RESTRICTED  
  
WT/ACC/COM/3  
25 October 2013  
(13-5939)  Page: 1/97  
Working Party on the Accession of 
the Union of the Comoros  Original: French  
 
  ACCESSION OF THE UNION OF THE COMOROS 
MEMORANDUM ON THE FOREIGN TRADE REGIME 
 In a communication circulated in document WT/ACC/COM/1 on 2 March 2007, the Council 
of Ministers of the Union of the Comoros applied for accession under Article XII of the Agreement 
Establishing the World Trade Organization (WTO). 
  The General Council established a Working Party (WT/ACC/COM/2) on 11 October 2007 with the following terms of reference: "To examine the application of the Government of the Union of 
the Comoros to accede to the World Trade Organization under Article XII and to submit to the 
General Council recommendations which may include a draft Protocol of Accession."  
 In accordance with the established procedures  (WT/ACC/1), the Secretariat is circulating the 
attached Memorandum on the Foreign Trade Regime received from the Council of Ministers of the 
Union of the Comoros. WTO Members wishing to su bmit questions on the Memorandum are invited 
to do so by 31 January 2014 for transm ission to the Comorian authorities. 
 
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TABLE OF CONTENTS 
ACRONYMS ....................................................................................................................... 6  
I. INTRODUC TION ............................................................................................................ 8  
II. ECONOMY, ECONOMIC POLI CIES AND FORE IGN TRAD E ............................................ 10  
1.   Economy ..................................................................................................................  10 
(a)   General description ................................................................................................ 10  
(b)   Current econ omic situation .................................................................................... 12  
2.   Economic  policies ..................................................................................................... 14  
(a)   Main directions of the ongoing economic policies ................................................... 14  
(b)   Monetary and fiscal policies ................................................................................... 18  
(c)   Foreign exchange and payments system ................................................................ 21  
(d)   Foreign and domestic investment policies .............................................................. 23  
(e)   Competitio n policies ............................................................................................... 25  
3.   Foreign trade in goods and se rvices ......................................................................... 26  
4.   Domestic trad e in services ....................................................................................... 32  
5.   Information on financial movement s related to nationals working abroad, 
remittances, etc. ............................................................................................................ 34 
6.   Information on growth in trade in  goods and services over recent years 
and forecasts for ye ars to come ..................................................................................... 37  
III. FRAMEWORK FOR MAKING AND ENFO RCING POLICIES AFFECTING FOREIGN 
TRADE IN GOODS AND TR ADE IN SERV ICES .................................................................. 39  
1.   Powers of executive, legislative and judicial branches of government ..................... 39  
2.   Government entities responsible for making and implementing policies 
affecting foreign trade ................................................................................................... 42  
3.   Division of authority between central and sub-cent ral govern ments ....................... 43  
4.   Any legislative programmes or plan s to change the regu latory regime .................... 44  
5.   Laws and le gal instruments ..................................................................................... 44  
6.   Description of judicial, arbitral or  administrative bodies or procedures ................... 44  
IV. POLICIES AFFECTING TRADE IN GOODS ................................................................... 45  
1.   Import regulations ................................................................................................... 45  
(a)   Registration requirements for engaging in importing ............................................. 45  
(b)   Characteristics of the national tariff ....................................................................... 46  
(c)   Tariff quotas, ta riff exempt ions .............................................................................. 50  
(d)   Other duties  and charges ....................................................................................... 50  
(e)   Quantitative ex port restri ctions ............................................................................. 50  
(f)   Import licensi ng proced ures ................................................................................... 50  
(g)   Other bord er measur es .......................................................................................... 51  
(h)   Customs valuation .................................................................................................. 51  
(i)   Other custom s formalities ....................................................................................... 52  
(j)   Preshipmen t inspection .......................................................................................... 55  
(k)   Application of internal taxes on imports ................................................................. 55  WT/ACC/COM/3 
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(l)   Rules of origin .........................................................................................................  56 
(m)   Anti-dumpi ng regime ............................................................................................ 57  
(n)   Countervailing duty regime .................................................................................... 57  
(o)   Safeguard regime ................................................................................................... 57  
2.   Export regulation ..................................................................................................... 58  
(a)   Registration requirements for engaging in exporting ............................................. 58  
(b)   Customs tariff nomenclature, types of  duties, duty rates, weighted average 
of rates ...................................................................................................................... .... 58 
(c)   Quantitative ex port restri ctions ............................................................................. 58  
(d)   Export licensi ng proced ures ................................................................................... 58  
(e)   Other measures ...................................................................................................... 58  
(f)   Export financing, subs idy and promotio n policies ................................................... 58  
(g)   Export performa nce requirem ents ......................................................................... 59  
(h)   Import duty drawback sc hemes ............................................................................. 59  
3.   Internal policies affecting foreign trade in goods ..................................................... 59  
(a)   Industri al policy ..................................................................................................... 5 9 
(b)   Technical regula tions and st andards ...................................................................... 60  
(c)   Sanitary and phyt osanitary me asures  .................................................................... 60  
(d)   Trade-related investment measures ....................................................................... 61  
(e)   State trad ing practices ........................................................................................... 61  
(f)   Fr ee zone s ..............................................................................................................  61 
(g)   Free econ omic zones .............................................................................................. 61  
(h)   Trade-related environmental policies ..................................................................... 61  
(i)   Mixing regulations................................................................................................... 61  
(j)   Government-mandated counter trade and barter .................................................... 62  
(k)   Trade agreements leading to co untry-specific quotas allocation ............................ 62  
(l)   Government proc urement practices ........................................................................ 62  
(m)   Regulation of trade in transit ................................................................................ 62  
4.   Policies affecting foreign tr ade in agricultur al products ........................................... 62  
(a)   Im ports ................................................................................................................. . 64 
(b)   Exports ................................................................................................................... 64  
(c)   Export prohibitio ns and restri ctions ....................................................................... 64  
(d)   Export credits, export credit guarantees or insura nce progra mmes ....................... 65  
(e)   Internal  policies ..................................................................................................... 6 5 
5.   Policies affecting foreig n trade in othe r sector s ....................................................... 65  
(a)   Textile s regime  ...................................................................................................... 65  
(b)   Policies affecting foreign trade in other ma jor sect ors ........................................... 65  
V. TRADE-RELATED INTELLECT UAL PROPERTY REGIME ................................................. 67  
1.   Overview .................................................................................................................. 67  
(a)   Intellectual property policy .................................................................................... 67  
(b)   Agencies responsible for polic y formulation and im plementation .......................... 68  WT/ACC/COM/3 
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(c)   Membership of international in tellectual property conventions and of 
regional or bilate ral agreements .................................................................................... 69  
(d)   Application of national and MFN treatment to foreign nationals ............................. 69  
(e)   Fees an d charges ................................................................................................... 69  
2.   Substantive standa rds of protection ........................................................................ 70  
(a)   Copyright an d related rights................................................................................... 70  
(b)   Trad emarks ............................................................................................................ 7 0 
(c)   Geographical  indications ........................................................................................ 70  
(d)   Industri al designs .................................................................................................. 70  
(e)   Patents ................................................................................................................... 71  
(f)   Plant variet y protection .......................................................................................... 71  
(g)   Layout-designs of integrated ci rcuits ..................................................................... 71  
(h)   Requirements on undisclosed info rmation ............................................................. 71  
(i)   All other categories of intellectual property  ............................................................ 72  
3.   Measures to control misuse  of intellectual property rights ....................................... 72  
4.   Enforcement ............................................................................................................. 73  
(a)   Civil judicial proc edures and re medies  ................................................................... 73  
(b)   Provisiona l measur es ............................................................................................. 73  
(c)   Administrative proc edures and re medies  ............................................................... 73  
(d)   Special bord er measur es ........................................................................................ 73  
(e)   Criminal procedures ............................................................................................... 73  
5.   Laws, decrees, regulations and other le gal instruments relating to the above ......... 74  
6.   Statistical data on applications fo r and the granting of intellectual property 
rights, as well as any statistica l data on IPR enforcem ent ............................................. 74  
VI. TRADE-RELATED SE RVICES REGIME ......................................................................... 74  
1.   Overview .................................................................................................................. 74  
2.   Policies affecting trade in se rvices ........................................................................... 89  
(a)   Government departments, agencies , professional associations or other 
bodies with authority or a role relevant to the conduct of service activities .................. 90  
(b)   Judicial, arbitral or administrative  tribunals or procedures providing for the 
review of, or remedies in relation to, ad ministrative decisions affecting trade in 
services .......................................................................................................................... 90  
(c)   Provisions, including those in international agreements, concerning 
qualification requirements and procedur es, technical standards and licensing 
and/or registration requiremen ts for the supply of services .......................................... 90  
(d)   Provisions governing the existence and operation of monopolies or 
exclusive servic e supplie rs ............................................................................................ 90  
(e)   Provisions relating to safeguar d measures as they apply to trade in 
services .......................................................................................................................... 90  
(f)   Provisions relating to internat ional transfers and payments for current 
transactions involv ing servic es ...................................................................................... 91  
(g)   Provisions relating to capital tran sactions affecting the supply of services ............ 91  
(h)   Provisions governing services procurement by gove rnment bodies ....................... 91  WT/ACC/COM/3 
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(i)   Provisions concerning any form of aid, grant, domestic subsidy, tax 
incentive or promotion scheme a ffecting trade in  services ............................................ 91  
3.   Market access and national tr eatment ..................................................................... 92  
(a)   Limitations on the num ber of service suppliers  ...................................................... 92  
(b)   Limitations on the total value of  services transactions or assets ........................... 92  
(c)   Limitations on the total number of  service operations or on the total 
quantity of serv ice output .............................................................................................. 92  
(d)   Limitations on the total number of natural persons that may be employed 
in a particular service sector .......................................................................................... 92  
(e)   Restrictions on, or requirements of  specific types of legal entity through 
