical incident through contractual provisions (in accordance with the Payment Services Directive), and bringing the processing of real-time payment flows into line with national data protection laws.<\/p>\n\n\n