Jean Claude Nshimiyimana, a Commercial Lawyer with ENS Rwanda.

In a significant stride towards promoting financial innovation, the Capital Market Authority (CMA) of Rwanda has introduced Guidelines n° 002/CMA_G/2023, dated 27/04/2023. These guidelines govern the Fintech Regulatory Sandbox for Capital Markets, creating a controlled environment for fintech innovators to test their products and services, ensuring a balanced approach between innovation and regulatory oversight.

Embracing Digital Transformation

Rwanda’s financial sector is experiencing rapid transformation driven by evolving financial technologies (Fintech). These innovations are reshaping market structures and creating new business models, offering financial products and services more efficiently. The Fintech Regulatory Sandbox (the “CMA Sandbox”) is designed to embrace this digital transformation, particularly within Rwanda’s capital markets, where fintech innovations are already making a significant impact across the entire value chain.

Key Objectives of the CMA Sandbox

The primary goal of the CMA Sandbox is to provide a conducive regulatory environment that encourages the deployment of a variety of fintech innovations. This aligns with Rwanda’s vision to become a leading international financial center renowned for its innovative and secure technologies. The CMA Sandbox serves as a live testing ground for capital market-related fintech innovations, ensuring they are viable and safe before being launched into the broader market.

Highlights of the Guidelines

The guidelines comprehensively outline the eligibility criteria, application process, operationalisation, and reporting requirements for participation in the sandbox. Here are some key highlights:

Eligibility Criteria

  • Applicants must be incorporated in Rwanda or licensed by a securities market regulator in an equivalent jurisdiction.
  • Required documentation includes registration certificates, CVs of founders and key management, and a detailed application form.

Application and Approval Process

  • The process is divided into three stages: Application, Evaluation, and Experimentation.
  • CMA reviews applications on a rolling basis, providing feedback within 15 working days.

Testing and Reporting

  • Participants must submit a detailed testing plan, including objectives, scope, methodologies, and success criteria.
  • Monthly interim reports are required during the testing period, along with a final report upon completion.

Exit Strategy

  • Post-testing, participants may proceed to a broader market deployment or discontinue the innovation based on CMA’s assessment and predefined exit strategies.

Scope of the CMA Sandbox

The CMA Sandbox encompasses fintech innovations across the entire value chain of the securities market, including but not limited to:

  • Capital Raising: Equity and debt-based crowdfunding.
  • Brokerage and Trading: Securities borrowing and lending, clearing, and settlement.
  • Investment Management: Saving and investment/wealth management.
  • Advisory and Corporate Finance: Investment advisory and corporate finance.
  • Credit Ratings
  • Commodity Exchange and Derivatives: Including Over-The-Counter (OTC) derivatives.
  • Regulatory and Supervisory Technologies: RegTech and SupTech solutions.

Benefits of the CMA Sandbox

The CMA Sandbox offers numerous benefits for all stakeholders:

For Innovators

  • Reduces regulatory uncertainty.
  • Provides a controlled environment to refine and perfect innovations.

For CMA

  • Enhances understanding of fintech products and services.
  • Informs the creation or amendment of regulations to foster innovation.

For Investors

  • Ensures investments are secure.
  • Protects against potential scams or failures.

Rwanda’s CMA Sandbox is a testament to the nation’s commitment to embracing financial innovation while maintaining a secure and regulated market environment. This initiative invites both startups and established firms to bring their fintech innovations to Rwanda, contributing to the nation’s goal of becoming a leading financial hub.

These guidelines mark a pivotal step in Rwanda’s journey towards a technologically advanced and inclusive financial system. Innovators are encouraged to apply and take advantage of this unique opportunity to shape the future of Rwanda’s capital markets.

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About the Author

Jean Claude Nshimiyimana is a licensed Commercial Lawyer at ENS Rwanda. A member of the Rwanda Bar Association, he excels in advising and representing clients on commercial aspects of Rwandan law, which include trademarks, business structuring, company and NGO registration and de-registration, mergers and acquisition, real estate acquisitions, employment law and data protection and privacy, fintech and regulatory compliance. He is fluent in English, Kinyarwanda, French and Kiswahili and can be reached via +250788921438.

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