Togo Forum: CIMA Article 13 Premium Payment Rules Enforcement Reviewed

• African insurers are meeting in Lomé to discuss financial stability and review premium payment rules.
• The 12th FANAF forum, in partnership with APSAT, is assessing compliance with Article 13 of the CIMA Insurance Code, 15 years after its revision.
• Article 13, known as "Cash Before Cover" and introduced in 2011, mandates premium payment before coverage to prevent unpaid receivables.
• Compliance with this rule has weakened over 15 years due to market competition and concessions, leading to a return of unpaid premiums.
• The forum aims to identify obstacles to enforcement and develop measures to improve compliance across CIMA-regulated insurance markets.

Fifteen years following the reform, adherence to this crucial mandate has significantly diminished, largely due to intense market competition and payment concessions extended to substantial corporate clients.

African insurance industry leaders are currently gathered in Lomé, Togo, to address pressing financial stability concerns and critically evaluate the enforcement of premium payment regulations that were initially introduced a decade and a half ago. This significant meeting marks the 12th forum hosted by the Federation of African National Insurance Companies (FANAF), which commenced on Monday, November 2, 2026. The event, organized in collaboration with the Association Professionnelle des Sociétés d'Assurances du Togo (APSAT), is scheduled to run for two days.

The primary objective of this forum is to conduct a thorough assessment of compliance with Article 13 of the CIMA Insurance Code. This review comes fifteen years after the provision underwent a significant revision, highlighting a sustained effort to ensure adherence to established financial protocols within the Inter-African Conference on Insurance Markets (CIMA) regulatory framework. The discussions are particularly focused on the challenges posed by unpaid premiums, a recurring issue that impacts the financial health of insurers across the region.

At the heart of the current discussions is Article 13 of the CIMA Insurance Code, a foundational regulation designed to govern premium payments. This article explicitly prohibits insurers from either providing new coverage or renewing existing policies until the policyholders have remitted their premiums in full. This crucial requirement, widely recognized as the "Cash Before Cover" principle, was formally implemented in 2011.

The introduction of "Cash Before Cover" aimed to fundamentally transform the insurance landscape by eradicating the practice of extending insurance on credit. Its core purpose was to prevent the accumulation of outstanding premium receivables, thereby bolstering the financial discipline and stability of insurance companies operating within CIMA-regulated markets. The rule was intended to create a more robust and predictable revenue stream for insurers, reducing their exposure to credit risk.

Despite the clear mandate of Article 13 and its initial objectives, compliance with the "Cash Before Cover" rule has notably deteriorated over the past fifteen years. This decline can be attributed to several factors, including intense competition among insurers for clients and the practice of granting payment concessions, particularly to large corporate customers. These market dynamics have inadvertently led to a resurgence of unpaid premiums, directly undermining the financial discipline that the 2011 reform sought to establish.

The re-emergence of widespread unpaid premiums poses significant challenges to the financial stability of African insurers. Forum participants are now meticulously examining the true scale of this issue, alongside identifying the various obstacles that hinder the effective enforcement of Article 13. The discussions are critical for understanding how these challenges impact the operational efficiency and profitability of insurance providers.

The ongoing forum is dedicated to formulating concrete measures aimed at significantly improving compliance with Article 13 across all insurance markets regulated by the Inter-African Conference on Insurance Markets. The participants are exploring strategies to overcome the identified enforcement hurdles and restore the integrity of the "Cash Before Cover" principle. This collective effort underscores the industry's commitment to strengthening regulatory adherence and ensuring a more stable financial environment.

The overarching theme guiding these critical discussions is "No Premium, No Cover," a concise yet powerful statement that encapsulates the fundamental principle at stake. This renewed focus on CIMA Article 13 premium payment rules signals a potential shift towards stricter regulatory oversight and enforcement, which will necessitate a thorough review of existing 'Cash Before Cover' policies and enforcement mechanisms by compliance officers and legal counsel for insurers operating in these markets.

Compliance officers and legal counsel for insurers operating in CIMA-regulated markets should review their 'Cash Before Cover' policies and enforcement mechanisms, as the industry is actively reassessing widespread non-compliance with Article 13, potentially leading to stricter regulatory oversight and penalties for unpaid premiums.

Source: Original reporting via industry reports.