Why a new doctrine in 2026?
CREPMF is WAEMU's capital markets regulator. Its instructions frame broker operations, investor protection, and market access rules. The 2026 doctrine, published by circular in March, addresses three concrete concerns: easing diaspora access, harmonising KYC practices across brokers, and strengthening fee transparency.
Three major changes for the diaspora
1. Explicit recognition of cryptographically signed unified KYC
For the first time, the circular grants legal value to Ed25519-signed KYC portable across licensed brokers. This legally anchors the model used by Inopay since 2024. Practical consequence: an investor completing KYC once can use it across any partner broker — saving the 10-15 day cycle each time.
2. New enhanced due diligence thresholds
Enhanced DD triggers move from 5M FCFA to 10M FCFA annual order volume for non-resident individuals. Above that, the broker must collect source-of-funds proof and, where relevant, a W-8BEN-equivalent document.
3. Fee transparency obligation
Brokers must publish a clear fee schedule on their site (brokerage, custody, FX). Hidden fees (opaque spreads, undisclosed execution commissions) are now explicitly sanctionable.
Practical implications
For diaspora investors
- Usable unified KYC: choose a partner broker within a portable KYC network (Inopay) to avoid redoing the dossier elsewhere later.
- Clearer DD: below 10M FCFA/year, the file stays light; above, prepare a source-of-funds proof.
- Easier fee comparison: brokers must publish schedules — useful for negotiation.
For brokers
- Invest in technical interoperability: ingestion and verification APIs for external KYC.
- Update regulatory reporting tools.
- Annual fee review with publication.
Timeline
New provisions apply from July 1, 2026, with a transition window to December 31, 2026 for broker system compliance. Investors already active have no immediate action — compliance is the broker's responsibility.
What about other markets?
COSUMAF (BVMAC regulator, CEMAC) is watching CREPMF's evolution closely and may harmonise by end-2026. Ghana SEC follows its own timeline but already recognises cross-broker unified KYC since 2023.
References
- CREPMF Circular 2026-03 on unified KYC doctrine.
- APSGI explanatory note.
- COSUMAF / SEC Ghana comparative analysis — Inopay Research, March 2026.