Abstract
The Economic and Monetary Community of Central Africa (CEMAC) launched its first regional credit bureau, BIC-CEMAC, in January 2026 with a founding cohort of 41 commercial banks and 20 microfinance institutions — and no mobile money operators. This is notable because both dominant Cameroonian mobile money issuers, Orange Money Cameroun and MTN's Mobile Money Corporation, have held Établissement de Paiement (EP) licenses since 2022 and 2023 respectively, and are, under the primary text of BEAC Instruction N°014/2020 (Article 3), mandatorily bound to furnish credit information to the bureau on the same terms as banks.
This paper undertakes a close textual analysis of the two governing instructions — 014/2020 (furnisher obligations) and 010/2020 (client-consent architecture) — and finds that the absence of EPs from the founding cohort does not reflect legal exclusion but a narrower, more consequential problem: the mandated data-content categories in Article 3 were drafted around a bank-shaped template of formal credit exposures and payment incidents, and do not contemplate the transactional and behavioral data (cash-in/cash-out volume, merchant payment frequency, airtime top-up patterns) that has underpinned alternative-data credit scoring in comparable African markets. We situate this within the information-economics literature on credit registries (Pagano & Jappelli, 1993; Djankov, McLiesh, & Shleifer, 2007) and argue that CEMAC's 2018–2020 regulatory architecture predates a demonstrable regional and continental shift — visible in UEMOA's 2016-era grands facturiers furnisher category and Morocco's 2024 reform — toward explicitly naming telecom and mobile data as bureau-eligible inputs. We propose a targeted amendment to Instruction 014/2020 rather than new primary legislation, and identify testable near-term indicators — including whether MTN's Momocash micro-credit product is already generating Article 3-reportable exposures — for assessing whether the gap is closing.