The legal framework for competition and consumer protection in Rwanda has been revamped with the enactment of Law n° 011/2026 of 26/02/2026 relating to competition and consumer protection (the “New Competition and Consumer Protection Act”). The New Competition and Consumer Protection Act replaces the decade-old Law nº 36/2012 of 21/09/2012 relating to competition and consumer protection (the “Competition and Consumer Protection Act of 2012”) and is designed to bring Rwanda’s regulatory framework for competition and consumer protection with the demands of the 21st-century global market. Why the revamp? The decision to move away from the Competition and Consumer Protection Act of 2012 was driven by several strategic necessities outlined in the New Competition and Consumer Protection Policy adopted in September 2023. After 12 years, the Competition and Consumer Protection Act of 2012 struggled to address emerging market trends, particularly the rapid growth of the digital economy. Moreover, as Rwanda deepens its integration into regional and continental blocs, it became imperative to harmonise domestic laws with the competition regimes of the East African Community (EAC), the Common Market for Eastern and Southern Africa (COMESA), and the African Continental Free Trade Area (AfCFTA). The New Competition and Consumer Protection Act serves as a modern toolkit to ensure market operations remain competitive while strongly protecting consumer interests in a cross-border context. The New Competition and Consumer Protection Act introduces several pioneering concepts that were absent in the Competition and Consumer Protection Act of 2012. Regulation of digital markets and e-commerce For the first time, Rwanda has established detailed obligations for e-commerce enterprises and online intermediaries. This includes mandatory disclosure of self-identifying information, including registration numbers and physical addresses, clear rules on digital distance contracts, and a defined right of withdrawal allowing consumers to cancel online purchases within seven days of receiving a good or service (Article 42 of New Competition and Consumer Protection Act). Regulation of Multi-Level Marketing Models The Competition and Consumer Protection Act of 2012 was silent on chain-based business models, which often led to fraudulent schemes. The New Competition and Consumer Protection Act recognises and regulates legitimate Multi-Level Marketing while distinguishing it from prohibited pyramid schemes (Article 71 & 72 of New Competition and Consumer Protection Act). Integration of sustainability and climate change into competition assessment Charting a future-oriented course, the New Competition and Consumer Protection Act integrates environmental considerations into competition assessment. Rwanda Inspectorate, Competition and Consumer Protection Authority (RICA) can now grant exceptions for anti-competitive agreements if they contribute significantly to an ecologically sustainable or climate-neutral economy. Monitoring of state subsidies and market distortions To prevent market distortions, public institutions are now required to consult RICA before granting significant subsidies that exceed a specified threshold, ensuring they do not unfairly tilt the competitive playing field. Beyond new introductions, the new act refines existing protections. Expanded definition of the consumer Protection is no longer limited to the direct purchaser. The definition now includes anyone authorised by the direct consumer to use a product or service, broadening the umbrella of legal recourse. Establishment of an independent appeal committee To reduce the burden on the court system and provide specialised dispute resolution, the New Competition and Consumer Protection Act establishes an Independent Appeal Committee. This body will decide on appeals against RICA decisions, offering a faster, expert-led administrative path for aggrieved parties (Article 64 of New Competition and Consumer Protection Act). Deterrent sanctions for non-compliance The New Competition and Consumer Protection Act introduces a more sophisticated and deterrent sanctions regime, moving away from the broader penalties of the Competition and Consumer Protection Act of 2012 to ensure proportionality and compliance. Anti-competitive practices such as prohibited horizontal agreements or abuse of a dominant position are now subject to administrative fines not exceeding 5% of an enterprise's annual turnover from the preceding year, whereas selling goods or services that do not meet quality standards is subject to fines reaching up to Rwf 5,000,000. Recidivists are subject to administrative fines that are doubled for a second offense and quadrupled for a third offense committed within two years. Introduction of leniency and settlement mechanisms To better detect hardcore cartels, the New Competition and Consumer Protection Act introduced a leniency programme that allows businesses that voluntarily disclose their participation in illegal horizontal agreements to receive a waiver or reduction of fines. The era of regulatory ambiguity in digital and network marketing in Rwanda is over, all existing e-commerce operators are granted a six-month grace period from March 4, 2026, to bring their operations into full conformity with the New Competition and Consumer Protection Act. Businesses should immediately review their consumer contracts to ensure they do not contain newly prohibited abusive clauses and audit their pricing displays to avoid misleading representations. The author is a corporate and legal services lead at Andersen, a tax, legal, and business advisory firm in Rwanda.
