Two lists published seven weeks apart by West Africa’s central bank have begun to sketch the map of who will move money across the eight-country monetary union — and the picture is one of narrow gateways rather than open rails.

On 17 September the Banque Centrale des États de l’Afrique de l’Ouest (BCEAO) updated its register of certified Business APIs for PI-SPI, the union’s interoperable instant payment platform, to 24 entries across the eight member states. The distribution is lopsided. Senegal accounts for nine and Côte d’Ivoire for eight. The remaining seven are spread across the other six countries, and in five of them — Benin, Burkina Faso, Guinea-Bissau, Mali and Togo — only one institution has been certified: Ecobank. In Niger, Ecobank is one of two, alongside i-FUTUR.

In practical terms, a business in Cotonou, Ouagadougou, Bissau, Bamako or Lomé that wants to plug into the regional instant payment rail today has one technical counterparty available to it. Ecobank is the only name that appears in all eight countries on the list.

What certification confers

The BCEAO’s communiqué sets out what a certified Business API allows a company to do: issue and receive payments, transmit bulk settlement requests, automate payment operations, track transactions in real time and improve treasury management. Crucially, those services work across the entire union irrespective of which provider the payer or beneficiary uses. For a finance director paying several hundred suppliers a month in two countries, that is the difference between maintaining multiple integrations and maintaining one.

The central bank says certification attests to compliance with its functional, technical, performance and security requirements, and that the list will be updated as further participants complete the process. That last sentence is doing considerable work: the register published on 16 September carried 23 names and was revised upward the following day. It is a queue, not a closed club. But queues have a front and a back, and at the moment the front is short.

The participant layer, and the aggregator gap

The API list sits on top of an earlier one. On 31 July the BCEAO published the roster of participants authorised to open PI-SPI services to the public: 104 entries, led by Senegal with 24 and Côte d’Ivoire with 23, followed by Mali (14), Burkina Faso (13), Benin (11), Togo (9), and Guinea-Bissau and Niger with five apiece. The composition is overwhelmingly banks, with telecom-owned mobile money subsidiaries and microfinance institutions making up the balance.

Among those 104 authorisations, one aggregator appears: TouchPoint Financial Services, operating in Côte d’Ivoire and Senegal.

Ashley Gauzere, founder and chief executive of the Abidjan-based aggregator HUB2, whose local entity CONNEKT4 appears on the API list, counted the entries publicly this week and declined to read them as exclusion. He described the sequence as the one central banks typically follow — first the entities they have supervised for thirty years, then the others — and argued that the open question is not whether the second phase arrives but what the waiting costs. “I have yet to see anyone put a figure on it,” he wrote.

The API register is, on its face, the more permissive of the two. CONNEKT4, Paymetrust, SYCA, Mikaty, Samir Money, African Financial Agent, Versus Finance Tech and i-FUTUR all appear there without appearing on the July participant list, which suggests the technical certification track admits a wider set of firms than the public-service authorisation track. Whether that translates into commercial access depends on terms the central bank has not published.

Wave’s conspicuous absence

Neither list contains Wave.

The Dakar-based company — francophone Africa’s first technology unicorn, valued above $1.7bn after a $200mn raise in 2021 — is by most measures the dominant retail payments operator in the region’s largest mobile money market. Electronic money outstanding in Senegal stood at CFA571bn ($999.25 million USD) on 21 August 2026, of which CFA459bn ($803.26 million USD) sat with Wave against CFA106bn ($185.50 million USD) with Orange Money Sénégal. The company puts its Senegalese user base at roughly 11mn.

Its absence from the PI-SPI rosters is the central fact of the current moment, and it cuts both ways. Interoperability is designed to dissolve the closed-loop advantage that low pricing and scale have built; for an operator holding four-fifths of a national float, joining a network that eliminates fees on person-to-person transfers within it compresses margin and weakens lock-in. Against that sits access to bank-held deposits and to cross-border flows the company does not currently touch. Wave has not publicly explained its position, and the BCEAO has not said whether it is in the certification queue.

The platform went live on 30 September 2025. Its first anniversary, two weeks away, is the date around which operators and regulators have organised their integration timetables, after a series of earlier postponements.

