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Bank of Mozambique is reaffirmed as central licensing/supervisory authority for the National Payment System under Lei n.º 15/2026, de 2 de Julho, which repeals Lei n.º 2/2008 and gives incumbent operators 180 days to register. Bank of Mozambique granted cross-border PSP PawaPay a licence to onboard merchants directly (8 Oct 2026).
The one area where Banco de Moçambique has built a distinct, lighter-touch gateway is virtual-asset activity. Under Aviso No. 4/GBM/2023, virtual-asset service providers are required to register - not obtain a full licence - in a centralised state register, with a 90-day review period, a unique ID issued per registrant, and revocable registration status. This registration regime is analytically separate from the Law 20/2020 licensing track: it creates a state visibility mechanism over VASPs without folding them into the credit-institution/financial-company/EMI licensing perimeter. That said, this registration-regime claim rests on a single T4 (vendor/law-firm) source this cycle and was not independently corroborated by a T1/T2 anchor, so it should be read as assessed rather than confirmed detail pending further corroboration.
Outlook
Because sub-national divergence is not a live consideration in Mozambique's unitary, BdM-centralised licensing structure, the module's forward risk sits almost entirely in how the VASP registration regime evolves relative to the core Law 20/2020 licensing track, and in whether Notice 1/GBM/2026's extension of mandatory instant-payment-system participation to EMIs and BdM-authorised wallet operators (see W4/W5) is followed by any adjustment to the underlying licensing categories themselves. No such adjustment has been identified in current sources; the licensing architecture is the established baseline against which subsequent scheme and product mandates are being layered.
Licensing, Authorisation & Market Access
Lei n.º 15/2026 formally designates Banco de Moçambique as the National Payment System authority for Mozambique, with powers to license operators, regulate, inspect and supervise all payment infrastructures, service providers and other sector participants. This is a consolidating statutory development: rather than fragmented or informal oversight, payment-system operators, service providers and participants are now required to register with and submit to licensing, inspection and supervision by the central bank as a matter of law. Breach of these requirements carries fines of up to 1,500 minimum wages, giving the licensing regime a defined penalty structure from the outset.
The law applies to both bank and non-bank participants in the payment system, meaning the licensing and supervisory perimeter is not limited to traditional deposit-taking institutions but extends across the payment-service-provider landscape more broadly. The law has been in force since August 2026, roughly two months ahead of this reporting window, giving Banco de Moçambique an established statutory basis from which to begin exercising its licensing, inspection and supervisory powers over the sector it now formally oversees.
No information was available this period on how many entities have been licensed or registered under this new authority since August 2026, nor on any enforcement action taken under the fine provisions. The full pinpoint statutory text of Lei n.º 15/2026 was not retrieved this period, so finer details of the licensing application process, conditions, and categories of regulated participant beyond the general authority grant remain to be confirmed.
Outlook
The item to watch is how Banco de Moçambique begins to exercise its newly consolidated licensing and supervisory authority in practice: which categories of payment-service provider are brought under active registration first, and whether any enforcement action under the 1,500-minimum-wage fine provision materialises. Given the law's in-force status since August 2026, the period ahead is likely to surface the first concrete applications of this authority.
5 earlier distinct update(s)
Licensing, Authorisation & Market Access
Mozambique's licensing and market-access landscape shifted structurally this cycle with the enactment of Lei n.º 15/2026, of 2 July, which establishes a new legal regime for the National Payment System and repeals the prior 2008 law. The new law requires incumbent payment-system operators to register with the Bank of Mozambique within 180 days of entry into force, a registration obligation rather than a full re-licensing exercise, but one that nonetheless compels every existing operator to actively re-present itself under the new framework. The practical deadline for that registration falls at the close of 2026, meaning the coming months will determine which incumbent operators remain formally on record under the revised regime.
Alongside this structural reset, the Bank of Mozambique granted a payment-services-provider licence to PawaPay, a cross-border payments aggregator, in an event dated 8 October 2026. The licence permits PawaPay to onboard merchants directly onto mobile-money rails rather than requiring intermediation through an existing bank or mobile-network operator. Reporting indicates M-Pesa connectivity is already live and e-Mola is enabled for payouts, while Tmcel's mKesh wallet remains unconnected. No Bank of Mozambique primary notice confirming the licence grant has been located; the finding rests on corroborating secondary and tertiary press reporting.
Taken together, these two developments describe a market-access environment in active transition: a wholesale legal reset of the registration regime for payment-system operators generally, occurring in parallel with a specific new market entrant gaining direct access to the country's dominant payments rail. For incumbent operators, the near-term task is compliance with the registration deadline; for new entrants such as PawaPay, the opportunity is direct merchant-facing access to a market where mobile-money penetration substantially exceeds traditional banking penetration.
Outlook
The registration deadline under Lei n.º 15/2026, falling at the close of 2026, is the key date to track for this module: it will reveal both how many incumbent operators successfully transition to the new regime and whether the Bank of Mozambique applies any substantive review during what is nominally a registration rather than re-licensing process. Separately, whether PawaPay's merchant-onboarding activity extends to a connection with Tmcel's mKesh wallet would materially expand the addressable mobile-money base available to the aggregator under its new licence.
