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Zambia enacted the National Payment System Act, 2026 (repealing and replacing the National Payment Systems Act, Cap. 359 of 2007) and the Banking and Financial Services Act, 2026 (Act No. 9 of 2026, repealing the Money-lenders Act Cap. 398). Both consolidate licensing/authorisation of payment service providers and financial service providers under Bank of Zambia oversight, but neither had a confirmed commencement order as of the most recent available legal commentary.
Outlook
The pending ministerial commencement instrument for the National Payment System Act 2026 is the key marker to watch; until it is gazetted, the 2007 Act continues to govern licensing and designation, creating a transition window in which both regimes are referenced but only one is operative.
Licensing, Authorisation & Market Access
Zambia's payments and banking licensing architecture moved from a pre-reform, system-level-only framework to an enacted but not-yet-operative individual-licensing regime this cycle. The National Payment System Act, 2026, assented to on 31 March 2026 and gazetted on 8 April 2026, repeals the National Payment Systems Act Cap 359 of 2007, which had governed payment systems principally through designation of systems rather than licensing of individual providers. In its place, the new Act introduces individual licensing for payment service providers and e-money institutions, with each licence carrying AML/CFT duties, cyber-incident-reporting obligations, capital requirements and customer-fund-segregation duties attached directly to the licence rather than imposed at the system level. A National Assembly committee report on the underlying Bill confirms that the legislation sets rules spanning governance, AML/CFT, cyber-incident reporting, capital requirements and segregation of customer funds, indicating the licensing framework was drafted as a comprehensive prudential package rather than a narrow authorisation gate.
Alongside it, the Banking and Financial Services Act, 2026 was assented to and gazetted on the same dates. This Act consolidates banks, microfinance institutions, moneylenders, fintechs and e-money issuers under a single Bank of Zambia licensing and supervisory framework, repealing both the prior Banking and Financial Services Act and the Money-lenders Act Cap 398. The practical effect, once the Act commences, is that categories of financial-service provider that previously sat under separate, sometimes lighter-touch regimes, including moneylenders and non-bank fintech credit providers, would move under direct Bank of Zambia prudential supervision alongside banks. Legal commentary on the Act's drafting indicates that its definitions of "financial service" and "financial service provider" are written to explicitly capture issuing and managing means of payment, including e-money, meaning e-money issuance is positioned to fall within the unified Bank of Zambia licence under this Act rather than being carved out to a separate payments-only authorisation track.
Both Acts share the same critical procedural feature: enactment without commencement. Each requires a ministerial statutory instrument to bring it into force, and no such instrument had been located in the sourcing reviewed this cycle. This means that, as a matter of current legal effect, payment service providers and financial-service providers operating in Zambia continue to be governed by the pre-reform statutes the 2026 Acts are designed to replace. For market-access planning purposes, however, the legislative destination is now fixed: a firm seeking to enter or expand in the Zambian payments or banking market can plan against the individual-licensing, AML/CFT-and-capital-bearing regime that is now enacted law, even while operating in the interim under the designation-based 2007 framework.
Outlook
The central open question for Zambia's licensing and market-access landscape is the timing of commencement. No commencement statutory instrument has been located for either the National Payment System Act or the Banking and Financial Services Act, and commencement is anticipated, as scheduled, around early 2027, though this estimate carries real uncertainty and should not be treated as confirmed. Firms with existing payment-system designations or banking licences under the pre-reform statutes should expect a transition process once commencement occurs, likely requiring re-licensing or confirmation of continued authorisation under the new individual-licence structure. Non-bank payment providers, e-money issuers, moneylenders and fintech lenders not currently captured by unified prudential supervision represent the segment most affected by the change, since they would newly fall within Bank of Zambia licensing and the associated AML/CFT, capital, cyber-incident-reporting and fund-segregation duties. Monitoring for the commencement instrument itself is therefore the single most consequential near-term signal for market-access planning in this jurisdiction.
3 earlier distinct update(s)
Licensing, Authorisation & Market Access
Zambia's licensing and market-access basis for payments and banking was re-legislated within a single 2026 cycle across two statutes. The National Payment System Act, 2026 (Act No. 5 of 2026) establishes the National Payment System for purposes of regulation and supervision by the Bank of Zambia under the Bank of Zambia Act, 2022, replacing the 2007 National Payment Systems Act as the statutory basis for BoZ's authority over payment system operators and participants. The Banking and Financial Services Act, 2026 (Act No. 9 of 2026) repeals and replaces both the 2017 Banking and Financial Services Act and the Money-lenders Act, consolidating financial-sector regulation under BoZ on an explicit proportionality principle and empowering BoZ to impose a licensing moratorium.
Both statutes route licensing and supervisory authority for their respective sectors through the same central bank, and licensing of financial service providers, including fintech and payment-service-provider entities that sit in the bank-PSP versus non-bank-PI/EMI space, continues under the new consolidated Banking and Financial Services Act framework rather than under any separate PI/EMI-specific licensing statute. The proportionality principle written into the Banking and Financial Services Act, 2026 is notable for the bank-PSP versus non-bank-PI/EMI distinction specifically, since a proportionality-based licensing approach typically signals differentiated capital and conduct requirements according to institution type and risk profile rather than a single uniform bank-grade licensing bar applied to every regulated entity.
The licensing moratorium power granted to BoZ under the Banking and Financial Services Act, 2026 is a market-access lever distinct from ordinary licensing criteria: it allows BoZ to pause new licensing activity across the sector at its discretion, which is a structural market-access control mechanism rather than an entry-criteria change.