Closer to the state, not to the rail

While Wave has stayed off the regional platform, it has moved steadily deeper into Senegal’s public plumbing. In 2024 it began powering ticketing for Dakar’s bus rapid transit system through Dakar Mobilité, where mobile ticket purchases rose from around 10 per cent of transactions at launch to roughly 30 per cent within months; it has since extended to the regional express train and the state bus operator. In April 2026 the Ministry of Health signed an agreement with Wave Digital Finance to digitise payment for consultations and treatment in public health facilities. Ibrahima Sy, the health minister, said the partnership would let the government “gradually extend digital payments to all healthcare facilities” and make electronic payment a “sustainable standard” in the sector. In September the Caisse de sécurité sociale said it would pay certain benefits directly into recipients’ Wave accounts.

On 10 September, Samba Diouf, minister of telecommunications and the digital economy, visited Wave’s Dakar offices. The discussions covered access to digital public services and the digitisation of transport, health and the Treasury, according to accounts of the meeting; no new mechanism or deployment calendar was announced. The Treasury’s own 2024 activity report recorded conventions signed with several electronic money operators, Wave among them.

The result is a company embedding itself in the state’s revenue and disbursement channels while remaining outside the central bank’s flagship interoperability project — a position available to an operator of its size and shareholder base, and to very few others.

The numbers behind the platform

The BCEAO’s 2025 annual report offers a sober baseline. By 31 December 2025, three months after launch, 74 institutions had connected to PI-SPI and opened services to the public: 58 banks, seven electronic money establishments and nine microfinance institutions. The report publishes no transaction count for the platform.

The older infrastructure carried the year. SICA-UEMOA, the retail clearing system, processed 31.2mn operations worth CFA88.5tn ($154.86 billion USD), up 3.8 per cent in volume and 9.3 per cent in value. STAR-UEMOA, the large-value system, handled 1.87mn operations worth CFA1,248tn ($2.18 trillion USD), with intra-union cross-border transfers rising 5.3 per cent to CFA115tn ($201.25 billion USD), or 9.2 per cent of the system’s value. Cheques still represented 71.7 per cent of the value clearing through the system, against 24.6 per cent of volume.

On licensing, the central bank processed 79 payment institution applications and approved 30, an approval rate near 38 per cent. Twelve new electronic money issuance approvals brought the union total to 81, concentrated in Senegal (11) and Côte d’Ivoire (9). Its regulatory sandbox, the Laboratoire d’Innovation Financière, opened on 8 April 2025.

Where the contest lands

The distribution of certifications tracks the distribution of licences, which tracks the distribution of mobile money adoption. Senegal and Côte d’Ivoire between them hold 47 of 104 participant authorisations and 17 of 24 certified APIs. Those two markets are where competitive pressure on pricing and on merchant acceptance will be felt first, and where an aggregator or payment institution has any realistic choice of counterparty.

Elsewhere, the choice is currently Ecobank. The BCEAO has committed to expanding the list, and its sequencing — supervised institutions first — is neither unusual nor, on its face, improper. But a rail conceived to end fragmentation has, in its first year of certification, produced a single point of access across five national markets, while the region’s largest wallet sits outside it and negotiates directly with a government.

Across the union, mobile money transactions reached CFA160tn ($280.00 billion USD) in 2024, equivalent to 119 per cent of combined GDP. Most of that value still ends as cash withdrawal. Whether PI-SPI changes that, and on whose terms, is the question the next twelve months will settle.

The queue, and what it costs

For the payment institutions and aggregators that have filed applications but do not yet appear on either register, the position is awkward rather than fatal. The BCEAO’s own licensing figures give a rough sense of the odds: of 79 payment institution applications processed in 2025, 30 were approved. Certification for PI-SPI is a separate and later gate, and the central bank has published neither the median time from application to homologation nor the number of files currently pending. Firms in the queue are therefore planning against a date they cannot see.

The immediate consequence is commercial, not technical. A merchant acquirer or treasury platform that cannot yet route through PI-SPI must keep maintaining the bilateral integrations the platform was designed to replace — one per wallet, one per bank, each with its own settlement cycle — while pitching against competitors who can offer single-integration coverage across eight countries. That is a cost carried on both sides of the ledger: engineering headcount retained, and deals lost or discounted on the promise of future coverage.

There is a second-order effect. Where only one certified counterparty exists in a market, firms awaiting their own certification must transact through it, which means accepting its pricing and, in some cases, disclosing volume and customer data to an institution that may later compete with them. Ecobank is a participant in the payments market as well as, at present, the sole gateway to it in five countries. The BCEAO has not published rules governing how certified participants must treat non-certified firms seeking access, nor whether access must be offered on non-discriminatory terms. That silence is the most consequential gap in the current framework.

