Bank of Uganda extends licensing deadline for large SACCOs to 31 March 2027
The extension is final and conditional. Eligible SACCOs that have not yet applied should submit the Form A application now.
The Bank of Uganda (the Bank) has extended to 31 March 2027 the deadline for large Savings and Credit Cooperative Organisations (SACCOs) to be licensed under the Microfinance Deposit-Taking Institutions Act, Cap. 58 and the Micro-Finance Deposit-Taking Institutions (Registered Societies) Regulations, 2023 (the Regulations). The extension, set out in a notice dated 28 September 2026, replaces the 30 September 2026 deadline. It follows a meeting convened by the Speaker of Parliament on 23 September 2026.
The extension gives more time to complete the process but does not remove the licensing obligation. The Bank has said there will be no further extensions, and eligible SACCOs must obtain and submit the Form A application within 14 calendar days of the notice. A parliamentary roadmap had referred to 30 June 2027 as an outer limit, but that date does not appear in the Bank’s notice. SACCOs should plan on 31 March 2027 as final.
Background
SACCOs are registered as cooperative societies under the Cooperative Societies Act. Most remain under the Tier 4 microfinance framework established by the Tier 4 Microfinance Institutions and Money Lenders Act, 2016. The Regulations, gazetted in 2023, bring the largest deposit-taking SACCOs within the Bank’s licensing and supervisory perimeter under the Microfinance Deposit-Taking Institutions Act.
The Bank initially set a compliance deadline of 31 March 2026 and, in February 2026, extended it by six months to 30 September 2026. Ahead of that date, the Bank warned that unlicensed large SACCOs would be cut off from the commercial banking system, including deposits held with commercial banks, and from mobile-money services from 1 October 2026.
On 23 September 2026, the Speaker of Parliament, Jacob Marksons Oboth, convened a meeting of the Bank, SACCO apex bodies including the Uganda Cooperative Savings and Credit Union and the Uganda Cooperative Alliance, and government representatives. At that time, eight SACCOs had been fully licensed, 21 were at the final stage and about 50 had collected application forms, out of more than 90 SACCOs identified for Bank regulation. The Governor cited the country’s forthcoming Financial Action Task Force (FATF) evaluation as a reason why large unregulated financial institutions could not be left outside the regulatory perimeter.
The meeting agreed a roadmap under which SACCOs would demonstrate commitment by collecting application forms, with phased compliance by 31 March 2027. The Ministry of Finance was also tasked with reviewing the laws governing SACCOs, with a view to harmonising the framework. The Bank then issued its notice of 28 September 2026.
Which SACCOs are affected
Under regulation 2 of the Regulations, the licensing requirement applies to a registered society that provides financial services among its members and has both:
▪ voluntary savings in excess of UGX 1.5 billion; and
▪ institutional capital above UGX 500 million.
The two thresholds are cumulative in the gazetted text, although some public commentary describes them as alternatives. Each SACCO should test its position against its most recent audited figures and keep that assessment under review as it grows. Registration as a cooperative society is not a licence to conduct deposit-taking business within the Bank’s perimeter: the two serve different legal purposes.
Licensing readiness requirements
The definitive documents and prudential standards are those in the Regulations and the Bank’s current application form (Form A). An eligible SACCO should be ready to demonstrate:
▪ its certificate of registration as a cooperative society and its registered by-laws;
▪ a compliant governance structure and a properly constituted board;
▪ clear membership, shareholding and beneficial-ownership records;
▪ audited financial statements and reliable accounting records;
▪ institutional capital of not less than UGX 500 million and core capital of not less than 10% of total assets (regulation 13), together with applicable liquidity and other prudential requirements;
▪ fit-and-proper directors and senior managers;
▪ effective internal controls, internal audit and risk-management systems;
▪ anti-money-laundering and counter-terrorist-financing (AML/CFT) controls;
▪ policies on lending, savings, recoveries and related-party transactions;
▪ adequate information-technology, cybersecurity and data-protection arrangements;
▪ consumer-protection and complaints-handling procedures; and
▪ a sustainable business plan supported by credible financial projections.
Consequences of non-compliance
A large SACCO that is not licensed by the deadline, and its responsible officers, may face regulatory action. Depending on the circumstances, the consequences may include:
▪ restrictions on deposit-taking and other regulated activities;
▪ loss of access to commercial bank accounts and payment channels, as regulated financial service providers will be barred from transacting with unlicensed large SACCOs;
▪ loss of access to mobile-money services;
▪ directions to cease or restructure particular operations;
▪ penalties prescribed under the law, potentially including closure; and
▪ reputational damage and loss of member confidence.
Immediate actions for eligible SACCOs
1. Confirm regulatory status. Test the SACCO’s position against both regulation 2 thresholds using its latest audited figures, and obtain a legal view where the position is borderline.
2. Submit Form A now. Obtain and lodge the licence application within the 14-day window following the Bank’s notice of 28 September 2026, even if some supporting documents will follow.
3. Conduct a readiness review. Compare governance, capital, policies and controls with the Regulations and the Bank’s application requirements.
4. Engage the regulator. Clarify institution-specific requirements and agree a timetable for outstanding items well before 31 March 2027.
5. Remediate deficiencies. Address governance, capital, record-keeping, AML/CFT, technology and internal-control weaknesses.
6. Preserve evidence. Retain application receipts, correspondence and other proof of engagement with the Bank.
7. Brief key counterparties. Where appropriate, update commercial banks, payment providers, members and funding partners on the SACCO’s licensing status.
8. Monitor law reform. Track the Ministry of Finance’s review of the SACCO legal framework, which may affect the longer-term regime.
Implications for banks and payment providers
The Bank has indicated that regulated financial service providers will be barred from transacting with large SACCOs that remain unlicensed after the deadline. Banks, mobile-money operators and other payment providers should take a risk-based approach now: identify SACCO customers that meet the regulation 2 thresholds, document each one’s licensing and application status, and plan for an orderly response, including member communications, if a customer is not licensed by 31 March 2027.
The extension should not be read as confirming that every SACCO may continue all existing activities until 31 March 2027. The legality of particular activities depends on the governing legislation, the institution’s status and any directions issued by the Bank.