which a service may be supplied .................................................................................... 92  
(f)   Limitations on foreign capital participation ............................................................. 92  
(g)   Measures providing for less than the treatment accorded to national 
services or serv ice supplie rs .......................................................................................... 92  
4.   Most-favoured- nation treatment .............................................................................. 92  
VII. INSTITUTIONAL BASE FOR TRAD E AND ECONOMIC RELATIONS WITH 
THIRD COUNTRIES ......................................................................................................... 93  
1.   Bilateral or plurilateral agreements  relating to foreign trade in goods and 
trade in se rvices ............................................................................................................ 93 
2.   Economic integration, custom s union and free trad e agreemen ts ............................ 93  
3.   Labour markets in tegration agre ements .................................................................. 94  
4.   Multilateral economic cooperation, membership in the multilateral economic 
organizations, trade-related programmes of other multilateral organizations ............... 94  
VIII. OTHER PROCEDURAL  REQUIREMENTS ................................................................... 94  
ANNEX 1 ....................................................................................................................... . 95 
 WT/ACC/COM/3 
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ACRONYMS 
ACP: African, Caribbean and Pacific countries 
AFD: French Development Agency 
AfDB : African Development Bank 
AGID : General Tax and Property Administration 
AGOA : Africa Growth and Opportunity Act 
AIMPSI : Prince Said Ibrahim International Airport 
ANPI : National Investment Promotion Agency 
ANRTIC : National Information and Communications Technologies Regulatory Authority 
ASECNA : Agency for the Safety of Air Navi gation in Africa and Madagascar 
BCC: Central Bank of Comoros 
BDC: Comoros Development Bank 
BFC: Federal Bank of Comoros 
BIC: Bank of Industry and Commerce 
C.I.F .: Cost, Insurance, Freight 
COMACO : Comorian Handling Company 
COMESA : Common Market for Eastern and Southern Africa 
CCP: Postal current accounts 
CCUIA : Chambers of Commerce, Industry and Agriculture 
CET: Common External Tariff 
COMAIR : Comores Air Assistance 
CTN: Common Tariff Nomenclature 
CU: Customs Union 
DTIS : Diagnostic Trade Integration Study 
EBA: "Everything but Arms" initiative 
EDF: European Development Fund 
EEDC : Water, Electricity of Comoros 
EPA: Economic Partnership Agreement 
EU: European Union 
FAO: Food and Agriculture Organization of the United Nations 
FDI: Foreign Direct Investment 
FNDPC : National Forum on Trade Policy Development 
F.O.B .: Free on Board 
FTA: Free Trade Area 
GATT : General Agreement on Tariffs and Trade 
GDP Gross Domestic Product 
GPRSP : Growth and Poverty Reduction Strategy Paper 
HIPC : Heavily Indebted Poor Countries 
HS: Harmonized System 
IATA : International Air Transport Association 
ICAO : International Civil Aviation Organization 
IDB: Islamic Development Bank 
IFAD : International Fund for Agricultural Development 
IFC: International Finance Corporation 
IMF: International Monetary Fund 
IMO: International Maritime Organization 
IOC: Indian Ocean Commission 
LDC: Least Developed Country 
MAMWE : Madji na Mwedje (Water and Electricity) 
MDG: Millennium Development Goals 
MECK : Comoros Savings and Credit Associations 
MFN: Most-Favoured-Nation 
MIGA : Multilateral Investment Guarantee Agency 
NIF: Tax Identification Number 
OAPI : African Intellectual Property Organization 
OCPI : Comorian Intellectu al Property Office 
OHADA : Organization for the Harmonization of African Business Law 
OIF: International Organization of la Francophonie 
ONICOR : National Office on the Impo rtation and Marketing of Rice 
PNAC : National Pharmacy of Comoros 
RAU: Single Administrative Charge WT/ACC/COM/3 
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SAP: Structural Adjustment Programme 
SIACE : Islamic Society for the insurance of investment and export credits 
SCH: Société Comorienne des Hydrocarbures [State-owned oil import company] 
SOCOPOTRAM : Société Comorienne pour le Transport Maritime [Comorian Maritime 
Transport Company] 
TC: Consumption Tax 
TCR: Regional Cooperation Tax 
TUI: Single Import Tax 
TUS: Specific Single Tax 
UN: United Nations 
UNWTO : World Tourism Organization (UNWTO) 
UCCIA : Union of the Chambers of Commerce, Industry and Agriculture 
UNCTAD : United Nations Conference on Trade and Development 
VAT: Value Added Tax 
WB: World Bank 
WCO : World Customs Organization 
WIPO : World Intellectual Property Organization 
WTO : World Trade Organization 
 WT/ACC/COM/3 
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I.  INTRODUCTION 
1.  In support of its request for accessi on to the WTO under Article XII of the 
Marrakesh Agreement Establishing the World Trade Organization (WTO), the Government of the Union of the Comoros submits this Memorandum on the Foreign Trade Régime of the 
Union of the Comoros. 
2.  Since gaining independence on 6 July 1975, the Comoros have not experienced the full level 
of political stability required for socioeconomic development and the establishment of a viable 
political and institutional framework. Instability has severely hindered the country 
in its development efforts. 
3.  With the support of several international organizations (including the African Union, 
the International Organization of la Francophonie, the United Nations, the European Union, 
the League of Arab States, the Indian Ocean Commission) and friendly countries (South Africa, 
France, Mauritius), the Comorian parties reached a resolution of the dual separatist and institutional crisis when on 17 February 2001 they  signed the Fomboni Agreement (Fomboni is the 
main settlement on the Island of Moheli, the smal lest in the Archipelago), which formed the basis 
of subsequent agreements and the new institutional framework. 
4.  The fact that the Union held presidential  elections on 14 May 2006 and 26 December 2010 and 
conducted them in a transparent fashion that was commended by international observers, 
demonstrates respect for the new provisions of the constitution and consolidates the process of national reconciliation. 
5.  The annual GDP per inhabitant of the Unio n of the Comoros was assessed at US$820 in 2010, 
placing this outlying island country among the least developed countries as defined by the UN and 
recognized by the WTO. That indicator has risen by over 30% since 2007. 
6.  The modest Comorian economy has a number of structural handicaps that affect growth. 
Limited resources, a narrow manufacturing base and a wafer-thin export base (making 
it particularly vulnerable to external shocks) are the source of a serious trade imbalance, and the country's relatively high external debt, alongs ide growing unemployment, are exacerbating the 
country's economic problems. Comoros has a small domestic economy and low institutional 
capacity. The economy is focused on the primary sector and retail services which account for 51% and 18% of GDP respectively. The primary sector is  concentrated on the production of three high 
value export crops: vanilla, cl oves and ylang-ylang essence, which provide the bulk of export 
revenue (around 95%). Agricultural food producti on, chiefly bananas and tuber crops, together 
with peaches for the local market, is still in short supply. 
7.  The Comorian economy is strongly dependent on public development aid and assistance from 
donors, and transfers from the diaspora in France to balance its foreign accounts. 
8.  The world food crisis in 2007-2008 had a major impact in Comoros. Imports – chiefly of rice, 
meat, dairy products and cooking oils – cover around half of food consumption and rising food 
prices on international markets affect Comorians and contribute to increased food insecurity. 
In particular, the prices of vegetable oils and me at have risen by over 50% over the last year. 
The price of imported dairy products – chiefly powdered milk – doubled last year. 
9.  Economic development over the past 20 years has been restricted by a combination 
of recurring political crises, macroeconomic imbalances and external shocks. This led to a gradual 
fall in real GDP per inhabitant at an average annual rate of around 1% in the mid-1990s. 
10.  Real-term growth has been positive, rising from 2.2% in 2010 to 2.6% in 2011. 
Economic activity has developed against a background of a modest rise in prices to consumers 
despite increased external financial assistance . Indeed, to prevent inflationary tendencies, 
the monetary authorities have tightened up monetary policies by raising the reserve requirement 
from 25% to 30%. Consequently average annual infl ation fell to 1.8% in 2011 from 3.8% in 2010. 
11.  Comoros has been carrying an unsustainab le external debt burden for over 20 years 
and is debt distressed. Following the cancellati on of US$34.5 million to the African Development WT/ACC/COM/3 
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Bank at end-2007, public external debt was estimated at around US$276 million (around 56.7% 
of GDP) compared to 67.4% at end 2006. In 2008, Comoros' debt in relation to net present value (NPV) was 238% according to IMF estimates. Debt servicing accounted for 11% and 13% of exports and revenue respectively. 
12.  The International Monetary Fund (IMF) and the World Bank agreed on 17 and 20 December 
respectively that Comoros had reached Completion Point under the Enhanced Heavily Indebted P o o r  C o u n t r i e s  ( H I P C )  I n i t i a t i v e .  T h a t  d e c i s i o n  w i l l  c u t  t h e  c o u n t r y ' s  e x t e r n a l  d e b t  
by US$176 million, representing a reduction of up to 59% in the country's future external debt 
servicing over a 40 year period. 
13.  In order to deal with these many challeng es, Comoros has undertaken to work towards better 
regional integration within COMESA and to ensure monetary stability by anchoring the Comorian 
franc in the euro zone and the currencies of the Franc Zone (Note: 491.9677 KMF = 1 euro). 
14.  The possibility of a strategic foothold in the regional integration process for Eastern 
and Southern Africa provides the country with  opportunities within the COMESA common market, 
with its population of over 400 million people, an d removes the burden of a small island market 
while pursuing the process of economic and so cial development. Membership of the franc 
and euro zones is a considerable factor promoting monetary stability. 
15.  In the 1990s the Comoros successfully launched a programme of economic liberalization that 
gave a prominent place to market-economy reforms and private-sector-led growth. As a result the 
State has divested itself of its monopoly on meat  marketing, port handling, and the production and 
distribution of water and energy. The State resu med control of activity in the energy sector 
following the failure of the private foreign company and in the absence of any other successor. 
16.  The State continued in this approach by di vesting itself of the air and maritime transport 
sector and breaking up the national airline Ai r Comores and SOCOPOTRAM, the maritime transport 
company. This paved the way for full liberalization of the sector to private operators. 
17.  As part of this approach, postal and telecommunications activities were separated from the 
principal public operating company, the Société Nationale des Postes et Télécommunications  
(SNPT). Since 2004 services have been provid ed by two independent public companies: 
Comores Télécom  and Société Nationale de la Poste et des Services Financiers  (SNPSF). 
This development prepared the ground for the gr adual divestiture of the State from the sector, 
a commitment reflected by the signature in 2009 of a service contract with the IFC conferring upon 
it the authority to assist the State in exploring the modalities and best conditions for the 
privatization of Comores Télécom  and Société Comores Hydrocarbures  (hydrocarbons). 
18.  By adopting a new law on the investment code in 2007 the Government boosted Comoros' 
attractiveness as a destination for both domestic and foreign direct investment, offering a revised 
and updated package of benefits comparable to othe rs available in the region and the international 
competition. Meanwhile the authorities acceded to the COMESA Common Investment Area (CCIA). 
The law established the National Investment Promotion Agency (ANPI). 
19.  Comoros has a small share of international trade; exports accounted for only US$5.28 million 
in 2008 compared to US$9 million in 2007, and imports for US$120 million. Comoros has been affected by the aftermath of the events and ch anges that have occurred in the world economy, 
especially the food and energy crisis, and subsequently the financial crisis. 
20.  The Government has set a target of promotin g exports by fostering improved competitiveness 
for its traditional products and pursuing a policy of diversification that focuses on the niches where 
the country would appear to have a comparative advantage, particularly exports of manufactures 
and services, as part of an outward-orientated st rategy for the production of goods and services 
for export to markets providing preferential a ccess (COMESA, the League of Arab States, the 
European Union and, through the access provided under the AGOA initiative, the United States). 
21.  The national development strategy set out in the Growth and Poverty Reduction Strategy 
Paper (GPRSP 2009) prioritizes the tourism industry  and associated services, and fisheries as the WT/ACC/COM/3 
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principal engines for growth in the medium and long term. The strategic approach to achieve that 
end is to attract a greater volume of foreign direct investment in those key sectors. 
22.  Comoros hopes that accession to the WTO will help it achieve these objectives. As a result 
of its commitment to the Diagnostic Trade Inte gration Study the country gained access to the 
Integrated Framework programme. The reso urces available under Window 1 enabled 
it to strengthen its capacity to oversee external  trade, assess the overall competitiveness of the 
Comorian economy, identify the sectors with greater export potential and to lift barriers 
to trade development. 
23.  After completing this stage of the IF proc ess, the country gained access to Window 2 funds 
amounting to US$1 million which since the third quarter of 2008 have enabled the country to take a number of priority measures identified in the diagnostic study action matrix. Additionally, the 
greater resources available under the Enhanced Integrated Framework will allow implementation 
of other actions in the matrix. 
24.  Incidentally, as a net importer of almost everything needed for trade and consumption, 
the country cannot afford to remain outside the processes that shape international trade. 
Regardless of the size of its economy, the Union of  the Comoros is of the view that it has a great 
deal to offer the WTO, particularly with regard to improving the understanding of problems that 
least developed countries and small, vulnerable island economies face in conducting their trade 
relations and becoming part of the world economy. 
25.  The Union of the Comoros wishes to become a Member of the WTO in accordance with terms 
and conditions that have due regard to its stat us as a small island country with a vulnerable 
economy that is among the least developed countries in the world, where production, transport 
and distribution, among other factors, give rise additional costs that place a heavy strain on its trade and have repercussions for the income of the most vulnerable social groups. 
II.  ECONOMY, ECONOMIC POLICIES AND FOREIGN TRADE 
1.  Economy (a)  General description 
26.  Comoros is a small archipelago formed by four islands: Mayotte (Maore), Anjouan (Ndzouani), 
Moheli (Mwali) and Grande Comore (NGazidja). The archipelago lies 400 km north-west of the island of Madagascar and 300 km from the coast of Africa at the entrance to the Mozambique 
Channel. At the northern entrance to the Mozambique Channel between Africa and Madagascar, 
the archipelago is located between latitude 11°20' and 13°04' South and 43°11' and 45°19 
longitude East. The four islands are all located within 30 to 40 km from each other. 
 
