A new regulation adopted unanimously in Bata, Equatorial Guinea, on December 19, 2025, is shifting the burden of credit risk within the Central African Economic and Monetary Community (CEMAC). Regulation No. 05/25/CEMAC/UMAC/CM/COBAC introduces a system of “mise à l’index,” or blacklisting, for borrowers who default on loans, effectively barring them from accessing financial services across the six-nation economic zone.
Historically, CEMAC’s regulatory framework focused on the solvency of banks, classifying bad debts, and requiring robust provisioning. This “institutional” approach, as it’s been termed, is now being supplemented by direct accountability for borrowers. The new regulation marks a significant departure, intervening directly in the debtor’s assets and contractual freedom to restore market discipline, according to analysis of the rule.
The “mise à l’index” is defined as an administrative police measure with broad coercive effect, essentially prohibiting defaulting clients from making withdrawals or opening new accounts within the CEMAC zone. This measure comes as the CEMAC banking system grapples with a decade-long increase in compromised assets, weakening bank balance sheets and reducing their capacity to finance the real economy.
The move reflects growing concerns about liquidity pressures within the CEMAC market, even after monetary easing measures, including a rate cut in March 2025, and increased liquidity injections. Fitch Ratings reported in September 2025 that liquidity conditions remained strained despite these efforts, and the market faces significant refinancing needs.
Recent economic performance within CEMAC has been mixed. While the economy showed some momentum in 2024, with easing inflation, the external position weakened, with a rising current account deficit and stagnant reserve coverage, according to an IMF report from July 2025. Fiscal positions are also deteriorating, indicating substantial budgetary slippages.
The heads of state of CEMAC nations recently acknowledged recurring challenges including declining foreign exchange reserves, over-reliance on raw materials, and insufficient implementation of structural reforms. The new regulation appears to be a response to these systemic issues, aiming to address the root causes of financial instability by increasing borrower responsibility.
The regulation raises fundamental questions regarding debt obligations and civil liberties, though the full implications of its implementation remain to be seen. The COBAC, the banking supervisory body for CEMAC, has not yet issued further guidance on the practical application of the “mise à l’index” procedure.
