Systemic important institutions are companies as defined by Article 4 of the Annex to the Convention of 17 January 1992 on the Harmonization of Banking Regulations in the Central African States whose failure would, in the opinion of the Banking Commission (COBAC) and the Monetary Authority, have a direct or indirect negative impact on all or part of the banking and financial system and whose effects could spread to other sectors of the economy.

This regulation No. COBAC R-2018/03 lays down the criteria for identifying and monitoring systemic important institutions in the CEMAC.

The objectives of identifying and supervising systemically important institutions in the CEMAC are to:

– To reduce the risks to the stability of the banking and financial system posed by the difficulties of these institutions;

– Ensure the continuity of their operations, in accordance with the regulations in force.

Each year, the Banking Commission is responsible for identifying systemic important institutions in the CEMAC zone on a parent company, consolidated or combined basis, as appropriate.


Systemic important institutions are identified on the basis of criteria such as their size, the interdependence of their activities, the absence of direct substitutes or of a financial infrastructure for their services, their activities on a sub-regional, regional or global scale and their complexity.

Size measures the importance of an institution’s activity within the CEMAC banking and financial system.

For the purposes of this regulation, the size of institutions refers to their total assets, as shown in their reports sent to the General Secretariat of the COBAC.

The General Secretariat of COBAC assesses the off-balance sheet items that be taken into account.

Interdependence as per the COBAC regulation reflects the degree to which institutions are intertwined in the banking and financial system. It results from the links between an institution and other institutions, due to the assets and liabilities it holds on them and vice versa.

For the application of this regulation, the interdependence of institutions is analyzed through the volume of interbank assets and liabilities.

The absence of direct substitutes or of a financial infrastructure for the services is expressed through the monopoly or exclusive exercise of one or more banking services by the credit institution, or through the exclusive ownership or management of infrastructure necessary for the provision of financial services deemed essential by the COBAC.

This criterion concerns, in particular, assets under custody, payment flows payment systems and underwriting transactions on financial markets.

The complexity of the Group’s activities stems from the size of its assets or liabilities, the realization of which requires the implementation of valuation, counterparty identification, hedging, accounting, monitoring and control procedures, the implementation of which presents proven difficulties.

For the purposes of this Regulation, complexity is assessed on the basis of the various balance sheet and off-balance sheet items and through an analysis of the activities of the reporting institution, in particular assets relating to market activities and forward foreign exchange transactions.

Cross-border activities relate to transactions carried out abroad.

For the purposes of this Regulation, cross-border activities are assessed on the basis of the relative volume of transactions carried out with non-resident counterparties.

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