 
 WT/ACC/COM/3 
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27.  The archipelago extends over a distance of 250 km from east to west (Mayotte, Anjouan, Moheli and Grande Comore) and also includes a large number of islets. The country is located 300 km off the coast of East Africa. The capital city, Moroni, is on the island of Grande Comore. 
28.  The country's official name since 2002 has been Union des Comores  (in French) 
(Union of the Comoros) or Udzima wa Komori  (in Comoran). 
29.  The island of Grande Comore to the north-west covers an area of 1,148 km² 
(longitude: 43. 38° East, Latitude: 11.75° South), whereas Anjouan measures 424 km², 
Moheli 290 km² and Mayotte 376 km². Mayotte has been under French administration since 1975, the date of its unilateral declaration of independence. In total the archipelago extends over 2,236 km², of which 1,862 km² comprise the is lands of Anjouan, Moheli and Grande Comore, 
over which the Union of the Comoros exercises sovereignty. 
30.  In terms of its geology, the Comoro Archipelago consists of volcanic islands. Like some of the 
massifs in the north of Madagascar, the Comoros were formed in the Tertiary 
and Quaternary Eras. The island of Mayotte is the oldest still above sea level and underwent three 
volcanic phases between 15 million and 500,000 years ago. The ages progressively decrease from east to west. The most recent island is that of Grande Comore, and rising to a height of 2,361 m, 
its volcano, Karthala, is still active. The summit caldera is one of the largest in the world. 
31.  The Comoros Archipelago enjoys a tropical maritime climate, characterized by slight daytime 
temperature variations throughout the year of around 26°C at sea level and by abundant 
precipitation: 2,679 mm a year. The average temperature of the sea water is 25°C. 
32.  There are two seasons in Comoros: the hot and humid season  flowing in from the north-west 
from November to April and the dry season  from May to October. The climate on Mayotte is, 
nevertheless, noticeably warmer and drier. The climate is also characterized by significant local 
variations in temperature and precipitation according to altitude, relief and the degree of exposure 
to the elements. Annual precipitation varies in the region from 1,000 to 6,000 mm and the record 
lowest temperature of 0°C was recorded at the summit of Karthala. 
33.  The hot, dry season is caused by a vast low pressure area which extends over a large part 
of the Indian Ocean and Central Africa. This low pressure favours gusty winds and cyclones. (The last cyclone was " Gafilo " which passed close to the Comoros on the 5 March 2004 causing 
great material damage.) During the hot and humid season as much as 200 mm of rain can fall 
in 24 hours. 
34.  The dry season is calmer. The low pressure moves towards the continent of Asia (this 
is the Monsoon, the wind blowing from the so uth-east) and an anticyclone forms above the 
Comoros. This still does not prevent the islands from having a few gusts of wind, but their 
intensity is a lot less than during the hot season. 
35.  Average rainfall is between 1,500 and 5,000 mm. Grande Comore has the most abundant 
rainfall for altitude. Rainfall is greatest on the coasts and Western slopes. The eastern coastal 
region however varies from dry to very dry in  places. Annual rainfall can vary between 600 
and 7,000 mm depending on altitude and the expo sure of slopes to the wind: from 1,187 mm 
on the island of Moheli to 8,042 mm on the island of Grande Comore (recorded maxima 
and minima). 
36.  The Comoros are periodically hit by cyclones – spiralling, mobile cloudy air masses 
accompanied by very strong winds and torrential rain. Three types of cyclone may hit the 
Comoros, depending on whether they form along the archipelago, to the north of Madagascar, 
or to the east between longitude 55° and 65° East. It should be noted however that climatic disturbances recorded globally have led to a clear drop in precipitation, a change in the timing 
of the seasons, and a rise in aver age temperature of around 0.5 °C. 
37.  The volcanic origin of the archipelago means that the islands are generally rocky 
and mountainous with extensive coastal strips that vary in size depending on the island. The land is particularly fertile, especially at the mouths of valleys where alluvial deposits are very thick. WT/ACC/COM/3 
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38.  Comorian flora and fauna are similar to those of Madagascar but exhibit certain individual 
characteristics owing to their relative isolation. 
39.  The rising human population density is th e greatest threat to animal and plant life. 
Various studies have concluded that the primary forests of Comoros will disappear within 15 years 
if deforestation continues at its current rate. The second most serious threat is from invasion 
by exotic species. 
40.  The total area of dry land is divided as follows: 
 - arable land 35.87%; 
- land under permanent cultivation: 23.32%; - other: 40.81% (2005). 
 
