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.
About this guide
The Union of the Comoros currently offers investment opportunities in sectors as diverse as infrastructure, energy, tourism, telecommunications, transport, financial services, agriculture, and the digital economy. For a foreign investor, the first question is often simple: can you freely create and own a company in the Union of the Comoros? The principle is favorable. But it must immediately be supplemented by several precautions. The freedom to invest does not mean that all activities are freely accessible under the same conditions, nor that forming a company is sufficient to allow a foreign investor to immediately take over its operational management. The legal framework of the Union of the Comoros must also be read in conjunction with OHADA law and, for certain activities, with specific sectoral regulations. Before committing capital, several questions therefore deserve to be examined.
For a structured overview of the legal framework for investment, see our Doing Business in Comoros — 2027 Edition.
For an overview of the Investment Code and its approval regimes, see our Comoros Investment Code page.
Doing Business in Comoros
## 1. Can a foreign investor own 100% of a company in the Union of the Comoros? In principle, yes. The general investment law does not set the association of a foreign investor with a local partner from the Union of the Comoros as a general condition. A foreign investor can therefore, subject to the rules specific to the envisaged activity, incorporate a company in which they hold 100% of the capital. This is an important point: the presence of a partner from the Union of the Comoros is not, under general law, a general condition for foreign investment in the Union of the Comoros. However, this freedom should not be confused with the conditions required to personally carry out a professional activity on the territory of the Union of the Comoros. One must indeed distinguish between ownership of capital and the actual exercise of company management. This distinction is fundamental. ## 2. Owning your company does not necessarily mean being able to manage it immediately. This is a particularity that a foreign investor must identify very early in their implementation schedule. Law n° 88-025 of December 29, 1988, regarding the entry and stay of foreigners, provides that a foreigner who wishes to stay in the Union of the Comoros beyond three months is subject to the long-stay regime and the residence permit. Above all, its Article 10 provides that a foreigner holding a residence permit who wishes to exercise a professional activity must obtain a resident card. When it involves an industrial, commercial, artisanal, or liberal activity, the application for a resident card follows a specific procedure. In the case of creating an activity, it must in particular be accompanied by an application for authorization to create a company, and the decision to grant it rests with the Council of Ministers under the conditions provided by law. This results in an important practical consequence. An investor may have legally structured their investment and own their company without being able to assume that the formalities relating to their own situation as a foreign manager are without impact. The implementation schedule must therefore integrate, from the outset, issues of entry, stay, residency, and the exercise of a professional activity. In practice, when a company must start operating before the completion of its foreign manager's personal formalities, a transitional governance organization may need to be envisaged, for example by means of a person locally authorized to temporarily assume certain management or representation functions. Such an organization must, however, be legally structured: powers, limits of the mandate, bank signatures, contractual commitments, and replacement mechanisms must be clearly determined. The local partner or representative should never be chosen simply to satisfy a formality. ## 3. Warning: the 100% ownership principle has sectoral exceptions. This is probably one of the most important checks before incorporating the company. The freedom to invest is the principle. However, sectoral regulations may impose specific conditions. Certain strategic or regulated activities may be subject to requirements concerning: - the nationality or residence of directors; - the composition of capital; - minimum participation of interests from the Union of the Comoros; - the obtaining of a license or accreditation; - minimum share capital; - the qualification of managers; - prior authorization from the regulatory authority. Particular vigilance is required in sectors such as civil aviation, banking and financial activities, telecommunications, and certain maritime activities. In these areas, the first question should not be: “What company are we going to form?” but: “What conditions does the regulation of this activity impose on the shareholding, control, and management of the operator?” The capital structure should only be decided after this verification. A structure that is perfectly valid under OHADA corporate law may indeed not satisfy the specific conditions required to obtain the license necessary to carry out the activity.