Mozambique

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.

Depositor protection, however, is structured asymmetrically between the two categories. A formal Deposit Guarantee Fund (FGD) was established via Decree 36/2024 and Ministerial Diplomas 85/2024 and 86/2024, giving bank depositors a codified guarantee mechanism. No equivalent e-money float-segregation or safeguarding regime for IME/EMI customer funds was identified in the sources reviewed this cycle - the protection architecture for bank deposits is formal and recent, while the analogous protection for non-bank e-money balances remains, on current evidence, less codified. Given that Notice No. 1/GBM/2026 (see W4/W5) simultaneously makes instant-payment-system participation mandatory for EMIs and wallet operators, this is a live asymmetry: non-bank issuers are being drawn further into core payments infrastructure while the customer-fund protection layer beneath them has not visibly kept pace with the bank-deposit analogue.

Outlook

The safeguarding gap identified this cycle is the module's central forward-looking question. As mobile-wallet participation in real-time payments scales under SPIM/METIX, the absence of a dedicated e-money safeguarding regime becomes more consequential in proportion to the value flowing through non-bank rails. Whether Banco de Moçambique addresses this through an EMI-specific instrument, or through an extension of FGD-style protection, is not yet indicated in the sources reviewed and should be treated as an open regulatory question rather than a settled trajectory.

Outlook

With no stablecoin law and no CBDC exploration currently on record, this module's trajectory is properly read as stable rather than escalating: Mozambique's digital-money activity is being channelled through the VASP registration gateway and general AML monitoring rather than through dedicated product regulation. Any shift toward substantive crypto-asset or stablecoin rulemaking, or toward CBDC exploration, would represent a material change from the current baseline and should be watched for in subsequent cycles.

This reform is explicitly precedent-driven: in 2018, a vendor-licensing dispute triggered a nationwide blackout of the SIMORede payment system, leaving hospitals, schools and businesses unable to process electronic payments. That episode remains the reference case cited for the current resilience push, illustrating the concrete cost of third-party and vendor-dependency risk in Mozambique's payments infrastructure.

Outlook

This module is escalating: the Cybersecurity Law and CII-mapping exercise represent Mozambique's first systematic move toward operational-resilience regulation for payments and other critical systems, following years in which the 2018 SIMORede blackout stood as the primary cautionary precedent without a corresponding statutory framework. The key forward marker is the still-undated legal framework that will designate CII operators and their obligations; until that framework is published, the practical scope of the new law for payment-system operators specifically remains to be defined.

The more consequential scheme-level development this cycle is Notice No. 1/GBM/2026, which establishes the Mozambique Instant Payment System (SPIM) and, critically, makes participation mandatory not only for credit institutions but for electronic money institutions and Banco de Moçambique-authorised digital wallet operators. This is a direct extension of scheme participation obligations to non-bank e-money issuers, tracked on the standing "Scheme Rule Changes" tracker as escalating alongside the SIMO/Euronet migration itself, and on the "Instant Payments" tracker as newly established.

Outlook

Scheme compliance in Mozambique is running on two simultaneous tracks: legacy card-scheme migration friction that continues to generate intermittent Mastercard acceptance problems despite Visa's dominant share, and a newly mandatory instant-payment participation regime that pulls EMIs and wallet operators into scheme-level obligations for the first time. The near-term question is whether SIMO/Euronet migration disruption resolves before EMI participation in SPIM meaningfully scales, since both dynamics touch the same merchant-acceptance and consumer-experience layer.

Set against that domestic launch, the formal South Africa-Mozambique remittance corridor - one of the four largest formal SADC remittance destination markets - has been contracting: formal remittance volumes are down 36% since a 2022 peak, with flows shifting toward informal channels.

Outlook

The corridor picture this cycle is bifurcated: domestic instant-payment infrastructure is opening up new formal rails just as the largest formal inbound remittance corridor is contracting toward informality. Whether SPIM/METIX's mobile-wallet reach (via mandatory EMI participation, see W4) can be extended to capture some of the remittance volume currently migrating to informal channels is an open question not addressed in current sources, but it is the natural point of convergence between this module's two active dynamics.

Outlook

The structural picture is one of balance-sheet concentration sitting with a small number of banks while transactional reach and day-to-day usage sit overwhelmingly with mobile-money wallets operated as MNO-affiliated IMEs. As SPIM/METIX extends mandatory instant-payment participation to those same wallet operators (W4/W5), this usage-dominant but asset-light non-bank layer is being drawn further into core payments infrastructure, a dynamic worth monitoring for its effect on industry concentration metrics in future cycles.

Separately, and on a more routine cadence, Banco de Moçambique operates an active sanctions regime against credit institutions and financial companies for prudential, AML/CFT, forex and consumer-protection breaches. Nine institutions were fined between December 2023 and December 2024 under Law 20/2020 and Law 11/2022, and further fines were imposed in late 2025 against FNB Mozambique, Banco Letshego, BIM and MyBucks.