41.  Plant cover consists in the main food crops, namely maize, cassava, sweet potato, banana, 
legumes and coconut. The second most abundant plant cover is in the form of cash crops, mainly 
vanilla, clove, ylang-ylang and basil. Nonethel ess, pastureland and forests cover around 10% 
of the area of the three islands of the Unio n of the Comoros, according to estimates. 
42.  The fisheries sector is not commercially significant and remains a small-scale industry serving 
the needs of local consumption. 
43.  The islands in the archipelago have few known mineral resources. The few that have been 
identified including basalt, pozzolana (a siliceous volcanic ash that can be used in the manufacture of hydraulic cement). There are small seams of cl ay and pools of mineral water. Salt production 
offers significant potential for growth, however the country continues to import salt from 
Madagascar. 
44.  According to data from the General Popula tion and Habitat Census of 2001 and estimates 
from the National Statistics Department on demographic trends in Comoros, the total population 
of the archipelago, excluding Mayotte, is 669,327, distributed unevenly across the three inhabited 
islands that comprise the Union of the Comoros: Grande Comore, the largest island, has the largest population with 342,201 inhabitants, followed by Anjouan with 283,522 and Moheli, 
the least populous, with 43,604 inhabitants. French-administered Mayotte has 
186,452 inhabitants. The annual rate of populati on growth is 2.76%. It is 3.77% in Mayotte, 
a rate that has largely been sustained on the island as a result of inter-island migration with Grande Comore, Mayotte and Moheli the chie f beneficiaries of demographic growth. 
(b)  Current economic situation 
45.  With a population of 794,683, excluding Mayotte, and a gross domestic product 
of US$579.15 million (provisional figures for 2011, National Statistics Directorate), (around 
US$730 per inhabitant in terms of parity of purchasing power), Comoros' small island economy 
faces many challenges. 
46.  The primary sector is a striking feature of the Comorian economy, accounting for 40% of GDP 
chiefly in the form of agriculture, livestock and fishing according to the BCC report of 2011. 
The average growth rate was 3.4% in the period 1986-1990. The agrifood sector is regarded as one of the principal drivers of the economic re vival. It accounts for around 70% of the active 
population and provides 90% of export revenue. 
47.  The secondary sector including industry, construction and energy production accounts for 
12%, including 4% for industry. The low share of in dustry in the structure of GDP is illustrative 
of the country's under development. 
48.  The tertiary sector, covering administration, commerce, tourism and banking services, 
accounts for 48% of GDP. Import trade plays a leading role in the sector. WT/ACC/COM/3 
- 13 - 
Chart 1: GDP by categories of expendit ure and branch of economic activity 
in 2009 - Comoros 
100.8  
15.7 13.4 14.9 44.9 
050 100 150 
% du PIB GDP by expenditure (%)  
Household consumption expenditure
Government consumption expenditure
Gross capital formation
Exports of goods and services
Imports of goods and services% of PIB 48.2 
10.5 41.4 
0102030405060
% du PIB GDP by economic activity  
Agriculture, hunting, forestry and fisheries  
Industry
Services% of PIB 
 
