Corporate governance
Registration is only the beginning
Incorporating a company triggers a set of ongoing legal obligations that many businesses underestimate. Non-compliance can be costly.
The risk of non-compliance
Incorporating a company triggers a set of ongoing legal obligations that many businesses underestimate. Non-compliance can result in penalties, regulatory scrutiny and complications in financing or procurement, and officers can be personally exposed. Three core obligations apply to every registered company.
Statutory records
Companies must maintain and keep current their shareholder and beneficial owner registers, director and officer registers, board and shareholder meeting minutes, and accounting records with financial statements. These must be retained for at least 10 years. Poor record-keeping is the most common compliance gap identified in due diligence exercises, and one of the most avoidable.
Annual filings
Every company must file an annual return and financial statements with the Registrar General. Companies with annual turnover above FRW 600 million require certified financials. Dormant companies are not exempt, and their obligations continue until formal dissolution. A common misconception is that inactivity excuses a company from these requirements. It does not.
Notifying corporate changes
Changes to directors, shareholders, share capital, registered office or company type must be reported promptly to the Registrar General. This keeps public records accurate and supports trust with lenders, investors and counterparties conducting due diligence.
Key takeawayCompliance doesn’t end at registration. Periodic corporate reviews help catch gaps before they become costly problems.
Tax
VAT compliance is more than filing returns
Rwanda’s VAT regime is more nuanced than periodic filing. Classification, documentation and internal controls all determine your exposure.
The framework
Rwanda’s VAT regime applies at 18% on most taxable supplies, with zero-rating and exemptions available in specific circumstances. These include exports, healthcare, education and certain donor-funded activities. How a supply is classified directly affects the right to recover input VAT, which makes accurate classification critical.
Sectors requiring attention
Sectors increasingly requiring attention include international trade, digital services and cross-border transactions. Businesses must make sure their VAT treatment is backed by robust documentation, such as contracts, invoices, customs records and accounting entries. Audits assess both the position taken and the evidence supporting it.
Inadequate documentation leads to disallowed input VAT claims and additional assessments, penalties and interest.
Documentation and internal controls
VAT compliance is heavily documentation-driven. Businesses should regularly review the VAT treatment of their goods and services, the accuracy of tax invoices, their VAT accounting procedures and their internal controls. This matters most for cross-border and digital transactions, which may have unique VAT implications.
Key takeawayVAT compliance is an ongoing exercise in classification, documentation and internal controls. It is not just periodic filing.
Legal update
Rwanda’s new competition and consumer protection law
Law No. 011/2026 of 26 February 2026 replaces Rwanda’s 2012 competition regime entirely. It covers market conduct, mergers, consumer rights, digital commerce and enforcement.
Anti-competitive conduct
The law distinguishes between horizontal agreements between competitors and vertical agreements across the supply chain. Price-fixing, market allocation, bid-rigging and output restrictions now attract heightened scrutiny. Businesses may seek authorisation for arrangements that could otherwise be prohibited. This allows RICA, the Rwanda Inspectorate, Competition and Consumer Protection Authority, to weigh efficiencies against competition concerns.
Dominant market positions
Holding a dominant position is not prohibited. Abusing it is. Conduct such as predatory pricing, discriminatory practices, refusal to supply and exclusionary arrangements may trigger regulatory action by RICA.
Merger control
The law adopts a broad concept of control, recognising that influence over strategic decisions can arise without majority ownership. Certain transactions must be notified to RICA and may not proceed until cleared. RICA may consider innovation, efficiency, sustainability and the public interest, not just competition. Early legal assessment of deals is now essential.
Market inquiries
RICA can investigate entire sectors proactively, without a formal complaint, to identify structural issues before they escalate. This is a significant new power that businesses operating in concentrated or regulated markets should be aware of.
Consumer protection
Businesses face strengthened obligations on pricing transparency, product safety, fair contract terms and accurate information. Standard terms, marketing materials and sales practices all warrant review to make sure they meet the new requirements.
E-commerce
Businesses operating online platforms must provide clear information on identity, pricing, delivery, complaints and data protection. Consumers gain additional rights, including withdrawal and refund mechanisms. This is a major shift in the regulation of digital commerce.
Multi-level marketing
Specific licensing and compliance requirements now apply to multi-level marketing models, to prevent pyramid schemes and protect consumers from abusive practices.
Penalties and enforcement
Competition violations may attract fines of up to 5% of annual turnover. Consumer protection violations carry additional sanctions. An Independent Appeal Committee provides structured review of regulatory decisions. Businesses should review their commercial arrangements, distribution structures, consumer contracts, pricing policies, advertising and e-commerce operations now, before enforcement begins.
Key takeawayThis is a fundamental modernisation of Rwanda’s regulatory landscape. Early compliance review is the best protection against enforcement risk.
This newsletter is for information only and does not constitute legal advice. Receiving it does not create a lawyer and client relationship.