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Fintech & payments regulation in Sudan (2026)

Fintech and digital payments in Sudan: partial.

Sudan has a CBoS-administered licensing regime for e-money and mobile payments, but it remains incomplete and in transition: a 2020 reform ended the state monopoly on e-money issuance and a later directive permits MNOs and fintechs to form CBoS-licensed payment subsidiaries, yet implementing regulations are still pending and the process is described as onerous and untransparent. Infrastructure is highly centralized around the EBS national switch, and the April 2023 war severely disrupted the ecosystem, leaving Bank of Khartoum's Bankak app as the dominant rail. There is no open-banking framework or distinct BNPL regime.

Last verified Official sources first · MethodologyCompare Sudan with other countries

Legal framework

Central Bank of Sudan (CBoS) under the Bank of Sudan Act and its E-Money/Mobile Payment Regulations; CBoS is the sole licensor and supervisor of e-money issuers, payment service providers and the retail payment system.

Key points: digital payments & fintech in Sudan

  1. Regulator & legal basis

    The Central Bank of Sudan holds oversight of e-money licensing and provision, the retail payment system and agent operations, acting as the single authority licensing and supervising payment/e-money providers.

    ifc.org cbos.gov.sd

  2. End of EBS e-money monopoly (2020)

    Until late 2020, mobile money had to run on the centralized platform of the state-owned Electronic Banking Services (EBS), the only permitted e-money issuer. Revised e-money regulations opened issuance to other licensed providers, though new models are still maturing.

    cgap.org ifc.org

  3. Directive for MNO/fintech payment subsidiaries

    CBoS issued a directive allowing mobile network operators and fintechs to establish payment subsidiaries supervised and licensed by CBoS; MTN was an early licensee. However, implementing regulations have not yet been issued and the licensing process lacks clarity and transparency.

    ifc.org migrantmoney.uncdf.org

  4. Capital-requirement concerns

    Fintechs have raised concerns that the capital requirements for a payment service licence may be set too high for start-up businesses, a barrier compounded by the unsettled implementing rules.

    ifc.org

  5. Centralized rails (EBS switch) and single point of failure

    All financial service providers connect through the EBS national switch, which also runs the clearing house, national ATM switch and SWIFT gateway via a single API, providing interoperability but a single point of failure.

    migrantmoney.uncdf.org fsdafrica.org

  6. War disruption and Bankak dominance

    When EBS lost power early in the April 2023 conflict, much of the mobile money ecosystem went down; Bank of Khartoum's Bankak app became the primary functioning rail, handling tens of millions of wartime transactions amid an ~85% rise in app activations.

    cgap.org cgap.org

Sources

  1. cbos.gov.sd/en/content/laws-and-regulations
  2. ifc.org/content/dam/ifc/doc/mgrt/sudan-building-resilience-through-dfs.pdf
  3. cgap.org/blog/sudan-dispatch-inclusive-finance-in-times-of-crisis
  4. cgap.org/blog/can-what-remains-of-sudans-financial-system-be-used-to-fight-fam
  5. migrantmoney.uncdf.org/wp-content/uploads/2023/05/Sudan-Infrastructure-Assessment-Report-ENG
  6. fsdafrica.org/wp-content/uploads/2022/09/22-09-19-Supporting-Digital-Payments-in-Ca

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Orientation, not legal advice: verify against the primary sources linked above. Last verified 24 May 2026. Methodology & how to cite · State of Technology Regulation 2026