Africa trade finance regulations: Algeria's factoring framework in two steps
The first step is Bank of Algeria Regulation No. 26-03, dated 13 August 2026 (29 Safar 1448). According to the Algerian outlet Algérie Eco, it was published in Journal officiel No. 67 and signed by Governor Mohammed Lamine Lebbou. The Algerian business site UpGrowth reports that the central bank put the text online on 21 September 2026, and Algérie Eco reported on it on 20 September 2026.
Per those reports, the regulation treats factoring as a credit operation under Article 70 of Law 23-09 of 21 June 2023. Doing it on a habitual basis is reserved to licensed banks and financial institutions. Factoring is described as the transfer of commercial receivables to a factor that, for a fee, pays the receivable amount in advance and bears the risk of non-payment.
The second step is Bank of Algeria Instruction No. 09-2026, dated 7 October 2026. FCI's summary says it sets practical requirements for banks and financial institutions carrying out factoring and follows the regulation introduced in August. The sources reviewed give no effective date for the instruction, so readers should check the official text before relying on any timing.
What Regulation 26-03 requires of banks and clients
Within Africa trade finance regulations, this text is the most detailed item in the snapshot. The regulation defines which receivables can be financed. According to the UpGrowth summary, they must be trade receivables evidenced by invoices or an equivalent document. They must be certain, liquid, fixed in amount and not disputed by the debtor. Payment must fall due in less than six months from the invoice date. The receivable must not be extinguished or encumbered, it must be freely transferable, and the debtor must not be in cessation of payments, judicial reorganisation or liquidation.
A written contract must be concluded before the factor provides any financing. A contract that finances receivables already financed under another factoring contract is void. The seller marks invoices with a subrogation mention and informs the debtor without delay, by registered letter with acknowledgement of receipt or another written method. The debtor's consent is not required for subrogation, according to Algérie Eco.
On remuneration, the factor's pay is made up of a financing commission and a factoring commission; the latter covers management, collection and, where applicable, the risk of non-payment. On accounting, factoring receivables follow the same classification and provisioning rules as other receivables, and factoring data is reported to the credit register. Implementing details were left to a Bank of Algeria instruction, which is the role Instruction 09-2026 now plays.
Instruction 09-2026: how a factoring operation is meant to run
UpGrowth, summarising a report by Radio Algérienne, describes the procedure. A factoring operation starts with a request from the client, called the member, to the factor, identifying the debtor and giving information on the debtor's financial situation. Before a contract is concluded, the factor assesses both the member and the debtor. Operations rest on a written contract signed by both parties.
The factor must check that receivables are eligible before any transfer. According to the same summary, eligible receivables are commercial receivables held on debtors resident in Algeria. The member sends the invoices or equivalent documents with a summary slip, and a subrogation receipt is drawn up in two copies for each invoice or document financed.
The instruction also lists clauses that the contract must contain: the express wording "factoring contract", the identification of the parties, the purpose and the terms of subrogation, the rights and obligations of the parties, the factor's remuneration, the duration, the identification of the debtor or debtors, the factor's overall commitment ceiling and, where applicable, individual ceilings per debtor, and the conditions of termination and their effects on financed receivables. The summary does not cover reporting requirements, detailed risk rules or penalties, so those points remain unconfirmed here.
Congo, ATIDI and guarantees for Central Africa
The second African item concerns the Republic of Congo. FCI states that talks with the African Trade and Investment Development Insurance agency (ATIDI) advanced in October, after Congo ratified the ATIDI agreement in August 2026. FCI suggests that better access to guarantees and risk-mitigation tools could support SME financing and non-recourse factoring across Central Africa, but it gives no figures.
More detail comes from the financial site Sika Finance, in an article of 14 October 2026. It reports that on 13 October 2026 Congo's Finance Minister, Christian Yoka, met ATIDI chief executive Manuel Moses on the sidelines of the IMF and World Bank annual meetings in Bangkok. According to the ministry, ATIDI could guarantee sovereign loans and grant guarantees to local banks to help finance small and medium-sized enterprises and companies in the public portfolio.
The same article says a convention between ATIDI and the Bank of Central African States assigns a 0% credit risk weighting to covered sovereign loans. Brazzaville is described as seeking lower interest rates on future borrowing. Nothing in the sources indicates that a guarantee has been signed; at the time of writing (3 November 2026) the matter is a negotiation. The ATIDI website lists credit risk insurance, political risk insurance and surety bonds among its products.
Africa trade finance regulations and the push to grow factoring
FCI also reports that Afreximbank and FCI will hold a one-day factoring workshop on 19 November 2026 at the Gaborone International Convention Centre in Botswana, titled "Unlocking Working Capital for Africa's Growing Businesses through Factoring and Supply Chain Finance". According to FCI, it follows the Afreximbank Trade Finance Seminar, held in Gaborone from 16 to 18 November 2026. Speakers listed include FCI's Secretary General and a director of factoring and trade finance at Banque Postale du Congo.
FCI cites Africa's factoring turnover at about 51.4 billion euros in 2025, up from about 32.3 billion euros in 2021, while noting that the continent is still a small share of the global market. It argues that growth needs more than finance: legal and regulatory frameworks, institutional capacity, technology and cooperation also matter. Separately, FCI announced a fourth Import-Export Factoring Networking E-vent for 17 and 18 November 2026.
The snapshot also covers markets outside Africa that are useful for comparison. It says Ukraine's new Law on Factoring took effect on 30 July 2026 and that Georgia's first dedicated factoring law, adopted in 2026, takes effect on 1 January 2027, creating a factoring registry. These are FCI's statements and are mentioned only to show the wider direction of factoring legislation.
Africa trade finance regulations: what banks, importers and exporters can take from it
The items above are reported facts; the points below are general context, not legal advice. For banks, a defined legal category for factoring in Algeria means that product design, contracts and internal credit processes can be compared against a written standard. Banks with correspondent or receivables business touching Algeria may wish to read the regulation and the instruction in full, since the summaries reviewed here leave gaps.
For Algerian exporters and importers, the reported eligibility rules matter. Receivables due in less than six months, undisputed and evidenced by an invoice fit the model; longer payment terms or contested invoices, as described in the sources, do not. The summary of Instruction 09-2026 says eligible receivables are those held on debtors resident in Algeria, so it does not automatically extend to export invoices owed by foreign buyers; whether and how that may change is not stated in the sources.
Africa trade finance regulations cover very different products, so it is important to separate what is new from what is not. Factoring is not a letter of credit rule, and nothing in these texts changes the Uniform Customs and Practice for Documentary Credits or the way a documentary credit is issued. These provisions concern the sale of receivables to a bank or financial institution, a different product with its own contract, its own risk assessment and its own cost structure of financing and factoring commissions.
For businesses outside Africa that trade with the continent, the Congo item is a reminder that sovereign and bank guarantees from regional insurers can influence how local banks lend. The effect on pricing depends on coverage level and cost, as the source itself notes, and no savings have been quantified. Anyone relying on a specific rule, deadline or guarantee should confirm it with the issuing authority or a qualified adviser.
What remains to be confirmed
Several points are still open as of 3 November 2026. The effective date of Instruction 09-2026 is not given in the summaries reviewed. The detailed reporting and risk-management requirements are not described. For Congo, the scale and terms of any ATIDI guarantee have not been published in the sources. Readers tracking Africa trade finance regulations should therefore watch for the official texts of the Bank of Algeria, ATIDI announcements and the outcome of the November events in Gaborone.