Fintech & payments regulation in Botswana (2026)
Fintech and digital payments in Botswana: licensing regime.
Botswana operates an in-force licensing regime for digital payments: the Bank of Botswana licenses Electronic Payment Service (EPS) providers, including e-money issuers and money/value-transfer service providers, under the Electronic Payment Services Regulations 2019 and 2022 Licensing Guidelines, anchored in the National Clearance and Settlement Systems Act 2003. Core rails (the BISS/RTGS and the BACH automated clearing house) are operated by the central bank, and a register of licensed EPS providers is published. Some adjacent areas remain less developed: dedicated buy-now-pay-later rules are absent, open banking exists at policy level, and digital-credit fintechs still operate in a partly unregulated space pending broader reforms.
Legal framework
Electronic Payment Services Regulations, 2019 (issued under the National Clearance and Settlement Systems Act, Cap 46:06, 2003), supplemented by the Bank of Botswana Electronic Payment Services Licensing Guidelines (2022); administered by the Bank of Botswana, with NBFIRA and BOCRA covering adjacent non-bank lending and telecom/mobile-money enablers.
Key points: digital payments & fintech in Botswana
Dedicated EPS / e-money licensing in force
The Electronic Payment Services Regulations 2019 set the legal framework for licensing entities that issue e-money, hold payment accounts, and execute electronic transfers; an applicant must be incorporated in Botswana under the Companies Act. The 2022 Licensing Guidelines operationalise entry requirements, fund protection, outsourcing and agent rules.
Regulator and statutory basis
The Bank of Botswana has statutory oversight of the National Payments System and licenses/recognises payment and settlement operators under the National Clearance and Settlement Systems Act (Cap 46:06, 2003) and its 2005 Regulations; it publishes a public register of licensed EPS providers.
Payment rails: RTGS and bulk clearing
The Bank of Botswana operates the Botswana Interbank Settlement System (BISS), the real-time gross settlement system for high-value transfers, and the Botswana Automated Clearing House (BACH) for bulk/retail batch payments such as salaries; both are mandated under the NCSS Act 2003.
Mobile money licensed under EPS regime
Mobile money is well established and supervised under the payments framework, with Orange Money the market leader (over 70% share and roughly P33.5bn in transaction value in the year to March 2024) and Mascom MyZaka also active; mobile network operators are additionally licensed by BOCRA.
Emerging-fintech and instant/cross-border payments developing
The Bank of Botswana has introduced a Fintech Analytical Assessment Framework to assess risks across balance-sheet lending, crowdfunding, robo-advisory, InsurTech, virtual assets and stablecoins, and cross-border instant payments are expanding (e.g. SADC/TCIB-based real-time links via banks in 2025-2026), indicating active but still-maturing areas beyond the core EPS regime.
Gaps: BNPL, open banking, digital credit
There is no dedicated buy-now-pay-later regime; open banking exists at the policy level rather than as binding licensing rules; and the World Bank FSAP and local reporting note many mobile/digital lenders operate in a partly unregulated zone, with NBFIRA (under the NBFIRA Act) supervising non-bank lenders.
Timeline of decisions
- Law · officialNBFIRA Act 2023 Commences, Unified VASP and Fintech Licensing Regime
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.
NBFIRA
- Decision · officialBank of Botswana Opens Fintech Regulatory Sandbox
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.
Bank of Botswana Fintech Portal
- Decision · officialBank of Botswana Establishes Digitalisation and Innovation Hub
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.
Bank of Botswana
- Guidance · officialBank of Botswana Publishes EPS Licensing Guidelines V1.0
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.
Bank of Botswana
- Guidance · officialNational Payments System Vision and Strategy 2020-2024 Published
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.
Bank of Botswana
- Law · officialElectronic Payment Services Regulations 2019 Promulgated (SI No. 2 of 2019)
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.
Bank of Botswana
- Law · officialNational Clearance and Settlement Systems Act No. 5 of 2003 Enacted
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.
Botswana Laws (Official Consolidated Statutes)
Sources
- bankofbotswana.bw/content/oversight-national-payments-system
- bankofbotswana.bw/content/licensing-requirements
- bankofbotswana.bw/content/legislation-and-regulations
- bankofbotswana.bw/sites/default/files/Electronic%20Payments%20Services%20Regulations%20
- bankofbotswana.bw/sites/default/files/Electronic%20Payment%20Services%20Guidelines%20Fe
- bankofbotswana.bw/sites/default/files/Register%20of%20Licensed%20Electronic%20Payment%2
- bankofbotswana.bw/content/botswana-interbank-settlement-system
- bankofbotswana.bw/content/fintech-and-national-payments-systems
- bis.org/cpmi/paysys/Botswana.pdf
- nbfira.org.bw/
- documents1.worldbank.org/curated/en/099120523162012347/pdf/BOSIB085cdbd880a608a0009dfae732ce9d
- weekendpost.co.bw/botswana-digital-credit-growth-faces-regulatory-challenges/
- dobusiness.co.bw/mapping-the-fintech-ecosystem-in-botswana/
- techafricanews.com/2026/03/02/payincs-tcib-unlocks-real-time-cross-border-payments-betwe
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Next topicOrientation, not legal advice: verify against the primary sources linked above. Last verified 25 May 2026. Methodology & how to cite · State of Technology Regulation 2026