The Central Bank of The Gambia has directed commercial banks to replace non-Gambian employees who are not covered by approved expatriate quotas with qualified Gambian nationals by December 31, 2026.
The directive applies to all commercial banks operating in the country, including Nigerian-owned lenders such as Access Bank, FirstBank, Guaranty Trust Bank and Zenith Bank, as well as regional institutions including Ecobank.
The Central Bank of The Gambia said the decision followed an industry-wide review which identified a “relatively high number” of non-Gambian workers employed by banks in positions beyond those formally recognised under expatriate arrangements.
The regulator said the practice was inconsistent with The Gambia’s Labour Act 2023 and Guideline 9, which governs expatriate employment in the banking sector.
Under the directive, affected banks are required to identify qualified Gambian nationals who can take over the positions, develop succession plans and ensure the transfer of relevant skills and institutional knowledge.
The banks were also instructed to ensure that the localisation exercise does not affect the smooth running of their operations.
The order has, however, generated criticism, with some commentators questioning its implications for regional labour mobility and the free movement of Africans across the continent.
Gambian commentator, Alpha Bah, questioned the logic of African countries advocating greater freedom of movement for Africans abroad while imposing restrictions on African workers within the continent.
Bah argued that the treatment of African migrants should be judged by the same principle whether the restriction comes from a Western country or an African government.
Similarly, a Nigeria-based financial analyst and economist, Chukwunonso Ihuoma, questioned whether The Gambia had enough qualified local professionals to replace the affected workers without affecting the efficiency of banks.
“Does The Gambia have enough qualified local talent to replace the affected workers without reducing banks’ efficiency?” he asked.
Ihuoma said a rushed localisation programme could increase costs, disrupt banking operations and weaken regional financial integration if qualified Gambian replacements were unavailable.
“This kind of order can raise banks’ transition costs. Clearly, replacing experienced employees within a short period of time requires recruitment, training, compensation changes and knowledge transfer programmes. Those costs may outweigh any savings from reducing expatriate employment,” he said.
An emerging markets analyst, Ike Ibeabuchi, also criticised the directive, warning that the loss of specialised expertise could affect banking efficiency.
He said areas including treasury, cybersecurity, risk management, technology and compliance often require specialised experience.
“If qualified local replacements are unavailable, forcing rapid replacement may weaken operational capacity,” he said.
Ibeabuchi added that the policy could affect the regional operating model of Nigerian banks and other pan-African financial institutions, which frequently move experienced employees between subsidiaries.
“Restricting that flexibility could make regional operations more expensive and less efficient,” he said.
“It could increase recruitment costs. If several banks compete for the same pool of qualified Gambian professionals, salaries for scarce skills could rise. That could offset some of the expected savings from localisation,” he argued.
“Again, if multinational and regional banks perceive employment rules as unpredictable or excessively restrictive, they may factor that regulatory risk into future investment and expansion decisions.”