Firms already certified for the API but absent from the July participant list occupy a third position: technically cleared, but not authorised to open services directly to the public. What that distinction permits in practice — whether a certified API holder can serve business clients while awaiting participant status — has not been set out publicly.

What it means for investors

For capital already deployed in the region, the two lists function as a repricing event, and the direction is not uniform.

Regulatory position is now a legible asset. A portfolio company that holds both participant authorisation and API certification has something a competitor cannot replicate quickly, and that scarcity should show up in valuation. TouchPoint Financial Services, the only aggregator on the July participant list, and the certified names in Senegal and Côte d’Ivoire are in that category. Conversely, a company whose model assumed the interoperable rail would be broadly accessible by the end of 2026 is now carrying timeline risk that its business plan probably does not price.

Investors should expect diligence to shift accordingly. The questions that matter are narrower than they were: what is the filing date, what stage is the file at, what is the fallback distribution if certification slips two years, and what proportion of revenue depends on rails the company does not control. For firms in markets where Ecobank is the only gateway, counterparty concentration is now a standalone risk line.

The wider point is about where returns accrue. If interoperability compresses transfer pricing toward zero for person-to-person flows, as the BCEAO intends, margin migrates away from movement and toward the layers around it — merchant services, reconciliation, treasury tooling, credit, data. Investors underwriting pure payment-transmission spreads in the union are underwriting a shrinking line. Those underwriting the software and services that sit on top of a commoditised rail are, on this reading, better positioned, provided their portfolio companies can reach the rail at all.

Wave’s case complicates the thesis in a specific way. Its float share and its direct relationships with Senegalese ministries suggest that scale and state proximity can substitute, for a time, for regulatory participation. Whether that is replicable by a company without a $200mn balance sheet and marquee shareholders is doubtful, and investors should treat it as an outlier rather than a template.

For international entrants

For payment companies outside the region weighing entry — global processors, remittance operators, treasury and payroll platforms, stablecoin and cross-border settlement firms — the lists change the arithmetic of a market approach in three ways.

First, the technical case for entry has improved. A single certified integration reaches eight countries and roughly 130mn people under a common currency, with capital movement within the union already free of restriction and the platform built on ISO 20022, the messaging standard most international systems already speak. That is a materially simpler proposition than assembling country-by-country coverage, and it is the strongest argument the BCEAO has made for the platform.

Second, the route in runs through incumbents, not around them. Entry by licence is slow and, on 2025 evidence, selectively granted. Entry by partnership means partnering with a bank — in five countries, one specific bank — which sets pricing, holds the customer relationship and is not obliged to offer terms that favour a new competitor. Entry by acquisition of an already-certified local firm is the fastest route and is likely to become more expensive as the scarcity of certified counterparties becomes better understood. Firms that have been watching the region without acting should assume that the price of a licensed, certified local entity rises from here.

Third, the market being entered is less contestable than its headline numbers suggest. CFA160tn in annual mobile money value at 119 per cent of combined GDP describes activity, not addressable revenue: most of it is low-value, high-frequency transfer that ends in cash withdrawal, on which one operator in Senegal already holds roughly four-fifths of the float at a flat fee near 1 per cent. Cheques still carry 71.7 per cent of clearing value. An entrant pricing against the mobile money total is pricing against a number that does not correspond to a margin pool.

There is also political exposure that international entrants may underweight. The most valuable payment flows in Senegal — hospital receipts, social security disbursement, transport ticketing, Treasury collections — are being allocated through ministerial agreement rather than open procurement. Those relationships are durable while they last and are not readily won by a foreign entrant without a local footprint and local political standing. Companies whose regional revenue would depend on public-sector flows should account for the possibility that the flows are already spoken for.

The countervailing consideration is the BCEAO’s stated direction. The central bank has said the certification list will be updated as participants complete the process, has opened a sandbox for supervised trials, and has begun talks on connecting PI-SPI to the Pan-African Payment and Settlement System and to the ECOWAS payment system. If those connections are delivered, the union becomes a node in a continental network rather than a closed bloc, and the value of an early certified position rises accordingly. If they slip — and central bank interoperability projects generally do — the current concentration becomes the operating reality for longer than anyone currently planning entry has assumed.