A New Lex Informatica for CEMAC Finance: Navigating the BEAC’s Mandatory Migration to ISO 20022

Fonyam & Partners | Legal & Regulatory Advisory

A quiet but profound revolution is underway in the financial architecture of the Central African Economic and Monetary Community (CEMAC). With the issuance of Instruction N° 001/GR/2025, the Governor of the Bank of Central African States (BEAC) has enacted a binding mandate that will fundamentally recalibrate the region’s payment systems. The subject of this seismic shift is the adoption of the ISO 20022 standard, a move that aligns CEMAC with a global financial migration already in progress.

For financial institutions in Cameroon and across the CEMAC, this is not a mere technical update; it is a new lex informatica—a law of the digital realm—that carries the full force of regulation. Compliance is not optional. This article provides a foundational analysis of the Instruction and outlines the critical path to adherence.

The Core Mandate: A Tripartite Standardization

Article 1 of the Instruction establishes the ISO 20022 standard, specifically under the “ISO Accelerator Pack (IAP)” variant, as the new legal and technical foundation for all payments within CEMAC’s systems. This move is rooted in the BEAC’s stated objectives to:

· Enhance Interoperability: Ensure the CEMAC financial system remains seamlessly connected to the global financial community.

· Improve Security & Service Continuity: Address the evolving risks and operational demands of modern payment ecosystems.

· Adopt Global Best Practices: Elevate the region’s financial infrastructure to international standards.

The practical implementation of this mandate is detailed in Article 3, which prescribes a tripartite framework for message formats:

For International Flows: The SWIFT CBPR+ rulebook.

For Domestic High-Value Flows: The BEAC_SYGMA_ISO20022 rulebook.

For Domestic Retail Flows: The BEAC_SYSTAC_ISO20022 rulebook.

This delineation is crucial. It means that institutions must prepare to operate different technical specifications for cross-border, domestic large-value (via the SYGMA RTGS system), and domestic retail (via SYSTAC 2) payments, all under the overarching ISO 20022 umbrella.

The Scope of Application: A Broad Cast Net

The reach of this Instruction is extensive. Per Article 2, it applies to all entities whose payment platforms interact with BEAC-managed payment and settlement systems, specifically SYGMA and SYSTAC2. The list of “assujettis” (regulated entities) is deliberately comprehensive and includes:

· Credit Institutions (Banks)

· Microfinance Establishments

· Payment Institutions

· BEAC-authorized Managers of Interbank Payment Systems

· Public Treasuries

· National Postal Financial Services

· Other Financial Institutions

Critically, the Instruction also applies to “any other structure” that interacts with SYGMA. This catch-all clause provides the BEAC with broad regulatory latitude, potentially encompassing fintech companies, large corporates with direct access, and other non-traditional financial actors.

Legal Obligations & The Imperative of Compliance

Articles 4 and 5 articulate the core legal obligations for regulated entities.

First, Article 4 imposes a positive duty on all assujettis to “take the necessary measures” to align their processes with the new formats in accordance with the regional migration calendar (annexed to the Instruction). This is a proactive obligation. Institutions must:

· Audit their current systems and map the gaps against the new BEAC and CBPR+ specifications.

· Acquire and implement the technical specifications published on the SWIFT mystandards portal, access to which will be governed by a forthcoming BEAC circular.

· Adhere to the prescribed technical specifications without deviation.

· Strictly follow the regional migration timeline. Delay is not a strategic option; it is a regulatory failure.

Second, Article 5 offers a lifeline. The BEAC has committed to providing technical support through its SYSTAC2 and SYGMA V10 project teams. Prudent institutions will proactively engage with these teams to clarify ambiguities and validate their implementation plans. Documenting these engagements may also serve as evidence of good-faith compliance efforts should any issues arise.

Strategic Recommendations for Financial Institutions

The BEAC has set the wheels in motion. The time for strategic action is now.

Constitute a Cross-Functional Task Force: This is not solely an IT project. Legal, compliance, operations, and business development teams must be involved from the outset to address the multifaceted impact on processes, contracts, and customer interactions.

Secure the Official Documentation: Immediately initiate the process to obtain the BEAC circular detailing access to the mystandards portal and secure the requisite rulebooks and technical specifications.

Conduct a Gap Analysis: Perform a comprehensive legal and technical gap analysis comparing current messaging practices and system capabilities against the new ISO 20022 requirements.

Develop a Phased Migration Plan: Align your internal project plan precisely with the BEAC’s annexed calendar. Build in contingencies for testing and unforeseen complexities.

Engage with the BEAC: Proactively communicate with the central bank’s project teams for guidance. A collaborative approach will mitigate risk.

Review and Update Internal Policies: Ensure that internal operational manuals, risk management frameworks, and compliance policies are updated to reflect the new messaging standards and processes.

Conclusion

Instruction N° 001/GR/2025 is a definitive step towards the modernization and integration of the CEMAC financial landscape. While the path to compliance demands significant investment and operational overhaul, the long-term benefits of enhanced efficiency, richer data, and global interoperability are substantial.

For our clients and all financial actors in Cameroon and the CEMAC region, the message is clear: The era of ISO 20022 has been legislated into existence. The imperative to adapt is immediate, and the cost of inaction will be both operational and regulatory. Our firm is positioned to advise on the full spectrum of legal and compliance challenges associated with this migration.

By Banyong Fonyam Jonie Jr.