Outlook

The tuna-bonds litigation cycle appears to be reaching a point of resolution on its major fronts - judgment, global settlement and criminal conviction - which should, over time, reduce this specific item's ongoing salience even as its reputational and market-confidence effects persist. The domestic sanctions cadence, by contrast, shows no sign of slowing and should be read as a standing feature of Mozambique's supervisory environment rather than an episodic one. Note that the tuna-bonds affair's bribery, embezzlement and sovereign-debt fraud dimensions extend beyond WPM's payments-market scope and are flagged to FIM.

Outlook

The contraction in physical acceptance infrastructure, set against surging digital-wallet usage and the new SPIM/METIX rail, is consistent with a broader shift of retail payment activity away from card-present physical acceptance and toward account-based and wallet-based instant payments. Whether this reflects a deliberate acquirer rationalisation of underused terminals or a funding/investment constraint on physical acceptance infrastructure is not addressed in current sources.

The other major product-innovation development is the Mozambique Instant Payment System itself, which Notice 1/GBM/2026 explicitly frames - beyond its infrastructure function addressed under W4/W5 - as a vehicle for promoting digitalisation, financial inclusion and innovation within the financial system.

Outlook

With the sandbox's seventh edition running concurrently with SPIM's 2026 launch, and both explicitly tied to the ENIF 2025-2031 strategy, Mozambique's product-innovation posture this cycle is escalating and institutionally coordinated. ENIF's first phase is expected to conclude around 2027, which is the natural horizon marker against which to assess whether sandbox output and SPIM adoption have converted into measurable financial-inclusion gains.

Within that BdM-run complaints function, ATM-related disputes dominate the complaint mix: approximately 45% of complaints concern instances where ATM funds were debited but not dispensed, with Millennium BIM and BCI accounting for the largest complaint shares. No dedicated mandatory-reimbursement regime for authorised-push-payment fraud, of the kind operated in the UK by the Payment Systems Regulator, was identified in the sources reviewed for Mozambique.

Outlook

Consumer protection in Mozambique remains structurally concentrated within the prudential regulator rather than distributed to a specialised agency, and the complaint profile - dominated by a specific, identifiable operational failure mode (ATM non-dispense) rather than diffuse fraud typologies - suggests the more tractable near-term intervention would be operational (ATM reliability and reconciliation) rather than a new APP-fraud liability regime. No indication of movement toward either a dedicated consumer agency or an APP-fraud reimbursement rule was found in current sources.

Separately, Banco de Moçambique has imposed tiered (Level I-III) transaction and balance limits on electronic money institutions since April 2024, citing a "high" terrorism-financing threat assessment linked to the movement of funds into areas of active terrorist threat via rural IME concentration.

Outlook

The FATF delisting is a material, positive change to Mozambique's cross-border financial-crime risk profile and interacts directly with the correspondent-banking access questions addressed under W12. The IME transaction-limit tiers remain in force independent of that delisting, reflecting a threat assessment specific to rural fund-movement patterns rather than the broader grey-list status; for further analytical depth on either item, see the corresponding Sentinel.gi reporting and FIM's cross-monitor treatment.

SADC-RTGS (see W5) provides a partial structural offset to this correspondent-banking pressure, giving Mozambique a regional settlement channel that does not depend on bilateral USD correspondent relationships for intra-SADC flows.

Outlook

Mozambique's October 2025 FATF grey-list delisting (see W11) should, over time, ease some de-risking pressure specific to Mozambique's own risk classification, though the broader Africa-wide correspondent-banking contraction is a structural trend operating independently of any single country's FATF status. SADC-RTGS and any future PAPSS/COMESA REPSS interlinking remain the more durable offsets to correspondent-access constraints than a change in any one jurisdiction's grey-list status.

Separately, Mozambican fintech Roscas secured investment from Renew Capital; the amount was not publicly disclosed in reporting reviewed this cycle.

A third, development-finance-adjacent event is included for completeness: FINOVA, the Innovative Financing for Agribusiness Project, rolled out a Banco de Moçambique-supported agribusiness credit line backed by German development finance - a EUR 33.5 million KfW-funded facility split between EUR 20 million in working capital and EUR 13.5 million in investment capital, led by the Ministry of Planning and Development.

Outlook

Mozambique's domestic fintech/startup base remains nascent and telecom/bank-linked rather than venture-driven, with a small tracked population of startups and comparatively few funded or acquired entities. The Kuunda and Roscas events indicate external and Africa-focused investor interest is beginning to reach Mozambique specifically, rather than treating it purely as an extension market, but the private-company signal depth for Mozambique remains thin relative to more heavily VC-covered African fintech hubs, a standing gap noted for future cycles.