What Regulation 24-04 Actually Says
Regulation No. 24-04, issued on 13 October 2024 by the Governor of the Bank of Algeria, defines the specific conditions for “authorization of establishment, approval, and exercise” of digital banking activities. It is the first piece of Algerian banking law that contemplates a fully digital bank as a distinct license category — not a digital channel of an existing brick-and-mortar institution.
According to Algeria Invest’s analysis, the regulation sets out a deliberately strict perimeter. A digital bank under the new regime must (a) carry out its activities exclusively in the digital environment, (b) maintain its administrative headquarters in Algeria, and (c) host its digital platform inside Algeria. Branches of foreign digital banks are not allowed. The local-presence requirements are intentional: the regulator wants regulated entities, not API wrappers operated from abroad.
The regulation sits on top of Law 23-09 of 21 June 2023 (the Monetary and Banking Law), which is the umbrella statute. Together, the two texts give the Bank of Algeria a complete toolkit to license, supervise, and if necessary withdraw the agreement of a digital bank — the same supervisory powers it already exercises over conventional credit institutions.
The Two-Stage Licensing Path
A licensing application under Regulation 24-04 is a sequenced process, not a single filing. Compliance teams should plan for two distinct submissions, separated by up to 12 months.
Stage 1 — Authorization of Establishment. The applicant submits a request to the Chairman of the Monetary and Banking Council. The dossier must include a project presentation, a technical-economic study, the legal articles of association, internal control and risk management procedures, and specific anti-money-laundering and counter-terrorism-financing measures. The Council issues a formal authorization to constitute the company.
Stage 2 — Approval (agrément). Once authorization is obtained, the applicant has 12 months to apply for full approval to the Governor of the Bank of Algeria. Approval is what allows the bank to actually open its doors and take on customers. Missing the 12-month window means going back to Stage 1.
The shareholding rule is the single most important constraint at the founding-team table: at least 30% of the bank’s equity must be held by an established Algerian bank with expertise in online banking. This effectively rules out the European-style fintech-only neobank — every Algerian digital bank needs an incumbent banking partner on the cap table from day one.
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Where the Fintech Strategy 2024-2030 Fits
Regulation 24-04 does not exist in a vacuum. It is one component of the Fintech Strategy 2024-2030, which also includes the PSP regulation (Instruction 06-2025), the PAPSS integration, and the planned regulatory sandbox.
According to the Bank of Algeria announcement carried by Afreximbank, Algeria became the 18th country to join the Pan-African Payment and Settlement System in 2025 — a move that opens cross-border payment rails between Algerian banks and the rest of the AfCFTA zone without going through correspondent banking in USD or EUR. For digital bank applicants, PAPSS membership is a strategic unlock: a license under Regulation 24-04 plus PAPSS connectivity means a meaningful cross-border product offering from launch.
On the Payment Service Provider side, Instruction 06-2025 sets a minimum capital of 160 million DZD (approximately $1.2 million) for registered companies operating as PSPs. Individuals cannot become PSPs — only companies. The regulatory sandbox is targeted for full operation by 2026 to allow at least 20 fintech startups per year to test innovations under supervision, according to the published Phase 1 timeline of the Fintech Strategy 2024-2030.
What Founders And Incumbent Banks Need To Prepare
Building a digital bank in Algeria is a multi-year, capital-intensive exercise that mixes banking law, IT architecture, AML programs, and partnership negotiations. The right preparation today determines whether a 2026 application gets through, gets stuck in remediation, or never gets submitted.
1. Lock the Algerian banking partner before drafting the dossier
The 30% Algerian-bank shareholding rule is non-negotiable. Founders that show up at the Monetary and Banking Council with an offshore cap table and a “we will find a partner” line lose the room. Before spending money on legal and IT consultants, sign a non-binding term sheet with at least one Algerian banking partner that covers (a) the equity stake, (b) governance representation, (c) operational support during the 12-month authorization-to-approval window, and (d) a path to expansion if the partner exits. Incumbent banks have leverage here, but they also have an incentive to participate — Regulation 24-04 was clearly drafted to keep them in the digital banking story rather than around it.
