As countries expand instant payment systems, regulators are confronting what could be the harder part of the continent’s digital payment transformation: harmonising rules so that national and regional systems can communicate and make cross-border payments as seamless as domestic ones.

Someone in Rwanda can send money locally within seconds through mobile money or an instant payment system. But a business trying to pay a supplier elsewhere in Africa may still face higher costs, currency conversion, additional compliance requirements and more intermediaries.

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Sabine Mensah, Deputy Chief Executive Officer of AfricaNenda Foundation, a non-profit that works with central banks to develop inclusive instant payment, Africa's cross-border payment challenge is less about the effectiveness of technologies and more about regulators' failure to work together.

"Finding the option to be able to do cross-border payment instantly sometimes is difficult, and the options that are currently available for cross-border payment sometimes are expensive,” she said.

A seamless cross-border system, she said, would allow businesses to pay suppliers and receive money from customers elsewhere in Africa almost as easily as they transact domestically.

Africa has already made considerable progress in developing the underlying infrastructure. The State of Inclusive Instant Payment Systems in Africa 2025 (SIIPS 2025) report counted 36 live instant payment systems as of June 2025, comprising 33 domestic systems across 25 countries and three regions.

In Rwanda, following the full migration to eKash, transactions reached 14.6 million in the first two weeks, worth about Rwf1.2 trillion, according to the BNR.

Governor Soraya Hakuziyaremye said active users had reached about 4.7 million, demonstrating growing adoption of affordable instant payments.

Nick Barigye, Deputy Governor of the central bank, said eKash is expected to increase digital payments, reduce charges and transaction times, and provide financial service providers with common infrastructure.

The bigger question is how systems such as eKash can eventually connect efficiently with payment systems beyond national borders.

Currency challenges

Africa has more than 40 currencies. Where two currencies cannot easily be exchanged directly, a transaction may first be converted into a hard currency such as the US dollar or euro before being converted again into the recipient country’s currency.

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Africa is estimated to incur about $5 billion annually in payment transaction costs, including transaction fees, currency-conversion spreads and inefficient international routing mechanisms. Afreximbank has said full implementation of PAPSS could save the continent more than $5 billion annually in payment transaction costs.

Mensah argues that technology is no longer the principal obstacle. The bigger challenge is establishing rules that allow payments to cross borders without being delayed by conflicting regulatory requirements.

For example, one country may require only an identification document from a customer conducting a transaction, while another may also demand proof of address and a bank reference.

"So it means that even if I send instantly, the receiver might still have challenges to receive it instantly because the requirements are quite different,” Mensah explained.

Differences also exist in anti-money laundering rules, transaction limits, exchange controls, consumer onboarding, data localisation and supervision.

"There needs to be coherence between domestic regulation, regional regulation, and then before you go into the Pan-African organisation,” she said.

Mensah said aligning domestic and regional regulations can take years as regulators identify areas of convergence and determine where mutual recognition is possible.

Could one fintech licence work across Africa?

Fintech licensing is one area where harmonisation could have an immediate impact. A fintech wishing to provide payment services across several African markets may need to obtain a separate licence in each jurisdiction, increasing the cost and time required to expand.

Mensah advocates for fintech licence passporting, through which regulators develop comparable standards and recognise licences issued by one another.

Rwanda has already pursued arrangements with countries including Ghana and Kenya aimed at making fintech expansion between markets easier.

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Similar harmonisation could apply to customer due diligence, anti-money laundering requirements and digital identity.

"We need digital identity to support interoperability. That should be prioritised,” Mensah said.

The Association of African Central Banks has also directed its Task Force on Payment Systems Integration to prioritise regulatory harmonisation for cross-border payments, with AfricaNenda and the African Union Commission supporting the agenda.

Mensah said progress does not require every country to move at the same pace. More advanced markets can begin testing cross-border interoperability while others continue strengthening their domestic systems.

For millions of African small businesses, easier payments could mean sourcing goods from another country, serving customers beyond their domestic market and receiving money without costly intermediaries.