The Central African Banking Commission (COBAC) is the institution of CEMAC responsible for harmonizing banking practices between Member States (Cameroon, Gabon, Equatorial Guinea, Chad, Congo and the Central African Republic). However, a reform with significant political and economic stakes undertaken in 2024 creates a divergence between the institution and the CDEC (Deposit and depository fund).

In 2025, COBAC adopted Regulation No. 01/25/CEMAC/UMAC/CM/COBAC on the conditions for the exercise and supervision of the activities of deposit and deposit funds in CEMAC (planned to enter into force in January 2027). Through this regulation, COBAC wants to harmonise the operation of deposit and deposit funds in the Member States to ensure greater stability in the banking sector.

The rationale for this policy is that certain activities carried out by deposit funds are bank activities; COBAC, being the CEMAC bank agent, is therefore legitimate to control these activities. However, the regulation did not lead to full adherence because of the legal controversy and sovereignty it generated.

Mobilization of law as a tool for diplomatic action

The said Regulation provides that COBAC is now the supervisor of deposit funds in CEMAC countries. This supervisory role gives him a number of administrative, supervisory and sanctioning powers. In this case, COBAC may lay down rules on financial management, rules on internal management of consignments, conduct internal and external audits; It may also, under the new Regulation, ensure that deposit and deposit management procedures comply with CEMAC banking regulations and legislation. In the event of a violation of this regulation, the COBAC, as the financial officer of the sub-regional organisation, may impose sanctions (disciplinary or pecuniary) against the deposit and deposit fund.

The CEMAC of Cameroon, established in 2008 and operationalised in 2023, and the Caisse de dépôt et de consignation du Gabon, oppose the application of this Regulation on the ground that it is not in conformity with Community law governing CEMAC. The CEMAC of Cameroon, on the basis of article 4 of the Convention of 17 January 1992 on the Harmonization of Banking Regulation in the CEMAC States, argues that transactions that enter into its missions (including the recovery of funds in disinherence in banks and deposits) are not banking operations.

The CEDC also claims to be an administrative entity created by the State of Cameroon to perform a public service; as such, its organization and operation are governed exclusively by the Government of the Republic of Cameroon. COBAC would therefore not have jurisdiction to control it, let alone exercise disciplinary power. This is the position openly defended by the Director of the CDEC in a letter addressed to the Secretary General of the COBAC:

« For the State of Cameroon, the public deposit and depository service is not part of the matter transferred to CEMAC within the framework of its attribution jurisdiction and remains a sovereign activity governed by the relevant provisions of the domestic legal order.. »

Two actions for annulment were brought by the CECEC of Cameroon to the Court of Justice of CEMAC between September and October 2025: one to suspend the implementation of Regulation No 01/25/CEMAC/UMAC/CM/COBAC on the conditions for the exercise and supervision of the activities of deposit and deposit funds in CEMAC, and the other to cancel it. Beyond the divergence in the legal assessments, the issue of this disagreement is as economic as it is political.

The challenges of economic and political sovereignty

One of the main subjects of this controversy is the management of inactive funds and disinherent assets. In principle, where the holder or beneficiaries of a bank account have not carried out any banking transaction on their account for a consecutive period of ten years (from the day following the last transaction), the account shall be considered to be inactive. In this case, the bank must notify them; If inactivity continues, the assets of this account are considered to be in disrepair and become public funds which must be returned to the Caisse de dépôt et de consignation.

For accounts hosting records, the duration is 30 years of inactivity. It is in this context that, since its operationalization in 2023, the CDEC has ordered the banks operating in Cameroon to transfer to it the assets of the inactive accounts, in addition to other funds in disinherence. This is an important sum for the CEDC, which wishes to use it to finance certain national public policies.

However, for COBAC, this measure is likely to undermine banking stability with economic consequences. The latter believes that the sudden repatriation of these disinherent funds could exacerbate the liquidity crisis in banks. By way of illustration, bank deposits in Cameroon in 2023 amounted to CFAF 7,756,755 billion and CFAF 8,362,049 billion in 2024. Disinherence funds are estimated at about 20%.

Between 2023 and 2024, the CDEC estimated that 400 billion funds from inactive accounts and disinherited assets (only in banks and deposit-taking institutions), based on audits carried out in different banks.

The recovery process was already underway with commercial banks (about 8 billion) before the legal battle with COBAC began. Because dormant deposits contribute to the liquidity of commercial banks, the sudden withdrawal of these deposits would lead to the drying up of bank liquidity and the reduction of banks' capacity to provide credit to local companies.

The CDEC, for its part, intends to defend its financial sovereignty. All the more so as Cameroon needs funds to finance major structural projects and public development policies with a view to its emergence.

In addition, this COBAC-CEDEC Cameroon confrontation exposes the flaws in the economic and financial integration of CEMAC and is not likely to reassure or encourage international investors. The referral to the Court of Justice of CEMAC questions the ability of the economic and monetary community to effectively regulate banking and financial policies through consultation and dialogue.

In this connection, COBAC invited the various deposit funds of CEMAC to a consultation meeting on the adoption of the Regulation on the harmonization of the activities of deposit funds.

The CDEC, in a letter dated 15 June 2026, refused, by the voice of its director, to take part in it by stating « that it will not be possible for him to participate in an umpteenth attempt to satisfy interests contrary to those of Cameroon ».

Ultimately, this dissonance is the result of a distant cause: the construction of subregional integration in Central Africa has as its main challenge the revival of sovereignty. This is one reason why integration, understood as the voluntary, progressive and sectoral transfer of state sovereignty to a higher organizing entity, encounters obstacles. Improving the process of integration into the economic sector now requires multidimensional solutions that take into account economic, structural, institutional and political factors.

By BODI ENDANGA ARTHUR LOIC

Doctor in International and Strategic Studies

(University of Douala)