A chief risk officer at a bank in the CEMAC zone has three ways of handling a non-performing file: pursue it internally, provision it and wait, or write it off. They are the same three as twenty years ago.
There is a fourth, ordinary in most banking systems in the world, and it has no organised existence here: sell it.
This is not a legal gap. Assignment of receivables is perfectly available under civil law and under OHADA law; nothing prevents a bank from transferring a portfolio of unpaid receivables. What is missing is everything else: a dedicated regime, identified acquirers, a shared valuation method, predictable prudential and tax treatment, and enough market practice for price to stop being a blind negotiation between two parties who have never done the transaction.
One country on the continent is building precisely that. It is worth looking at what it is building, because the question will eventually be asked here.
What Morocco is putting in place
The Moroccan project is not an intention. A draft law governing the direct transfer of non-performing receivables held by credit institutions and similar bodies has been transmitted to the Secretariat General of the Government and opened to public consultation. It was developed with the technical support of the International Finance Corporation, and its objective is stated: to give legal structure to a secondary market in impaired loans, and to give banks an operational tool for lightening their balance sheets.
The order of magnitude driving the work is a growing stock: non-performing receivables in the Moroccan banking system rose by around 5 % to reach 102.3 billion dirhams.
Two provisions of the text deserve the attention of a banker in the OHADA zone, because they are exactly the two locks that block a transfer here.
First: the transfer does not require the debtor's consent, save contrary contractual stipulation. This is what makes a portfolio transfer practicable. A regime requiring the consent of each defaulting debtor across a portfolio of several hundred files is not a market — it is a collection of individual negotiations with counterparties who have no interest in cooperating.
Second: the market opens beyond regulated institutions alone. By derogation from existing restrictions, any person will be able to acquire one or more non-performing receivables. This is the point that decides whether a price exists. A market reserved to banks is a market where the potential buyers have exactly the same problem as the sellers, at the same point in the cycle. An open market brings in actors whose business is precisely to handle what banks no longer wish to handle — and it is that entry which creates demand, and therefore a quotation.
Why this concerns us, with figures
The zone does not have this project. It has the problem.
In Cameroon, non-performing loans are growing by around 14.5 % a year in volume, according to COBAC. This is not a stock ratio — it is a rate of accumulation, and that is what makes it a structural rather than a cyclical matter: a stock growing at that pace doubles in five years if nothing drains it.
And nothing drains it. In a system without a secondary market, an impaired receivable remains on the balance sheet of the bank that produced it, until recovery or write-off. There it consumes three things at once: provisioning, regulatory capital, and above all the time of your recovery teams — the very time that is not going to recoverable files.
This immobilisation arrives at the worst point in the regulatory cycle. COBAC regulation R-2025/02, adopted on 10 December 2025 and in force since 1 January 2026, raises the minimum share capital of banks from 10 to 25 billion CFA francs on a dated staircase: 14 billion by 31 December 2026, 18 billion by end-2027, 22 billion by end-2028, 25 billion by end-2029. The capital increase plan was to be filed with the Secretary General of COBAC no later than 30 June 2026.
An institution that must raise capital while its balance sheet carries a growing stock of immobilised receivables raises it more expensively. Every impaired receivable removed from the balance sheet before the reference year is capital that no longer needs to be raised.
What a chief risk officer can do without waiting for a text
The absence of an organised market does not prohibit transactions. It simply makes them more expensive to structure, and places the whole structuring burden on the seller. Three work streams are open today, and none requires new legislation.
The first is legibility of the impaired portfolio. Nobody buys what they cannot value. A sellable portfolio is described in cohorts — age of the arrears, nature and ranking of the security, existence of an enforceable title, sector, average ticket, actual recovery history. A portfolio presented as a single global figure is unsellable: the buyer then applies the discount of the worst file to the whole. Granularity is worth money, literally.
The second is the quality of the security, and it is decisive under OHADA law. The Uniform Act organising securities and the Uniform Act organising simplified recovery procedures and enforcement measures provide real instruments. But the security must have been validly constituted, registered, and still enforceable at the time of transfer. A receivable backed by a poorly formalised guarantee does not sell: it is given away. This is the most profitable work in the whole exercise, because it is done on documents, in your own archives, dependent on no one.
The third is the intermediate route, often the right first step: outsourced recovery without transfer. The receivable stays on the balance sheet, but the handling leaves the house. That does not release regulatory capital, but it releases the scarcest resource — the time of analysts who should be assessing new credit rather than chasing files from 2019. And this route has a property that transfer does not: it produces, file after file, the performance data that will one day allow the portfolio to be properly valued should a decision to sell be taken.
The direction of travel, and the window
Two elements indicate that the question will not stay open indefinitely.
The first is that the CEMAC Credit Information Bureau entered service in January 2026, operated by Creditinfo Central Africa under the aegis of the BEAC and the International Finance Corporation, with deployment already extended to the Central African Republic, Chad and Congo, and full sub-regional coverage targeted for 2028. A market in receivables presupposes shared information on debtors; that infrastructure is being laid.
The second is that it is the same institution — the International Finance Corporation — that provides technical support to the Moroccan project and operates the credit bureau here. Instruments travel.
The question is therefore not whether a transfer regime will eventually exist in the OHADA zone. It is which institutions will have, on the day it does, an impaired portfolio described in cohorts, verified security and a documented recovery history — and which will present an opaque stock that no buyer can price.
That work is not done in six weeks. It is done now, on files already in arrears, and it requires no authorisation.
Published 14 August 2026. The status of the Moroccan draft law and the CEMAC regulatory calendar cited are verified as at that date.
