RWANDA Trends and Developments Contributed by: Molly Rwigamba, Happy Mukama, Dominic Ococ and Erick Mugisha, RR Associates
Similarly, Article 32 of Regulation Number 01/2018 of 24 January 2018 on Corporate Governance for Banks issued by BNR, requires the supervised institutions to establish a Board IT Committee which is responsible for oversight of technology strategy and systems. The regulation of virtual assets and cryptocurrency To date, Rwanda has no specific law governing virtual assets, and cryptocurrency is not recognised as legal tender. The National Bank of Rwanda has consistently discouraged its use and, on 31 January 2023, issued a directive prohibiting all financial institutions from engaging in any crypto-related activities until a regu - latory framework is established. This prohibition was addressed to managing directors and chief executives of financial institutions and was justified on the basis that such activities lack the safeguards required to ensure efficient and sound financial services. As of 2026, Rwanda has transitioned from a restrictive stance on cryptocurrency to introducing a draft law regulating virtual assets, although it is not yet pub - lished in the Official Gazette. The draft law introduces a structured governance framework led by the Capital Market Authority, which is given exclusive authority to license and supervise virtual asset service provid - ers. It also establishes co-ordination with the National Bank of Rwanda through a joint framework for infor - mation sharing, risk assessment and supervision. For boards, this creates a dual supervisory environment, requiring governance arrangements that respond to both market conduct regulation and financial stability supervision. From a corporate governance perspective, Article 8 of the Draft Law requires the boards to regulate the licensing requirement to ensure that no virtual asset activity is conducted without prior authorisation and to ensure that licensed legal entities conduct virtual asset activities within the scope of their authorisation. This places responsibility on boards to ensure that all activities are properly licensed and that the institu - tion operates strictly within the approved regulatory scope, with clear supervision of compliance at board level. The draft law also sets internal governance and conducts standards. Virtual asset service providers
must submit periodic reports to the regulator and are required to act honestly, fairly, and with due care, skill and diligence, while maintaining effective corporate governance structures. In addition, transaction trans - parency obligations require the collection and trans - mission of originator and beneficiary information. These provisions require boards to establish systems for reporting, compliance monitoring and operational control. Finally, accountability is directly attached to boards and senior management through enforcement pro - visions. Unlicensed activity constitutes a criminal offence, while board members and senior managers may be held liable for providing false information or obstructing supervision. Administrative sanctions are also prepared. These provisions require boards to ensure continuous supervision, proper disclosure, and effective risk, compliance and audit functions within their institutions. Conclusion The developments examined in this article, manda - tory ESG reporting, shortening of board terms, and the governance of emerging technologies reflect the direction of governance reform in the Rwandan finan - cial sector in strengthening accountability, supervi - sion, and ensuring that financial institutions operate within clear and enforceable governance structures. The introduction of mandatory ESG reporting through BNR Guidelines Number 040/2024 of 25 November 2024 on the Disclosure and Reporting of Sustainabil - ity-Related Financial Information for Financial Institu - tions has placed sustainability disclosure within the core responsibilities of boards and senior manage - ment. Financial institutions are now required to inte - grate environmental and social considerations into governance, risk management and reporting, in line with internationally recognised standards. This has direct implications for transparency, investor confi - dence and regulatory supervision. Board tenure reforms across banks, insurers and oth - er financial institutions reinforce independence and effectiveness in supervision. The adoption of fixed terms with limited renewals, combined with perfor - mance evaluations and regulatory approval, ensures
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