Source: UNCTAD Handb ook of Statistics. 
 
49.  Generally, agricultural production is disadv antaged by the dichotomy between food crops and 
largely inadequate food production to cover the population's current and future needs, and the 
supply deficit that is reflected in high import demand. Yet export supply is essentially agricultural 
in origin and includes cash crops inherited from the colonial period, the principal products being vanilla, clove, and ylang-ylang essence. The latte r products are heavily dependent on world price 
levels however, and consequently experience fierce international competition, except for 
ylang-ylang essence, where Comoros is the world leader. 
50.  The small island economy of Comoros may seek to position itself in the niches where it would 
appear to have potential and uncontested comparative advantage, such as fisheries and tourism, 
in addition to agrifood in order to improve domestic supply levels. 
51.  These strategic approaches are reflected in the frame of reference of the Growth and Poverty 
Reduction Strategy Paper (GPRSP) and the development strategies of the Diagnostic Trade 
Integration Study (DTIS). The latter, a frame of reference for external trade the chief elements 
of which are currently in the process of incorporation into the PRSP under review, sets out a priority action matrix detailing the opportunities and barriers that must be dealt with for the 
sector to flourish properly. 
52.  The absence of structural incentives for the rational allocation of resources to local production, 
for example the paucity of the domestic market, th e division of land and the islands' relative 
isolation from the major flows of world tr ade, severely disadvantages the economy. 
53.  The considerable burden of those constraints explains why Comoros remains dependent 
on external resources to finance its economy,  essentially through public development aid 
and transfers of remittances from its extensive diaspora in France which account for almost 20% 
of GDP and the annual equivalent of the State budget respectively. The remittances contribute 
50% of the balance of payments. The trade balanc e has had a structural deficit for a long time 
because of the strong imbalance in trade; it accounted for between -10% and -30% of GDP 
between 2004 and 2011. 
54.  The deficit rose considerably after 2004, reaching -25% of GDP in 2007 and 2008 following 
a downward trend that had begun three years earlier. Since 2000, exports have accounted 
on average for 10% of GDP, although the figure  for 1991 was 20%. Terms of trade have tended 
to deteriorate, reaching a periodic mean of around 35% between 2005 and 2008. Performance was clearly better at the start of the 1990s where the periodic mean was slightly over 5% according to the most recent data from the IMF. WT/ACC/COM/3 
- 14 - 
2.  Economic policies 
(a)  Main directions of the ongoing economic policies - Independence and introduction of a command economy 
 
55.  Comoros gained international sovereignty through a unilateral declaration of independence on 
6 July 1975 following almost 150 years of French co lonial administration. Political openness began 
to grow after 1990 and led to the establishm ent of pluralism of political parties. 
56.  After gaining independence, Comoros experienced two single-party political regimes; the 
second of these, a social liberal regime, came to power in 1978 and implemented a liberal economic policy. 
57.  Since gaining independence and until the beginning of the 1990s the country received 
sustained development aid averaging US$60 million a nnually; this sustained the bulk of long-term 
growth over 20 years. Indeed, growth reached 8% during that period. It decelerated after the beginning of the 1990s and fell to less than  2%. Since the mid-1990s it has made a modest 
recovery to just over 2%. 
58.  The long-term analysis of Comoros' growth performance reveals a strong correlation between 
growth and public development aid. 
59.  Since 1978 economic policy has been both social  and liberal with a fairly large public sector 
and a few public monopolies in various sectors (air and maritime transport, posts and telecommunications, hydrocarbons, tobacco an d matches, imports and marketing of essential 
products such as rice and meat, hotels, ports and airports) and a similarly sized private sector 
at the heart of the system. The State used to pl ay a considerable role in the economy and the 
country had around ten State enterprises until the beginning of the 1990s. 
60.  In that period, the development plan gave priority to strengthening supply to the domestic 
market with two programmes focused on agriculture and fisheries. An export stabilization fund 
introduced by the authorities was dismantled in favour of the first structural adjustment programme with the IMF in 1990. 
- Economic liberalization 
 61.  Over time, State involvement in the economic structure of the country in the form of public 
enterprises in certain sectors has proved unjustifiable. However, it was only against 
the background of the first structural adjustment programme with the IMF and the movement for 
democratic liberalization in the 1990s that the State agreed to divest itself of certain importation and marketing activities, involving fo r example meat, tobacco and matches. 
62.  This watershed in the movement for economic liberalization became more significant when the 
public monopoly over the air transport sector was dismantled, resulting immediately in the liquidation of the national companies Air Comores , and the Société Comorienne 
de Manutention , alongside a refocusing of the State presen ce in the exercise of port authority, 
representation of the principal maritime companies serving the country, minor levels of lighterage and transhipment activity to facilitate intra-is land and regional trade and reduce the relative 
maritime isolation of Comoros. That activity was brought together in 1991 under the umbrella 
of a public body, the Comorian Ports and Maritime Transport Company (SOCOPOTRAM). 
63.  SOCOPOTRAM was fully dismantled in 2002 as part of the privatization of the port handling 
activity for which it was responsible. It was replaced by the Autorité Portuaire des Comores  
and port handling has been provided by foreign private companies alongside a local branch of the 
company Mer Australe, the Compagnie Comorienne de Manutention  (COMACO). One of the foreign 
companies, the Anjouan Stevedoring Company , is established under Comorian law and conducts 
port handling for the principal deep-water port  in the Union of the Comoros, Mutsamudu. 
The Al Marwan Gulftainer Consortium has conducte d operations in the port of Moroni since 2006. WT/ACC/COM/3 
- 15 - 
64.  The financial sector, which has for a long time borne the clear stamp of the monopoly 
situation that existed in the absence of genuine competition, has developed strongly since 1993 
with the emergence of two mutual benefit micro-finance establishments. 
65.  The first such establishment, SANDUK, was a network of local branches. Located chiefly 
on Anjouan, the network was established in 199 3 with support from the French Development 
Agency. Its first target was rural areas and its strategy was to finance fairly low cost agricultural projects. The network comprised several small br anches and had three stages of development: 
- Experimental stage over three years be tween 1993 and 1995; over ten branches 
at national level. 
Satisfactory performance at this stage resulted in progress to the next stage. 
 
