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The Legal and Regulatory Framework of Mobile Banking in Zimbabwe

In terms of the Banking Act [Chapter 24:20] mobile banking refers to an arrangement which allows a customer of a banking institution or a licensee under the Postal and Telecommunications Act [Chapter 12:05], or any other operator of a wireless communication system to access any financial service activities through a mobile device, whether the arrangement is operated by the banking institution, licensee or operator concerned or by an independent operator. The increased use of and reliance on mobile banking by the ordinary Zimbabwean who has a “mobile money wallet” has necessitated the need for a legal and regulatory framework of mobile payments in Zimbabwe.

Resultantly, the Minister of Finance, Economic Development and Investment Promotion in Zimbabwe published the Banking (Money Transmission, Mobile Money and Mobile Money Interoperability) Regulations, 2020 as read with the Banking (Money Transmission, Mobile Money and Money Interoperability) (Amendment) Regulations, 2025 (No. 1) (the Regulations) which set out the legal and regulatory framework of mobile money transactions and / or payments in Zimbabwe. see also, F Muzeya and F Hamadzipiri, ‘Reconsidering the Banker Customer Relationship in the Context of Mobile Banking in Zimbabwe’ 2025 Potchefstroom Electronic Law Journal 28: 1 – 28.

In terms of the Regulations, all mobile money providers in Zimbabwe are required to be licensed in terms of the Regulations. Furthermore, any person desiring to become a money transmission provider and / or mobile banking provider in Zimbabwe is required by law to be registered. It is a further requirement of the Regulations, that all money transmission providers and mobile banking providers in Zimbabwe obtain recognition of their payment systems in terms of the National Payment Systems Act [Chapter 24:23].