2. Design the technical-economic study around the local-hosting constraint
The “platform hosted in Algeria” requirement reshapes the technology stack. A standard cloud-native architecture deployed on AWS Frankfurt or Google Cloud Paris does not meet the rule. The technical-economic study must show concretely where the production platform will run — sovereign cloud (Algerie Telecom’s data center, the planned national cloud), on-premises in a Tier-III certified Algerian facility, or a hybrid. Build cost projections for Algerian colocation rates, power and cooling, and disaster-recovery duplication inside Algeria. Founders who underestimate this line item end up with a dossier that fails technical review.
3. Treat AML/CFT as a first-class application track, not a section
Specific AML/CFT measures are explicitly required in the Stage 1 dossier — they are not a footnote. Algerian law enforces the FATF-aligned framework through several pieces of legislation, and the Council expects to see concrete tooling: customer-due-diligence flows for digital onboarding, transaction monitoring rules, suspicious-activity-report workflows, sanctions screening, and a named compliance officer. Many fintech founders try to ship a thin AML chapter and pad the technology section. That gets caught. Hire AML expertise early — the cost of getting it wrong post-approval is license suspension.
4. Plan for the 12-month authorization-to-approval window operationally
The 12 months between Stage 1 authorization and Stage 2 approval is not idle time. It is the build phase: construction of the platform, hiring of the operating team, finalization of vendor contracts, completion of penetration tests, and dry runs of customer journeys. A digital bank applicant that treats the 12 months as a queue rather than a build window arrives at Stage 2 with an empty office and no working product. The Governor’s approval requires demonstrated operational readiness — front office, back office, treasury, KYC, transaction monitoring, customer support — not just a deck.
Where This Fits in Algeria’s 2026 Banking Ecosystem
Regulation 24-04 is the most ambitious piece of Algerian banking modernization in two decades. Done well, it produces a generation of Algerian digital banks that can compete on customer experience with the regional incumbents. Done poorly, it produces a regulatory archive of stalled applications and a frustrated fintech community.
The realistic path for 2026 is incremental. The first wave of approved digital banks will most likely be incumbent-led: a major Algerian commercial bank takes the lead, brings in a fintech operating partner, and uses the new regulation to launch a digital subsidiary that competes for the under-banked segment. Pure-fintech-led applications will follow only after the first cohort proves the licensing path is workable.
For founders who are not aiming directly at a banking license, the PSP track under Instruction 06-2025 and the upcoming regulatory sandbox are the more accessible 2026 entry points. PSP status allows acquiring, wallets, payment initiation, and several adjacent services without the full balance-sheet weight of a bank license — and the sandbox is designed to test products before committing to a license category. The right sequencing for many teams is sandbox → PSP → digital bank, over a 3-5 year horizon, rather than digital bank from day one.
Frequently Asked Questions
What does Bank of Algeria Regulation 24-04 actually require?
Regulation 24-04 of 13 October 2024 sets the conditions for licensing a fully digital bank in Algeria. Applicants must hold administrative headquarters in Algeria, host the digital platform in Algeria, and at least 30% of the equity must be held by an established Algerian bank with online banking expertise. The license process has two stages: authorization of establishment from the Monetary and Banking Council, followed within 12 months by full approval (agrément) from the Governor of the Bank of Algeria.
How does Regulation 24-04 fit into the broader Fintech Strategy 2024-2030?
Regulation 24-04 is one component of a coordinated stack that also includes Law 23-09 of 21 June 2023 (the Monetary and Banking Law), Instruction 06-2025 governing Payment Service Providers with a 160 million DZD minimum capital, the Bank of Algeria’s PAPSS membership in 2025, and a planned regulatory sandbox targeted for 2026. Together they aim to move 50% of transactions cashless by 2030.
Can a fintech founder apply for a digital bank license without an Algerian bank partner?
No. The 30% Algerian banking ownership requirement is structural and non-negotiable. Founders need to secure a non-binding term sheet with at least one established Algerian bank with online banking expertise before submitting a Stage 1 dossier. Without that partner on the cap table from the founding round, the application will not advance.
Sources & Further Reading
- Digital Banks in Algeria: A Study of Bank of Algeria Regulation 24/04 — Journal of Human Sciences
- Introduction to Regulation 24-04 of 13 October 2024 — Algeria Invest
- Algeria’s Fintech Ecosystem in 2026 by Building Momentum — The Fintech Times
- Bank of Algeria joins PAPSS Network — African Export-Import Bank
- Algeria Launches First Fintech Regulation for PSPs — Startup Researcher