- Extension and institution-building stage (1996-1998), leading to the establishment 
of 40 additional branches and the introduction of a central structure: the National Union of SANDUK; 
 
- Consolidation stage (1999-2003) leading to an enhanced network and the 
establishment of three Regional Unions gr ouping together all the SANDUK branches 
on each island. 
66.  The second micro-finance structure was the mutual Comoros Savings and Credit Associations 
(MECKs). 
67.  This structure emerged in 1995 as a result of the "Support to Economic Grass Roots Initiatives 
Project "(AIEB) supported by the International Fund for Agricultural Development (IFAD) and the 
Comorian Government. 
68.  When locking the project in on a permanent basis, an initiative was launched to establish 
intermediate finance structures between the existing SANDUK branches and the traditional 
financial establishments, targeting a medium-income clientele. 
69.  Focusing on major regional towns, the initia l aim of the project was to open 12 self-managing, 
financially autonomous mutual associations capable of collecting local savings, making them grow 
and remitting them as loans to finance grassroots economic initiatives within the three islands of the Union of the Comoros. In all, the network has seven branches on Grande Comore, four on Anjouan and one on Moheli. In August 2003 the central body (Union of MECKs) was established 
and made responsible among other things for overseeing the network, representing it to the 
monetary authorities and finance bodies, managing excess liquidity and granting credit to grassroots mutuals. 
70.  Both networks have grown significantly in terms of numbers of branches and members, 
and of the volume of transactions. They have become a feature of the Comorian financial landscape and now rank second in terms of market share for savings and credit distribution. 
They do not solely specialize in microcredit to disadvantaged populations. They have also 
developed a policy similar to that of the traditional banks. A Presidential Decree of 22 June 2004 regulates activity in the sector. 
71.  The move to open the sector to competition is growing with the opening of a local office 
of Exim Bank Limited, under the name Exim Bank  (Comoros) Limited, in December 2007. 
Additionally, the Banque Fédérale pour le Commerce  (BFC) backed by private interests, opened 
its doors in July 2009 
72.  In the air services sector, air traffic control and assistance to navigation services, 
which until 2005 had been within the exclusive comp etence of the civil aviation and meteorological 
authority, were licensed to ASECNA, an inter-State body governed under private law. The licensing 
process led to significant investment to bring the main international airport into line with 
current standards. WT/ACC/COM/3 
- 16 - 
73.  The former civil aviation an d meteorology directorate became the Agence Nationale 
de l'Aviation Civile et de la Météorologie  (National Civil Aviation and Meteorology Agency), a public 
administrative establishment. 
74.  The State continues to have a presence as an economic stakeholder in a few public 
monopolies including the Société Comorienne des Hydrocarbures  (SCH) (hydrocarbons), 
MAMWE (water and electricity), Comores Télécom , SNPSF, COMAIR (ground-handling at airports), 
Office National d'Importation et de Commercialisation de Riz  (ONICOR) (rice imports 
and marketing), the Comoros Development Bank , Banque de Développement des Comores  (BDC), 
and the Pharmacie Nationale de Cession des Comores  (pharmaceuticals). The fact remains that the 
State, in accordance with the BrettonWoods institutions, will study the best approach to take to achieve appropriate privatization of the activities still under its control. 
75.  In that regard the State signed a service contract with the International Finance Corporation 
(IFC) in January 2009 conferring the requisite auth ority upon the IFC to provide the State with 
services to assist in the privatization of companies – initially SCH and Comores Télécom, 
in an order of priority proposed by the IFC's partners. 
76.  In accordance with IMF recommendations, the framework for the import of ordinary rice 
shifted away from a State monopoly and towards a cooperative structure, with the relevant private 
importers helping to finance the main public operator's operations, when the authorities renounced 
their monopoly during the supply difficulties encountered during the food crisis. The authorities subsequently continued to grant import authorizations to private operators as necessary. The public operator played a purely regulatory  role supervising and monitoring operations 
conducted privately. 
77.  By committing to liberalization and total or partial divestiture, the authorities have given the 
appropriate priority to the domestic market and are seeking to remedy the lack of managerial 
skills and qualified staff needed to improve the na tional economy's efficiency and competitiveness. 
The Government therefore intends to remedy the sh ortcomings of previous economic policies that 
gave rise to a number of problems including: 
- poor management and interference; 
- inefficiency in factors of production; - increased public debt; - poor productivity and poor profitability of certain public investments; 
- an under-developed private sector; 
- an increasingly significant informal sector; - limited competitiveness; and 
- a fall and stagnation in development aid. 
78.  Faced with a multitude of problems, the government decided that it would be necessary 
to restructure the economy in order to addre ss them, support long-term growth, employment 
and poverty reduction. The establishment of a stable political and institutional framework 
since 2001, the consolidation of democracy around  the principle of changes in political power 
following regular, free, democratic and transparen t elections, has given a renewed vigour to the 
process of economic restructuring. 
79.  The key choice was to demarcate the role of the State in the economy, thereby signalling the 
authorities' determination to increase Comoros' involvement in the world economy by prioritizing the private sector as a driver of development. 
80.  One of the first tasks the government embarked upon was to establish an environment where 
the financial, hotel, and telecommunications sectors were open to private Comorian and foreign interests and to establish new foreign banks such as the Banque Fédérale du Commerce , 
controlled by Kuwaiti private interests, Exim Bank , and mutual benefit microfinance networks. 
Private interests from the Gulf, including Dubai World  and Comoros Gulf Holdings  positioned 
themselves in the hotel and telecommunications sectors with a second GSM operator. 
81.  Five (5) State enterprises have been privatized since the 1990s and the State is poised 
to transfer its majority shareholding in the Banque de Développement des Comores  (BDC), WT/ACC/COM/3 
- 17 - 
a semi-public enterprise, to a private partner. The State is likely to retain a minority shareholding 
in BDC. In 2005, assistance to air navigation was transferred from the State to ASECNA, a multilateral agency representing 17 member states in Africa. 
82.  The State continues to hold shares in five entities, namely AIMPSI, SCH, SNPSF, 
Comores Télécom  and ONICOR, all of which remain under  government control, although three 
of them have competitors in their sectors and do not hold a monopoly (SNPSF, Comores Télécom  
and ONICOR). The only true monopolies that cont inue to exist are in the supply of hydrocarbons, 
and the production and distribution of water and electricity. 
83.  The State's divestiture of production satisfies a long-term objective of supporting 
an expansion of economic activity, attracting FDI and promoting the Comorian private sector. 
Table 1: Privatized enterprises 
Original name Name after privatization or divestiture 
SOCOVIA (meat) Importation and commercialization of meat fully liberalized 
and in the hands of private Comorian importers 
SOCOMA (handling) Wound up; acti vity transferred to SOCOPOTRAM 
SOCOPOTRAM (ports and maritime transport) Activities broken up and port handling activity licensed out 
AIR COMORES (air transport) Wound up an d sector fully liberalized; three private 
operators 
STAC (tobacco and matches) Wound up, activi ty liberalized and opened to competition 
EEDC (water and electricity) Under a farmout arrangement, the company was renamed 
CEE, a subsidiary of Vivendi 
Source: Ministry of the Economy and Trade.  
- Recent economic developments 
 