Licensing, Authorisation & Market Access
Mozambique has enacted Law 15/2026, replacing the 2008 National Payment System Law and establishing a new legal foundation for payment-system licensing and market access. Existing payment-system operators have a 180-day window from the law's approval to adapt to the new requirements. Notably, the transition mechanism for incumbents is registration with Banco de Moçambique rather than a fresh licensing round: operators already active in the market are exempt from initial licensing under the new law, but must complete registration within the adaptation window to remain compliant.
This is a market-access-defining change rather than an incremental update: it replaces the entire prior statutory basis for payment-system operation in Mozambique. For new entrants, this signals that the operative legal text governing licensing has changed, and any market-entry assessment should be conducted against Law 15/2026 rather than the superseded 2008 law. For incumbents, the registration requirement is a lighter-touch transition than full relicensing, but it remains a mandatory compliance step with a defined and immediate deadline.
Carrying the bank-PSP versus non-bank payment-institution distinction forward, the available evidence this cycle does not specify whether Law 15/2026 differentiates registration or licensing treatment between bank-affiliated payment-system operators and non-bank payment institutions or e-money issuers; this is a gap in the current evidence base rather than a confirmed absence of such differentiation.
Outlook
The close of the 180-day adaptation window is the key near-term marker for this module: it will indicate how comprehensively the existing operator base has completed registration under Law 15/2026. Any further implementing regulations, circulars, or Banco de Moçambique guidance clarifying registration procedure or differentiated treatment by operator type would be the next material development to track.
Licensing, Authorisation & Market Access
Mozambique enacted Law 15/2026, establishing a wholly new legal regime for the National Payment System and repealing the prior Law No. 2/2008. Banco de Moçambique is reaffirmed as the central licensing, inspection and supervisory authority for the payments sector under this new instrument. Existing payment-system operators are given a 180-day window to adapt to and register under the new law; the transition arrangements exempt incumbents from an initial fresh licensing process, but registration with Banco de Moçambique is still required. This is a confirmed, T1-anchored legislative reset of the market-access framework, corroborated by contemporaneous press reporting on the transition mechanics, and it applies across both bank and non-bank payment-system operators rather than to a single category of entity.
The practical effect for market participants is a defined compliance clock: operators already active under the repealed 2008 regime must complete registration within 180 days or fall outside the new legal perimeter, while new entrants presumably face the licensing pathway the new law establishes, though the specific licensing-category mechanics beyond the incumbent-transition provision were not detailed in this cycle's findings. The reform sits alongside, and is likely connected in intent to, the concurrent launch of the instant-payment infrastructure described under Operational Resilience below: a market-access reset paired with a new settlement rail suggests a coordinated modernisation push by Banco de Moçambique rather than two unrelated initiatives.
No enforcement action, licence revocation, or specific operator-level licensing decision was identified this cycle under this module; the finding is confined to the legislative reset itself and its transition terms.
Outlook
The marker to track is the close of the 180-day registration window opened by Law 15/2026, which will indicate how many existing payment-system operators have formally transitioned into the new legal regime, and whether any fail to register within the deadline. Any subsequent Banco de Moçambique guidance detailing new-entrant licensing categories or conditions under the new regime would materially extend this finding and should be watched for in the next cycle.
Licensing, Authorisation & Market Access
Banco de Moçambique's Notice/Aviso 1/GBM/2026, dated 25 February 2026, established the Mozambique Instant Payment System (SPIM) and approved its Regulation, entering into force 2 March 2026. This is a high-confidence, T1 primary-regulator finding. SPIM is operated by SIMO under a new technology platform branded METIX, which integrates commercial banks and mobile-wallet operators — M-Pesa, e-Mola and m-Kesh — onto a single real-time settlement platform, officially launched 16 March 2026.
The market-access significance of this development is best understood against Mozambique's account-holding structure: as of November 2025, mobile-wallet accounts numbered over 24.6 million against 6.6 million traditional commercial-bank accounts. SPIM's architecture is mandatory for licensed banks, microbanks and IMEs alike, meaning the market-access question for new entrants shifts from whether to obtain a banking or e-money licence toward whether that licence carries automatic SPIM participation rights under the new Regulation. The bank-PSP vs non-bank IME distinction is carried directly into this framework: both categories connect to the same METIX rail, but under access terms defined by their respective licensing category rather than a converged single licence type.
Outlook
Watch for confirmation of participation terms and technical-access requirements for non-bank IMEs relative to licensed banks under the SPIM Regulation, and for whether additional mobile-wallet operators beyond M-Pesa, e-Mola and m-Kesh are onboarded to METIX in subsequent cycles.
Licensing, Authorisation & Market Access
Banco de Mocambique's Aviso No. 1/GBM/2026, effective 2 March 2026, establishes the Mozambique instant payment system, branded SPIM or its operational name METIX, and designates SIMO as the operating entity. This is a Tier 1 primary-source development, carrying high confidence, and it sits squarely within the licensing and market-access perimeter because participation is mandatory rather than optional: credit institutions, payment service providers, and other Banco de Mocambique-authorised entities are all brought within the scheme's participation requirement. This mandatory design is the single most consequential market-access fact in the notice, because it forecloses the possibility of a two-tier market in which only banks connect to the new real-time rail while non-bank payment service providers remain on legacy bilateral arrangements. Both categories of institution face the same connectivity obligation, which is a materially different starting position from jurisdictions where instant-payment participation is bank-led with non-bank access following later, or mediated through indirect participation via a sponsoring bank.
