Financial services, broadly comprising banking and non-banking financial institutions (primarily insurers and excluding private capital), were not the focus of competition regulators in 2025. This is notwithstanding the continuing blockbuster litigation in South Africa regarding the alleged manipulation of the Rand and the resolution of an alleged cartel in Namibia involving the Payments Association of Namibia and its members ostensibly agreeing on setting interchange fees.
While competition regulators did not focus on financial institutions for competition enforcement in 2025, we saw them take both market conduct and enforcement action on the consumer protection side. In Nigeria, the Federal Competition and Consumer Protection Commission (FCCPC) took a landmark step by introducing the Digital, Electronic, Online, or Non-Traditional Consumer Lending Regulations. This framework was designed to curb abusive practices by unregulated digital lenders and follows some years after the Competition Authority of Kenya (in partnership with Innovations for Poverty Action) conducted a Digital Credit Market Inquiry on the challenges and other risks in the regulated and unregulated digital credit markets. The results of this inquiry were published in May 2021. We expect other competition agencies in Africa to turn their attention to digital credit markets as more fintechs enter this space.
For the non-banking financial institutions in South Africa, the South African Competition Commission’s (SACC) three-year investigation into alleged cartel conduct by eight of the country’s largest insurers, remains ongoing. The question on everyone’s mind is whether 2026 may mark the year in which the SACC finalises its investigation.
Looking ahead, we expect that the banking sector will face three new challenges:
- curbs on interest charged on credit card debts following US President Trump’s criticism of these fees;
- in South Africa, the SACC’s recently announced (although it commenced in 2021) investigation into practices relating to the prime lending rate; and
- either a market inquiry or a move towards one in South Africa, focused on lending practices to SMEs and firms owned or controlled by historically disadvantaged persons – notably, this topic received substantial interest at the SACC Annual Competition Law Economics & Policy Conference in September 2025.
This will be in addition to deepening vertical integration of banks into the fintech sector, with Nedbank having acquired Ikhokha in late 2025, Capitec acquiring Walletdoc and the South African Reserve Bank acquiring a 50% stake in BankServeAfrica, the parent company of Payshap in South Africa. Conversely, Flutterwave, Africa’s leading payments technology company headquartered in Nigeria, has acquired Mono, a pioneer in open banking infrastructure across the continent. A further notable development in South Africa’s fintech space is the announcement in early February 2026 of ZARU, a Rand‑backed stablecoin launched by financial institutions Luno, EasyEquities (part of Sanlam) and Lesaka. This consolidation between traditional banking and fintechs is likely to filter through to other markets in sub-Saharan Africa, with Kenya the likely next stop.
On the M&A trail, we anticipate well-capitalised banks making strategic plays for rivals’ operations in other jurisdictions (e.g. Access Bank’s acquisition of Bidvest Bank in South Africa, ABSA’s acquisition of Standard Chartered Bank in Uganda and FNB’s acquisition of Standard Chartered Bank in Zambia). Indeed, Nedbank’s proposed acquisition of NCBA in Kenya was recently announced.
As businesses and people move across the continent to take advantage of entitlements and opportunities under AfCFTA, the low-fee movement of money, both for personal and business use, will become an important consideration. This opens up a new world of possibilities for the introduction of stablecoins, with ABSA (in partnership with Luno) and Standard Bank already trialling offerings in this regard. This will test how competition regulators understand and define markets, which until now, have been largely the preserve of banks, international card schemes and banking regulators.
In South Africa, the SARB has for some time now been considering introducing a framework for domestic card schemes. Again, this will have implications for enforcement in an attempt to stimulate demand for or support the entry of, domestic card schemes into the market. Indeed, the world’s largest fintech, Revolut, has applied for its first full commercial banking licence in Africa, in South Africa.
For both banking and non-banking players, partnerships and the terms of such partnerships will continue to be key. A focus for competition regulators will be whether these partnerships are exclusive, what their durations are and whether they cover cross-border trade. On the latter, the COMESA Competition and Consumer Commission has adopted a stricter stance on restriction of trade or services that facilitate regional trade, viewing this as antithetical to the very existence of a Common Market. Other jurisdictions like Kenya and Namibia continue to view restraints (e.g. exclusivity) with scepticism. Distribution is important in these markets – particularly in the non-banking sector – and designing a flexible, responsive and competition law compliant distribution network will be key.
Finally, we also expect M&A activity in Africa to be robust on the non-banking side following the blockbuster partnership between Sanlam and Allianz. We expect that other insurers will look beyond their home markets to diversify risk and earnings, or to “right size” their business by making strategic disposals in certain markets.
Competition regulators will have their hands full whether assessing strategic M&A (like that of Access Bank and ABSA’s rumoured desire to emulate Standard Bank’s success on the continent) and opportunistic M&A (e.g., a brand exiting a market presents an opportunity for others to enter that market).
Looking ahead, 2026 will likely be shaped by converging forces. Regulatory frameworks for digital lending and payments will deepen, embedding consumer protection and data privacy into competition policy. Structural reforms in payment systems will continue, with interoperability, open access and pricing for cross border payments becoming central themes. Enforcement against collusion and foreclosure in finance deals will intensify, particularly as regulators test the boundaries of jurisdiction in global and regulated markets.
The days of competition regulators exercising restraint in regulated markets are waning and we expect 2026 to see that decline accelerate. For financial institutions, the message is clear: compliance is a strategic imperative in a sector where competition law is evolving to meet the demands of a digital, increasingly cross-border and inclusive economy.