84.  The economic situation of the Union of the Co moros has improved slightly over the last three 
years. The real rate of growth has remained positive, rising from 2.2% in 2010 to 2.6% in 2011. 
The generally favourable trend continued in 2012. The revival was mainly driven by activity in 
construction and public works, as well as in food crop agriculture. The economy continues to benefit from sustained donor support, foreign direct  investment, and resilient remittances from the 
diaspora. Notwithstanding a moderate deterioratio n in the terms of trade, the external current 
account deficit narrowed significantly to 6.9% of GDP in 2012 from 9% of GDP in 2011, reflecting 
a surge in public transfers, including under the economic citizenship program. As a result, gross international reserves increased to a level equivalent to 7.2 months of imports. 
85.  Economic activity has developed against a back ground of a modest rise in prices to consumers 
despite increased external financial assistance . Indeed, to prevent inflationary tendencies, 
the monetary authorities have tightened up monetary policies by raising the reserve requirement 
from 25% to 30%. Consequently average annual infl ation fell to 1.8% in 2011 from 3.8% in 2010. 
86.  Progress in budget consolidation continues; the authorities exceeded their 2012 revenue 
target, and brought the wage bill under tighter control following the 2011 census of the civil 
service. Excluding a windfall in economic citizenship receipts, estimated at 3.1% of GDP, 
the domestic primary budget deficit narrowed to 0.9% of GDP in 2012, compared with an IMF 
programme objective of 1.1% of GDP and 1.1% of GDP in 2011. 
87.  In the face of steady real appreciation of the euro-pegged Comorian franc, and with the terms 
of trade declining by an annual average of 16% in the last three years, the external current 
account deficit hit the equivalent of 7.5% of GDP in 2009. The deficit widened further to 9.8% of GDP in 2011 - mostly on account of the worsening trade balance deficit in conjunction with 
a rise in imports and a deterioration in the balances of services and revenue despite the 
improvement in exports of cloves and the consol idation of current transfers. At 56.5% of GDP 
in 2011 compared to 64.2% in 2010, the debt ratio has improved. This is due to the relief obtained under the IMF programme. The country's extern al debt remains unsustainable, however. 
88.  Under the heading of liberalization and State divestiture, the authorities again demonstrated 
the State's willingness to divest in the form of a service contract with the IFC, a subsidiary of the 
World Bank, conferring upon it the authority to examine and submit for a pproval by the national WT/ACC/COM/3 
- 18 - 
authorities the options and modalities for the privatization of Comores Télécom  
and Société Comores Hydrocarbures . 
89.  The authorities have signalled their determination to step up the pace of reform 
and liberalization, aiming in 2013 to secure effective private sector involvement in the 
management of Comores Télécom and to bring about substantive changes in the management 
of MAMWE (water and electricity) and the State-owned oil-import company (SCH). 
90.  In 2011 inflation fell as a result of the drop abroad in the prices of several imported products 
owing to the slowdown in growth and a fall in  the dollar against the euro. The trend unfolded 
against a background of a controlled rise in liqui dity driven by significant external financing 
and an improved supply of credit. Inflation was markedly more volatile, reaching 4.9% between December and December 2011. The annual average rate was contained at 1.8% in 2011 compared 
to 3.8% in 2010. 
91.  In view of the cooperation with the IMF an d the country's economic development objectives 
the Government agrees that it is crucial to improve financial intermediation to stimulate the 
development of the domestic private sector in particular, and to sustain growth. 
92.  Against that background it should be noted that two new foreign banks have opened: 
EXIMBANK of Tanzania and the BFC (Federal Bank of Comoros). 
93.  The authorities concur, however, that many challenges lie ahead, which must be addressed 
to ensure that expanded financial intermediation is effective in fostering growth over the medium term. 
94.  The political and monetary authorities intend to follow the IMF recommendations by working 
to strengthen bank supervision and licensing, and to improve micro-finance institutions (MFIs) 
regulation. To address weaknesses in these areas, the authorities have: 
(1) asked for IMF technical assistance in bank supervision and; 
(2) initiated negotiations with the central banks of Madagascar and Tanzania, aimed 
at securing technical support in critical bank supervision functions. 
 
95.  The authorities concur on the need to implement structural reforms, including measures 
to reduce factor costs, to diversify the economic and export base, and to improve the business environment; these are key to stemming the erosion of competitiveness, boosting exports, and reducing external imbalances. 
- Price policy 
 96.  The price policy in force is governed by Decree No. 96-126/PR, provisionally re-establishing 
price controls on certain staple products. The decree subjects twelve (12) products to price 
approval prior to being placed on the market; th e products are then subject to a price control 
procedure conducted by government departments. Ordinary rice, hydrocarbons, water 
and electricity, postal and telecommunications alone are the subject of prices administered 
by government. 
97.  A draft federal law on competition and prices is in the process of adoption; it will fill a legal 
void, lay down a common standard and harmonize rules, procedures and practices in the field. 
98.  The current price policy framework also relies  on the convergence criteria for the franc zone, 
of which Comoros is a member, and aims to st abilize the macroeconomic framework of which 
general prices (inflation) are a key aspect. 
(b)  Monetary and fiscal policies 
- Monetary policy 
 
99.  The regulatory framework governing money, credit and bank supervision in the Union of the 
Comoros is laid down in federal laws Nos. 80-07 and 80-08 of 3 May 1980 regulating Banks WT/ACC/COM/3 
- 19 - 
and Financial Establishments. They also define the role of the Central Bank of Comoros in 
monetary policy and policy on credit, monitoring and supervision of banking activities. Under those 
laws a bank's minimum capital is KMF 100 million. 
100.  The basic texts governing the financial sector are as follows: 
- Law 80-87, the Banking Law, regulates the activities of banks and financial 
establishments operating in Comoros; 
- Law 80-08 on money and the role of the BCC in the supervision of banks 
and financial establishments; 
- decree 87-005/PR regulating financial relations between Comoros and abroad. 
 101.  Additionally the Government strengthened regulations by introducing the following texts: 
- Law regulating and organizing leasing agreements; 
- Law ratifying the MIGA Convention; - Decree on the establishment of a National Committee to combat money-laundering 
and the financing of terrorism; 
- Decree reorganizing the financial information service (SRF); - Decree regulating the activities of Decentralized Financial Institutions (IFD), otherwise 
known as micro-finance activities; 
- Accession to the Islamic Society for the insurance of investment and export credits 
(SIACE/IDB) of the Islamic Development Bank. 
 