Outlook
No implementing regulations specifying licensing criteria, capital thresholds, or the practical application of the proportionality principle under the Banking and Financial Services Act, 2026 were identified this cycle. The next dated event to watch is the publication of any such implementing instrument or BoZ guidance clarifying how the proportionality principle differentiates licensing requirements across bank, non-bank PSP, and PI/EMI-type entities.
Licensing, Authorisation & Market Access
Zambia's payments market-access architecture underwent a significant statutory overhaul in 2026 with the enactment of the National Payment System Act, which repeals and replaces the National Payment Systems Act, Cap. 359 of 2007. The new Act introduces licensing, designation and authorisation provisions specifically for payment service providers, alongside insolvency and receivership rules that did not exist in equivalent form under the prior framework. This runs in parallel with the Banking and Financial Services Act, 2026 (Act No. 9 of 2026), which consolidates banks, microfinance institutions, moneylenders, fintechs and e-money issuers under a single Bank of Zambia licensing and supervisory regime, expressly repealing the Money-lenders Act, Cap. 398. Both instruments were sourced from Tier-1 parliamentary primary text and both carry an elevated impact assessment for market-access architecture.
The critical qualifier on both instruments is commencement status. Legal commentary tracking the ZambiaLII consolidated legal database recorded the Banking and Financial Services Act as uncommenced as of 5 August 2026, pending a ministerial statutory instrument; this sourcing carries a lower confidence tier than the primary parliamentary text itself, since it rests on a single Tier-3 corroboration rather than a Tier-1 confirmation of non-commencement. The practical effect is that Zambia currently has an adopted, but not yet operative, consolidated licensing architecture spanning both payment service providers specifically and the wider population of banks, microfinance institutions, moneylenders, fintechs and e-money issuers under the companion Act.
This consolidation is significant precisely because it collapses what was previously a more fragmented licensing landscape into unified Bank of Zambia oversight. Under the prior regime, moneylenders were governed by a dedicated Money-lenders Act now repealed by the Banking and Financial Services Act, while payment service providers operated under the now-superseded National Payment Systems Act, Cap. 359. The 2026 consolidation brings bank and non-bank payment institution regulation into closer alignment under common statutory instruments, though the degree to which prudential requirements will differ between bank-PSP and non-bank-PI/EMI categories under the new regime is not yet detailed in the sources available this cycle. The distinction between bank and non-bank payment institution treatment remains analytically important to track once implementing regulations or licensing guidelines are published, since consolidation under a single Act does not necessarily imply identical prudential treatment across entity types.
Outlook
The central item to track for Zambia's market-access architecture is the ministerial commencement order for both the National Payment System Act and the Banking and Financial Services Act, 2026, expected in the region of the first quarter of 2027 on current legal-commentary estimates, though this carries a half-year uncertainty band given the reliance on a single Tier-3 source for commencement timing. Once gazetted, the consolidated licensing, designation and authorisation perimeter will apply directly to payment service providers, and the interaction between this regime and the parallel banking consolidation will determine whether bank-affiliated payment providers face a materially different licensing pathway than standalone non-bank payment institutions and e-money issuers. Firms currently operating under the pre-existing National Payment Systems Act, Cap. 359 framework continue to do so pending that commencement order.
Licensing, Authorisation & Market Access
Zambia's National Payment System Act, 2026 (Act No. 5) repeals and replaces the 2007 National Payment Systems Act, providing for licensing, designation and authorisation of payment service providers, and introducing a statutory forty-five-day decision window for the Bank of Zambia to determine authorisation applications, with applicants notified within a further seven days. Alongside it, the Banking and Financial Services Act, 2026 (Act No. 9) consolidates banks, microfinance institutions, moneylenders, fintechs and e-money issuers under a single Bank of Zambia licensing, reporting and enforcement regime, replacing the fragmented 2017 Banking and Financial Services Act and Money-lenders Act patchwork. Both instruments are Tier-1 sourced and assessed at High confidence.
The practical market-access effect is twofold. First, the bank-versus-non-bank distinction is now explicit in statute: non-bank payment institutions and e-money issuers sit within the same Bank of Zambia-administered perimeter as banks rather than in a separate or ambiguous space, and face the same forty-five-day statutory decision window as any other applicant. Second, the cost of remaining outside that perimeter has risen sharply — the Banking and Financial Services Act imposes penalties of up to three million penalty units and/or up to thirty years' imprisonment for conducting banking business or providing a financial service, including payment services and e-money issuance, without a licence.
Outlook
The National Payment System Act's authorisation regime is expected to reach fuller operationalisation around the third quarter of 2026. Whether the Bank of Zambia honours the forty-five-day decision window in practice, and how the steep unlicensed-activity penalty ceiling is applied in the initial enforcement period, are the two central markers to watch next cycle.
Sources and findings (6)
- T1https://www.boz.zm/national-payment-systems-act.htmretrieved
- T1https://zambialii.org/akn/zm/act/2026/5/eng@2026-04-08retrieved
- T2https://www.afriwise.com/blog/regulation-of-fintech-in-zambia---a-legal-guideretrieved
- T1https://www.boz.zm/sites/default/files/2026-04/Requirements%20for%20Designation%20of%20Payment%20System.pdfretrieved
- T3https://blog.useaccrue.com/the-future-of-cross-african-payments-opportunities-and-regulatory-pinch-points/retrieved
- T1https://www.state.gov/reports/2025-investment-climate-statements/zambiaretrieved