Franc zone: two banking reforms, two calendars

Two reforms are moving in parallel across the franc zone, and they are not alike. In the south, the Central African Banking Commission raised the minimum share capital of CEMAC credit institutions from 10 to 25 billion CFA francs, a 150% increase in force since 1 January 2026, with compliance steps running to 2029. In the west, the new uniform banking law of WAMU follows a different path: it is transposed state by state, on different dates.

The difference in form matters as much as the substance. A community regulation applies everywhere at once. A uniform law must be taken up by each national parliament: Benin has adopted it, Côte d'Ivoire approved its updated framework in cabinet at the end of April 2026, Burkina Faso followed at the end of June. On paper the rule is common to the eight member states. In practice, it does not yet apply everywhere at the same time.

Going from 10 to 25 billion CFA francs over five years is not a year-end balance-sheet exercise. It is a trajectory: dated steps, shareholder trade-offs, sometimes mergers, and a governance that must account for its progress to the regulator and to its own board.

The first step sits at the end of this year, not at the end of the road: 14 billion CFA francs on 31 December 2026. Institutions unable to reach it had to file a strengthening plan with COBAC's General Secretariat before 30 June 2026, a deadline now past. In other words, the question facing boards this autumn is no longer the 2029 target but the gap on 31 December.

Institutions that treat this reform as an isolated legal file discover late that it commits their growth strategy, their distribution policy and their funding plan. Those that treat it as a transformation programme know, at every review, where they stand against the next step.

For a banking group present in several countries of the zone, asynchronous transposition creates a blind spot. Head office steers an average compliance, while requirements are not identical from one subsidiary to the next at the same moment. The subsidiary ahead carries constraints its neighbour does not yet know; the one behind becomes the group's weak point on inspection day.

The answer fits in one sentence: measure subsidiary by subsidiary, consolidate afterwards. That is the opposite of common practice, which consolidates first and discovers the gaps during the review. One diagnostic per institution, on the same prudential framework, makes the gap visible before it becomes a finding.

Both reforms share the same base of requirements: governance and internal control, overall risk management, capital adequacy, customer protection. That base is measured once, on a single scale, then projected onto the text applicable to each institution, a BCEAO instruction on one side, a COBAC regulation on the other.

This is what allows like to be compared with like: the maturity of an Abidjan subsidiary and that of a Douala subsidiary, on the same themes, with different local requirements. And it converts the gap into a dated action plan whose milestones fall before the regulator's, not after.