The Central Bank of The Gambia has ordered commercial banks operating in the country to progressively replace non Gambian employees with suitably qualified Gambian nationals, giving lenders until December 31, 2026, to complete the transition.
The directive affects the entire banking industry and includes subsidiaries of Nigerian financial institutions such as Access Bank, Guaranty Trust Bank, FirstBank and Zenith Bank, as well as Ecobank Gambia.
The CBG issued the directive in a September 16, 2026 circular signed by its Second Deputy Governor, Dr Paul J. Mendy, after meeting managing directors of commercial banks on August 27 and reviewing the employment of non Gambians across the sector. Brandspur Banking News Desk reports that the regulator said its review found a “relatively high number” of non Gambians working in banks beyond employees formally recognised under expatriate arrangements.
The regulator said banks must now identify positions that can be progressively localised and replace affected workers with qualified Gambians, while making sure the process does not disrupt banking operations or result in the loss of critical institutional knowledge.
The directive also requires banks to put proper skills transfer arrangements in place. Non Gambian employees whose positions are being localised are expected to transfer relevant knowledge and skills to Gambian workers who will eventually take over those responsibilities.
The move is tied to The Gambia’s Labour Act 2023 and Guideline 9 governing expatriate employment in the banking industry. The Labour Act does not completely prohibit companies from employing foreign workers, but places conditions around expatriate employment and requires employers with approved expatriate quotas to provide Gambian counterparts to understudy expatriate employees.
Under Section 38 of the Labour Act, the purpose of the understudy arrangement is to ensure that expatriates transfer research, development, technology, knowledge and skills to Gambian employees. The law also states that an expatriate quota should not be granted for a position where the required knowledge, skills or expertise already exists locally.
Employers that engage expatriates without the required quota clearance, fail to renew the clearance or do not provide a Gambian understudy can face a fine of not less than 500,000 dalasis upon conviction. The legal framework therefore allows expatriate employment but places greater emphasis on regulatory approval and the development of local capacity.
The CBG did not accuse Access Bank, GTBank, FirstBank, Zenith Bank or Ecobank of individually breaching the law. Rather, the September directive applies across the banking industry and requires institutions to bring their staffing arrangements into line with existing regulatory requirements.
The order means Nigerian banking groups with operations in The Gambia will have to review their existing workforce structures, particularly positions occupied by non Gambian employees who are not covered by recognised expatriate arrangements. The CBG has not publicly disclosed how many workers are affected or identified which banks have the largest number of non Gambian employees.
The development also comes against a wider West African push towards greater local participation in foreign invested businesses. Ghana, for instance, has long operated an expatriate quota framework under its investment laws, while its new Ghana Investment Promotion Authority Act, 2026, has strengthened local workforce requirements attached to expatriate quotas. Under the new framework, eligible foreign invested enterprises seeking expatriate quotas must meet additional local employment conditions, including a requirement that 90 per cent of their direct skilled workforce be Ghanaian.
The Ghanaian framework is not the same as the CBG’s banking directive, but both reflect a broader regulatory emphasis on developing domestic skills and ensuring that foreign expertise does not permanently displace qualified local professionals.
For banks in The Gambia, the immediate task is therefore not simply staff reduction. They must identify qualified Gambians, prepare them to assume affected roles and complete the transfer of institutional knowledge before the December 31 deadline.
The affected Nigerian banks have been contacted for their responses to the directive and requested time to comment. As of the latest reports, none had publicly indicated how the transition would affect their individual Gambian operations.
