By Gabriella Francesca Paolini, Matthew Freer & Holly Joubert

On 11 May 2026, the Central Bank of Egypt (“CBE”) signed an agreement with the Common Market for Eastern and Southern Africa’s (“COMESA”) Competition and Consumer Commission (“CCCC”). COMESA is a regional trade group covering Eastern and Southern Africa. The deal was signed by the CBE Deputy Governor Mai Aboulnaga and the CCCC Chief Dr Willard Mwemba.  This development carries greater significance than it may initially appear, as it materially alters the application of competition law within Egypt’s banking sector. The Memorandum of Understanding (“MoU”) establishes a formal cooperation framework between CBE and the CCCC, enabling the two authorities to coordinate on merger review, share information, and jointly investigate anti-competitive conduct within Egypt’s banking and financial services sector. To understand why this agreement matters, it must be read alongside the CCCC’s newly adopted 2026-2030 Strategic Plan. The Strategic Plan was published in February 2026 setting out five strategic pillars for the CCCC over its new five-year cycle. These pillars include integrating markets and regulatory harmonisation; effective enforcement and compliance; institutional innovation; contextual leadership; and strategic partnerships and stakeholder engagement. The Plan’s overarching mission is “Advancing Regional Integration through Competitive Markets and Empowered Consumers” (2026-2030 Strategic Plan of COMESA CCCC,2026). This Frames cooperation agreements such as this one not as diplomatic courtesy, but as enforcement infrastructure. This article examines the legal and practical implications of the MoU, situating it within Egypt’s broader history of cooperation with COMESA’s competition framework, and considers what the agreement means for banks, payment providers, and fintech businesses operating across the region.

The current environment

The timing of the MoU is equally significant when read against the broader evolution of COMESA’s competition framework. On 5 December 2025, the COMESA Competition and Consumer Protection Regulations, 2025 came into force, introducing for the first time a dedicated regulatory architecture for digital markets, including a global transaction-value threshold of USD 250 million for mergers involving digital market operators . Fintech and payment-related transactions, by virtue of their data-intensive and multi-sided characteristics, fall squarely within this expanded scope. It is against this backdrop that Dr Willard Mwemba, CEO of the CCCC, welcomed the CBE partnership, noting that it “provides a valuable platform for both institutions to share knowledge and strengthen enforcement of competition laws across member states” (Egyptian Gazette, 2026). Read together, the new digital merger regime and the CBE MoU suggest a deliberate, two-pronged strategy: COMESA is simultaneously expanding its own substantive jurisdiction over digital and fintech transactions, while securing the institutional cooperation, through instruments such as the CBE MoU, necessary to apply that expanded jurisdiction effectively within Egypt’s financial sector specifically.

How We Got Here

Egypt’s first agreement with the CCCC dates back to 2016. The 2016 deal was signed by the Egyptian Competition Authority (“ECA”), not the CBE. It addressed matters relating to information sharing, joint investigations, and avoidance of conflicts of bodies in enforcements, whilst ensuring neither party was required to change their own domestic laws. However, the shortfall with the 2016 agreement is that it did not extend to Egypt’s financial sector. In Egypt, competition rules for the financial sector are not handled by the ECA but rather fall into the jurisdiction of the CBE alone, under the 2020 Central Bank Law. There has been a gap for ten years due to COMESA having no formal link with the regulation of competition involving Egypt’s banking sector (Gazette Staff, 2026).

What the MoU Actually Does

The MoU expressly covers six sub-sectors of Egypt’s financial industry: banking, foreign exchange, money transfers, credit ratings, payment systems, and fintech. This scope reflects both the breadth of cross-border financial activity between Egypt, other COMESA Member States, and the CCCC’s 2026–2030 strategic emphasis on digital financial infrastructure as a priority enforcement area. Operationally, the MoU provides for three core cooperation mechanisms. Firstly, the investigative coordination where the CBE and CCCC may now coordinate on competition cases that have cross-border dimensions within the financial sector. Secondly, expertise and information exchange, the two institutions may share knowledge, data, and analytical capacity on issues of common concern. Thirdly, capacity building, the MoU contemplates structured technical assistance to strengthen the CBE’s competition enforcement capabilities over time. A particularly significant operational development arising from the MoU is that the CBE will establish a dedicated internal competition unit to manage implementation. This is a meaningful institutional commitment. It signals that the CBE intends to treat competition oversight in the financial sector as an ongoing operational function, rather than an ad hoc responsibility. For regulated entities, it is a clearer interlocutory for competition-related queries and procedures within the central bank.

What the New Deal Changes

The 2026 MoU fills the gap. The CBE is now the first central bank in COMESA, and the first sector-specific regulator of any kind, to sign a deal of this nature with the CCCC. It covers banking, foreign exchange, money transfers, credit ratings, payment systems, and fintech. Officials refer to it as a step toward “regional integration” and “fair competition.” Although this is an accurate statement, it undersells the practical changes pertaining to which Egyptian authority now works with COMESA on bank-related competition issues, and what that means for any bank or fintech doing business across the region.

Why It Matters

The biggest change resulting from the MoU is how the CBE and CCCC cases now connect. Before the MoU, the two processes were completely separated: anything admitted to one authority did not affect the other. A positive consequence of this change is that it reduces the risk of the CBE and CCCC reaching different conclusions in relation to the same matters. However, this arrangement creates the possibility that adverse findings or commitments made against a party before one authority may be relied upon against that party in proceedings before another authority.

Egypt now has two agreements with COMESA, the old 2016 agreement focusing on general competition and the new 2026 agreement with the CBE, focusing on the financial sector. The CBE and ECA have collaborated informally on anti-trust and merger cases that overlap; however, it is unclear how the new agreement affects this relationship. This question is sharpened by a further point of friction regarding COMESA’s “one-stop-shop” merger review mechanism, under which the CCCC’s clearance of a qualifying regional merger can substitute for separate national notifications across Member States, but this does not apply to Egypt. If that position holds, then the CBE’s accession to a cooperative framework with the CCCC, specifically in relation to merger control in the financial sector, creates an apparent asymmetry. COMESA-level coordination on financial-sector mergers may now operate co-operatively in substance even as the ECA maintains that the formal “one-stop-shop” mechanism is inapplicable to Egyptian merger notifications generally. Reconciling these two positions, in principle and in practice, is likely to be tested in the cases that follow.

The MoU’s express inclusion of payment systems, payment service providers, and financial technology businesses is also notable, and reflects a broader regional trend of competition regulators extending their analytical frameworks to digital financial infrastructure. Fintech mergers and platform-based payment arrangements often raise competition concerns, network effects, data advantages, multi-sided market dynamics, that sit awkwardly within traditional banking competition analysis (European Parliament, 2019). By bringing this sector explicitly within the CBE-CCCC cooperative framework from the outset, the MoU positions Egypt’s central bank to engage with COMESA on what is likely to be one of the more active areas of cross-border competition enforcement in the coming years.

Closing Remarks

The 2026 MoU is more than just a symbolic step toward “regional oversight”, it is the financial-sector version of the 2016 Agreement, finally closing a gap left when Egypt’s financial sector was taken out of the ECA’s control. For lawyers working with banks and fintechs in the region, should shape how they handle admissions and commitments before both authorities going forward.