IAA Insights

Reflections, analyses
and legal insights.

Food Safety in the Comoros: Towards a New Compliance Framework for Businesses Across the Food Chain?

Law No. 26-005/AU of 30 June 2026 on food safety goes beyond strengthening the hygiene requirements applicable to food products. By subjecting businesses in the sector to approval, self-monitoring, traceability, product withdrawal and recall requirements, while strengthening import controls and the powers of the competent authorities, it establishes a comprehensive compliance framework covering the entire food chain. Does this reform mark the emergence in the Comoros of a genuine food safety compliance regime for businesses operating in the sector?

Read analysis

Analyses

2 Oct 2026·32 min

Aïcham ITIBAR, Nezif-Hadj Ibrahim Halidi

Reform of the Comoros Merchant Shipping Code: Towards a New Governance Framework for the International Ship Registry?

Law No. 26-009/AU of 30 June 2026 goes well beyond amending the rules governing vessel registration. By establishing an International Ship Registry separate from the Local Registry and entrusting its administration to a Maritime Administrator vested with extensive powers, the reform reshapes the legal and institutional framework of the Comoros flag. Can this new regime strengthen the legal certainty and international credibility of the Registry while preserving the effective exercise of the flag State's authority?

Read analysis

Legal Updates

22 Sep 2026·45 min

Aïcham ITIBAR, Nadhur RADJABOU

Comoros' New Consumer Protection Law: Towards a New Corporate Compliance Framework?

Law No. 26-003/AU of 15 June 2026 goes beyond merely establishing new consumer rights. By regulating pre-contractual information, product compliance, warranties, advertising, distance selling, unfair contract terms and commercial practices, it imposes a new set of obligations on businesses that directly affect their contracts and commercial operations. The establishment of a National Consumer Protection Authority, vested with investigative, supervisory and sanctioning powers, further confirms this shift. Is consumer protection therefore becoming a genuine corporate compliance issue in the Comoros?

Read analysis

Analyses

22 Sep 2026·12 min

Aïcham ITIBAR, Moncef SAÏD IBRAHIM

Offshore Banking Activities in the Union of the Comoros: Legal Recognition and the Central Bank's Licensing Authority

Comorian law expressly recognises offshore banking transactions. Does this recognition allow an autonomous banking licensing regime outside the authority of the Central Bank of the Comoros? The statutory framework reveals a critical distinction between the offshore nature of a transaction and the legal authority permitting an institution to conduct banking business.

Providing Digital Financial Services into Comoros from Abroad: Does the Absence of a Local Presence Exclude Regulatory Requirements?

A fintech or payment service provider established abroad may technically serve customers in the Comoros without maintaining an office, employees or agents in the country. But does the absence of a physical presence mean that Comorian financial regulation does not apply? The position requires a more nuanced analysis, particularly where payment services, electronic money or remittance services are involved.

Read analysis

Édition 2027Practical Guide

14 Sep 2026·38 pages

ITIBAR & AVOCATS ASSOCIÉS

Doing Business in Comoros — 2027 Edition

Legal Framework, Opportunities & Practical Guidance

Non-Performing Loans and the Accumulation of Interest: The Limits of Debtor Protection under Comorian Banking Law

While Comorian banking regulations provide a detailed framework for the prudential deterioration of a loan classified as non-performing, they do not necessarily attach the same consequences to the relationship between the bank and its debtor. A loan may therefore be provisioned as doubtful in the institution's accounts while continuing, as a matter of law, to accrue interest, bank charges and penalties against the customer. This disconnect reveals an important limitation of the current framework and calls for an examination, beyond prudential regulation, of the mechanisms capable of containing the continued growth of the debt.

The New Law on Domestic Trade in the Union of the Comoros: Between Economic Sovereignty and Legal Certainty

Law No. 26-002/AU of 15 June 2026 on domestic trade marks a significant evolution in Comorian economic law. Between the affirmation of economic sovereignty, the protection of small commerce, the articulation with OHADA law and the strengthening of the administration's regulatory powers, this reform draws new balances on which the legal certainty of economic operators will largely depend.

Read analysis

Doing Business in ComorosPractical Guide

19 Aug 2026·10 min

Fahad NOURDINE

Investing in the Union of the Comoros: what a foreign investor must know before starting

Capital, company management, residency, regulated sectors, land, administrative relations, and project security: the key reflexes before committing to an investment.

Public-Private Partnerships in the Union of the Comoros: From a Derogatory Regime for Public Procurement to an Investment Attraction Instrument

We will argue that the Law of December 25, 2017, goes far beyond the mere procedural organization of public contracts. While it effectively establishes a regime that deviates from the classic rules of public procurement (I), it also constitutes a major instrument of national investment attraction policy, complementing the 2020 Investment Code (II).

Offsetting of debts regarding legal entities under public law in OHADA law: an incomplete easing of immunity from execution

This study will show that, while offsetting undeniably reflects a desire to ease immunity from execution (I), its legal regime remains affected by restrictions and ambiguities that significantly limit its effectiveness (II), despite the advancements introduced by the 2023 reform (III).

New law on domestic trade in the Union of the Comoros: what changes for businesses

Law n°26-002/AU of June 15, 2026, on domestic trade introduces new rules concerning the exercise of commercial activities in the Union of the Comoros, the reservation of certain activities, commercial practices, and the administration's inspection powers. An overview of the main changes businesses need to be aware of.

Read analysis

Reflections, analysesand legal insights.

Food Safety in the Comoros: Towards a New Compliance Framework for Businesses Across the Food Chain?

Reform of the Comoros Merchant Shipping Code: Towards a New Governance Framework for the International Ship Registry?

Comoros' New Consumer Protection Law: Towards a New Corporate Compliance Framework?

Offshore Banking Activities in the Union of the Comoros: Legal Recognition and the Central Bank's Licensing Authority

Providing Digital Financial Services into Comoros from Abroad: Does the Absence of a Local Presence Exclude Regulatory Requirements?

Doing Business in Comoros — 2027 Edition

Non-Performing Loans and the Accumulation of Interest: The Limits of Debtor Protection under Comorian Banking Law

The New Law on Domestic Trade in the Union of the Comoros: Between Economic Sovereignty and Legal Certainty

Investing in the Union of the Comoros: what a foreign investor must know before starting

Public-Private Partnerships in the Union of the Comoros: From a Derogatory Regime for Public Procurement to an Investment Attraction Instrument

Offsetting of debts regarding legal entities under public law in OHADA law: an incomplete easing of immunity from execution

New law on domestic trade in the Union of the Comoros: what changes for businesses

Reflections, analyses
and legal insights.