The scheme's initial operating parameters, reported at Tier 3 confidence via Club of Mozambique's coverage of the launch, set a daily transaction limit of 200,000 MZN, approximately USD 3,129, for individual transfers, with higher limits available to legal entities. Interbank individual transactions are exempt from fees under the initial parameter set. This fee-exemption choice is a market-access-shaping decision in its own right: it lowers the cost of switching from existing payment rails to SPIM for retail users specifically, which is consistent with a regulator-operator strategy of building transaction volume during the scheme's early adoption phase before introducing commercial pricing tiers.
A second material licensing and market-access development this cycle is Banco de Mocambique's Aviso No. 2/GBM/2026, dated 2 June 2026, which establishes new connection rules for the Rede Unica de Pagamentos, the country's shared payments network, and explicitly revokes the prior Aviso No. 2/GBM/2015. This is a Tier 1 primary-source development sourced directly from the BdM normativos register, carrying high confidence. The revocation of a decade-old connection-rules instrument in favour of a new framework, arriving three months after the SPIM launch, reads as a coordinated modernisation of the underlying network architecture rather than an isolated administrative housekeeping change. Because Rede Unica is the shared network underlying broader retail payments access in Mozambique, a reset of its connection rules is itself a market-access event. The interpreter record available this cycle does not itemise the specific participant-category detail, bank versus non-bank, for the revised connection rules, which is a gap worth closing in the next review cycle.
The bank-versus-non-bank distinction is worth stating explicitly for this module: Mozambique's mobile-money-led retail payments market has historically been dominated by non-bank electronic-money issuers operating alongside, rather than fully integrated with, the bank-centred settlement infrastructure. SPIM's mandatory-participation design changes that structural picture by placing both categories under a single real-time settlement obligation, which is a more integrated market-access model than a bank-only instant-payments scheme would produce. Both instruments took effect within a single calendar year, Aviso 1/GBM/2026 in March and Aviso 2/GBM/2026 in June, a fast implementation cadence relative to typical central-bank payments-infrastructure programmes, though the interpreter record does not identify any specific technical-assistance provider this cycle.
Outlook
The most consequential open question for market access is how quickly non-bank payment service providers achieve practical, not just nominal, connectivity to SPIM, given that the mandatory-participation requirement establishes the obligation but does not by itself guarantee uniform technical readiness across a diverse population of banks and PSPs. A second item to track is whether Banco de Mocambique publishes further implementing guidance on the Rede Unica connection-rules reset that clarifies participant categories and technical connection standards. Both developments should be read together as a single modernisation programme whose market-access implications will become clearer as implementation deepens.
1 earlier update recorded under a different module label
An early cycle filed this entry under this module code with a heading naming another subject. Kept for the record; not this module's latest position.
Regulatory Landscape & Supervising Authority
Banco de Moçambique underwent a leadership transition in early September 2026. Felisberto Dinis Navalha was sworn in as Governor, succeeding Rogério Zandamela, whose second and final five-year term as Governor concluded. Benedita Maria Guimino was sworn in concurrently as Vice-Governor. The appointment followed a rapid reversal: President Chapo revoked his initial appointment of Waldemar Fernando de Sousa as Governor less than a day after announcing it, before Navalha was installed. The transition is a governance-continuity event; Banco de Moçambique's prudential and conduct architecture for the payments sector, anchored in Law No. 20/2020 and its implementing Decree No. 50/2024, is not reported to have changed as a result. Separately, Banco de Moçambique opened the call for the eighth edition of its Regulatory Sandbox, continuing its innovation-policy engagement with bank and non-bank payment-service providers under the new leadership.
Outlook
The leadership change carries elevated near-term attention given its unusual sequencing, but the analytical baseline is continuity rather than disruption: the supervisory architecture applicable to both bank and non-bank payment institutions in Mozambique is unchanged, and the Regulatory Sandbox call signals continued openness to innovation-track engagement under the new Governor and Vice-Governor.
Sources and findings (7)
- T1https://www.bancomoc.mz/en/areas-of-expertise/licensing/licensing-of-institutions/retrieved
- T1https://www.bancomoc.mz/en/areas-of-expertise/licensing/licensing-of-institutions/retrieved
- T2https://practiceguides.chambers.com/practice-guides/banking-regulation-2026/mozambiqueretrieved
- T2https://practiceguides.chambers.com/practice-guides/banking-regulation-2026/mozambiqueretrieved
- T3https://www.mozambiqueexpert.com/en/mozambiqu-mobile-money-operators-mmo/retrieved
- T4https://incfine.com/en/obtaining-a-crypto-license-in-mozambique/retrieved
- T3https://www.mozambiqueexpert.com/en/mozambique-banking-sector/retrieved