The Central Bank of The Gambia has directed commercial banks to phase out existing non-Gambian employees and replace them with suitably qualified Gambian nationals by the end of 2026, potentially forcing significant changes to the workforce of foreign-owned lenders operating in the country.

The directive was contained in a September 16, 2026 circular addressed to managing directors of all banks and signed by Paul J. Mendy, Second Deputy Governor of the Central Bank of The Gambia (CBG).

The regulator directed banks to adopt a phased approach to replacing non-Gambian employees, while making arrangements for skills transfer and continuity of operations.

The transition must be completed by December 31, 2026, according to the circular seen by BusinessDay.

“Consequently, all banks are required to adopt a phased approach to replacing existing non-Gambian staff with suitably qualified Gambian nationals, with appropriate arrangements for skills transfer and continuity of operations,” the CBG said.

The directive follows a meeting between the central bank and managing directors of banks on August 27, 2026, where the employment of non-Gambian staff in the banking industry was discussed.

According to the regulator, an industry study found that a “relatively high number” of non-Gambians were employed by banks in addition to recognised expatriate staff.

“This is in violation of the provisions of the Labour Act 2023 and also not in line with guideline 9 on expatriate staff,” the CBG said.

The regulator directed banks to ensure full compliance with the country’s labour laws and its guidelines governing expatriate employment. “You are hereby directed to ensure full compliance with the law and strict compliance with CBG’s guidelines,” it said.

BusinessDay contacted the central bank on Monday to confirm the authenticity and details of the circular, particularly because the directive had not been published on the regulator’s website. The CBG had not responded as of Thursday.

Nigerian banks face exposure

The directive has implications for Nigerian banking groups that have established subsidiaries in The Gambia as part of their wider African expansion.

They include Access Bank, FirstBank, Guaranty Trust Bank and Zenith Bank, which operate subsidiaries in the country.

Ecobank Gambia is part of Ecobank Transnational Incorporated, the Togo-headquartered pan-African banking group.

However, the directive is not specifically targeted at Nigerian banks. It is addressed to all banks operating in The Gambia and covers non-Gambian employees generally.

The CBG has not announced a blanket ban on foreign employees. Instead, it instructed banks to replace existing non-Gambian staff with qualified Gambian nationals and put in place arrangements to transfer skills and responsibilities to local employees.

Foreign lenders dominate banking sector

The directive also comes against the backdrop of a banking industry with significant foreign ownership.

The Gambia has 11 licensed commercial banks, including four subsidiaries of Nigerian banking groups: Access Bank Gambia, First Bank Gambia, Guaranty Trust Bank Gambia and Zenith Bank Gambia.

Other foreign or regional banking groups include Ecobank, BSIC, Bloom Bank Africa and Vista Bank, while Agib Bank Gambia and Trust Bank are locally owned and Mega Bank Gambia is government-owned.

The World Bank has previously described The Gambia’s banking sector as predominantly foreign-owned, with significant participation from Nigerian and other African banking groups.

For Nigerian banks, the directive highlights a broader challenge associated with their expansion across Africa: balancing regional growth with local employment and workforce requirements in host markets.

Skills transfer becomes critical

The December deadline gives banks just over three months to complete the transition.

Rather than simply replacing foreign employees, the CBG requires banks to make “appropriate arrangements for skills transfer and continuity of operations”.

This could require lenders to identify Gambian employees capable of assuming responsibilities currently held by non-Gambian workers and provide the necessary training before the deadline.

The number of employees affected remains unclear. The CBG circular describes the number identified in its study as “relatively high” but does not provide a breakdown by bank, nationality, job function or seniority.

It also does not specify whether exemptions will be available for specialised positions where suitably qualified Gambian nationals are unavailable.

Those details will be important in determining the scale of the directive’s impact on foreign-owned banks.

For now, banks operating in The Gambia have until December 31 to complete the transition and comply with the CBG’s localisation directive. (Businessday NG)