Everyone has written about the capital increase. Little has been written about what comes after the filing deadline.
A reminder of the calendar, because it governs everything else. COBAC regulation R-2025/02, adopted on 10 December 2025 and in force since 1 January 2026, raises the minimum share capital of banks in the CEMAC zone from 10 to 25 billion CFA francs. The final target is dated 31 December 2029, but it is not reachable in one move: the text imposes a staircase.
| Deadline | Minimum share capital |
|---|---|
| 31 December 2026 | 14 billion FCFA |
| 31 December 2027 | 18 billion FCFA |
| 31 December 2028 | 22 billion FCFA |
| 31 December 2029 | 25 billion FCFA |
And a procedural deadline, distinct from those four: institutions unable to meet the requirement within the timeframe were to submit a capital increase plan to the Secretary General of COBAC no later than 30 June 2026.
That date is behind us. The next one is a little over four months away.
What the first step actually requires
Moving from 10 to 14 billion is a 40 % increase in share capital within a single financial year. For an institution already above the floor, the effort is smaller or nil. For an institution at the floor, it is four billion to find before the year-end close — and "before the close" does not mean "decided before the close", it means paid up and registered before the close.
This is the first source of unpleasant surprise, and it is purely calendar-driven. Between a board decision and effective registration of the capital there is an extraordinary general meeting to convene in due form, statutory notice periods, payment of funds, registration and publication formalities. For an ordinary capital increase in the OHADA zone, that path is not travelled in three weeks. A decision taken in November for a 31 December registration is a decision taken late.
The three routes, and what each really costs
The text leaves banks free to choose their means: cash contributions, capitalisation of reserves or profits, and even recourse to borrowing. That freedom is real, and it is a trap, because the three routes do not produce the same balance sheet or the same shareholding.
Capitalising reserves or profits is the cheapest and fastest route. It brings in no new shareholder, dilutes no one, and converts equity already present into share capital. Its limit is arithmetic: you can only capitalise what prior years left behind. An institution that distributed its results year after year discovers at this exact moment the deferred cost of its dividend policy.
A cash contribution always works, and it is the only route that raises a governance question. If existing shareholders follow, the balance is preserved. If they do not, the capital must be opened — and opening it in the middle of a sector-wide recapitalisation happens in the least favourable balance of power available: the buyer knows you are under regulatory constraint, and knows your date.
Recourse to borrowing is permitted and should be handled with care. Borrowing to strengthen capital means loading the income statement with a financial charge in order to satisfy a solvency requirement. The operation is legitimate, but it is not judged on its feasibility — it is judged on the capacity of net banking income to service that charge for the whole length of the staircase, that is, until 2029.
To these three a fourth is added, which the text has no reason to mention because it is not a means of recapitalisation but a consequence: consolidation. A sector-wide increase in minimum capital is, mechanically, an instrument of consolidation. Institutions that will not reach the target alone will leave the market through acquisition or sale, and that exit is negotiated far better eighteen months before the deadline than three.
What the capital constraint meets on the balance sheet
The difficulty is not only finding the capital. It is finding it while the balance sheet it must cover deteriorates on two fronts at once.
The first front is receivables. In Cameroon, the volume of non-performing loans is growing by around 14.5 % a year according to COBAC. A stock growing at that pace consumes provisioning and regulatory capital at the precise moment when capital must be raised. And there is no organised secondary market in the OHADA zone allowing those receivables to leave the balance sheet — unlike what is currently being built in Morocco, where a draft law governing the direct transfer of non-performing receivables, developed with the support of the International Finance Corporation, will open acquisition beyond regulated institutions alone.
The second front is maturity transformation. On 2 April 2026, the Monetary Policy Committee of the BEAC suspended refinancing operations for medium-term credit intended for productive investment. The Governor confirmed on 29 June that the suspension answered a request from the International Monetary Fund, whose position is that the mechanism should be phased out. Banks in the zone therefore lose one of the few arrangements that allowed them to match medium-term lending with a corresponding resource.
The combination is uncomfortable: capital must be strengthened, with a heavier stock of receivables and without the tool that lengthened the resource. It is exactly the kind of configuration in which the best-prepared institutions take durable market share from those that endure it.
What has to be decided before 31 December
Four points, in this order.
- Check the landing on 31 December 2026, not 2029. The most common framing error is to reason on the final target. The regulator will first observe the 14 billion step. A plan that converges on 25 billion by 2029 but misses the first step is a plan that fails in 2026.
- Recompute the real timetable, in working days. Convening the extraordinary general meeting, statutory notice periods, payment, registration, publication. Set the closing date and work the calendar backwards: the board's decision deadline then appears on its own, and it is almost always nearer than assumed.
- Quantify what can be capitalised before looking for cash. It is the cheapest route and it is systematically under-used. The exact capitalisable amount — available reserves, retained earnings, current-year result — takes a few hours to compute and determines everything else in the plan.
- Address consolidation while it is still a choice. An acquisition negotiated eighteen months before the deadline is a strategic transaction. The same acquisition negotiated in November 2028 is a forced sale, and the price says so.
The point that decides
The 30 June 2026 deadline concerned a plan, not capital. Its passing closes nothing: it merely separated the institutions that formalised a trajectory from those that judged there was still time.
There is indeed time left — but time for one kind of work only. Finding four billion takes months. Deciding how to find it takes weeks. And computing precisely how much is actually needed, once equity is restated and capitalisation is netted off, takes a few days.
That last calculation is where to begin, and it depends on no one but you.
Published 14 August 2026. The regulatory calendar cited is verified as at that date.