102.  Currently the Union of the Comoros has th ree commercial banks, two microcredit financial 
establishments, the savings bank and the postal cheque accounts administered by the Post Office appear likely to develop into a universal postal bank, and a development bank. 
103.  The Central Bank of Comoros (BCC) plays th e role of a central bank although its power 
as an issuing bank is restricted because the Comoros currency is pegged to the euro and guaranteed by the French Government. Nonetheless the decisions taken by the BCC board, 
a body where the Comorian and French Governme nts are equally represented, authorize banks 
and other financial establishments to increase competition and promote the development of a competitive financial sector. 
104.  The role of the BCC is to promote the monetary policy of the Union of the Comoros 
by maintaining price stability while at the same time regulating the national money supply. 
105.  Monetary policy must ensure a level of net external assets compatible with the monetary 
cooperation agreement signed with France. Within that framework and in accordance with the 
BCC's statutes, the rate of coverage of the BCC's long-term commitments by its external assets 
must be greater than 20%. Without prejudice to that target, monetary policy is part of the Government's economic policy. 
106.  The BCC sets intermediate objectives (monetary supply and domestic credit). The tools 
available to the monetary authorities to regulate th e money supply in line with the liquidity of the 
economy and the exchange reserves consist essentially of refinancing ceilings, the discount rate and the system of mandatory reserves based on customers' deposits. A uniform 35% rate applies 
to all liabilities in the assessment. The reserves are generated on an account at the BCC and bear 
interest at the current rate of EONIA-1/8. The State's opportunities for refinancing at the BCC are limited by Article 17 of the bank's statutes which restrict advances to the Treasury to 20% of the 
average of ordinary budgetary receipts colle cted over the three preceding fiscal years. 
107.  Bank interest rates are administered becaus e of the lack of competition. Since 1 March 2004 
the rates of interest on lending have been set freely by financial establishments on the basis 
of floor and ceiling rates announced by the Minister for Finance acting on a proposal from the BCC. 
The band currently in place is set at 8% and 14% and the interest rate on savings deposits is 3% annually. 
108.  There is no longer any ceiling on lending in the financial system: financial establishments 
have complete freedom over their lending policy. WT/ACC/COM/3 
- 20 - 
- Monetary cooperation 
 109.  Comoros belongs to the Franc Zone. A monetary cooperation agreement was signed between France and Comoros on 23 November 1979. The cooperation is based on: 
- an unlimited guarantee by France of the cu rrency issued by the BCC. In return France 
participates in management and supervision; 
- fixed parity between the euro and the Comorian franc, at a conversion rate 
of KMF 491.96775 to one euro; 
- deposits at the French Treasury (at least 65% of the exchange reserves of Comoros); - freedom of transfers between Comoros and France. 
 
110.  Under the provisions laid down in Decree 87-005/PR, financial transactions between 
Comoros and other countries are free. In June  1996 Comoros signed Article VIII of the IMF's 
Articles of Agreement providing for freedom of current and capital transfers The repatriation 
of dividends and capital in the event of termin ation is guaranteed under the Investment Code 
(Law 95-015 implemented under Decree 95-110/PR of 18 July 1995). 
111.  The aim of the monetary policy of the Union of the Comoros is to contribute to stabilizing the 
macroeconomic situation through monetary means and exchange policy and to support the 
exchange rate peg to the euro. The BCC will continue to make active use of the monetary instruments available to it – essentially refinancing ceilings, the discount rate and the system of mandatory reserves based on customers' deposits – to control liquidity and achieve 
monetary targets. 
112.  In view of the Comorian economy and ex ternal monetary relations, the Union of the 
Comoros' monetary policy mu st enable compliance with: 
- a level of net external assets that is compatible with the monetary cooperation 
agreement signed with France; 
- a rate of coverage of the BCC's long-term commitments by its external assets that 
is in excess of 20%, under the terms of the BCC statutes. 
 113.  Within this precise framework for action the stability of the nominal and the real effective exchange rate and currency convertibility are cr ucially important in the conduct of the central 
bank's board. The philosophy behind the country's monetary policy is the subject of broad national 
consensus and should therefore be pursued and st rengthened in conjunction with the objectives 
it seeks to attain. 
114.  The policy is conducted within the framework of the Franc Zone and therefore is essentially 
passive in nature. The monetary authorities intend to pursue their prudent line focusing on price stability and retaining a viable international investment position. 
- Fiscal policy 
 115.  The Union of the Comoros reaffirms the Government's willingness to maintain and improve the level of essential social services, develop the country's infrastructure and promote private 
sector led economic growth while retaining overall budgetary discipline. 
116.  In pursuing that aim by following a medium-term budgetary strategy as part 
of its cooperation with the IMF, public policy on fiscal matters will focus fully on improving 
revenues, the supervision and efficient manageme nt of public expenditure, and the settlement 
of domestic payment arrears. 
117.  The key revenue measures are aimed at expanding the tax base and strengthening the 
efficiency of tax and customs administration. Recent measures already taken include 
(i) introduction of a single taxpayer identification number system, (ii) implementation of ASYCUDA++ for customs revenue management, (iii ) completion of a census of major taxpayers 
and a refocusing of the large taxpayer unit's activi ties, and (iv) efforts to reduce ad hoc customs 
and tax exemptions. WT/ACC/COM/3 
- 21 - 
118.  Projected at 73% of total revenue and 60% of primary current expenditure in 2008, 
wage outlays are the single most important spen ding item in the budget. Their rapid increase 
in recent years has weakened government savings and crippled its ability to support public investment and growth. 
119.  In the face of erratic and weak revenue pe rformance, increasing wage expenditures have 
caused the accumulation of large payments arrears, hampering macroeconomic stability. 
Going forward, the authorities recognize that reining in the wage bill will be the single most 
important element of their spending policy. Unde r the latter, the wage bill is to be reduced 
to below 8% of GDP by 2013 (9% of GDP in 2008). 
120.  Corrective measures introduced and/or envisaged include (i) a freeze on civil service 
recruitment, effective 8 August  2008; (ii) a reduction of government ministerial portfolios 
from 35 to 26, effective November 2008; (iii) full computerization by end-December 2008; 
(iv) implementation of a computer based, integrated, payroll management system by end-December 2008; (v) adoption of organic frameworks setting the appropriate structure 
and optimal level of civil service staffing by end-June 2009 (see IMF memorandum); (vi) the 
adoption of a new tax code; and (vii) the estab lishment in 2012 of the General Tax and Property 
Administration (AGID). 
121.  Following full implementation of the salary management system the authorities intend, with 
technical assistance from donors, to introduce additional reforms to improve the operation of the civil service and reduce staff. 
122.  An International Monetary Fund (IMF) sta ff mission visited the Union of the Comoros from 
22 September  to 6 October  2012, to conduct discussions on the Article IV Consultation for 2012, 
the fourth review of performance under the Extended Credit Facility (ECF)1 programme, and to finalize preparations for reaching the He avily Indebted Poor Country (HIPC) initiative 
completion point. It noted that macroeconomic developments were broadly favourable in 2012. 
Progress in budget consolidation continues, with the authorities exceeding their 2012 revenue target, and the wage bill under tighter control following the 2011 census of the civil service. 
Additionally, implementation of the structural  reforms programme was broadly satisfactory. 
123.  The Government's fiscal reform programme seeks inter alia  to re-establish budgetary 
stability by containing the annual primary budget  deficit below 0.9% of GDP and raising total 
revenues to 15% of GDP in 2013. 
124.  Structural reforms, including reforms of public utilities, should help to raise growth 
in real GDP to around 3.5% in 2013. 
125.  Implementation of decentralization should allow gradual widening of the tax base to achieve: 
- income and asset base from constructed and non-constructed property; 
- income from physical persons. 
 
(c)  Foreign exchange and payments system 
- Foreign exchange system and foreign exchange controls 
 - Foreign exchange system 
 
126.  The foreign exchange system in the Un ion of the Comoros is based on the legal 
and regulatory framework provided for under Law 80-08 of 26 June 1980 on money and the role 
of the BCC in the supervision of banks and financial establishments, credit and foreign exchange, 
in particular Article 14, and under Decree No. 87/005/PR of 16 January 1987 regulating financial relations between Comoros and other countries, alongside Decision No. 98/683/EC 
of 23 November 1998 of the Council of the European Union concerning the legal basis for relations 
in exchange rate matters relating to the CFA Franc and the Comorian franc. 
127.  The IMF discussed the suitability of the cu rrent exchange rate peg under the Franc Zone 
arrangement. Both sides agreed that despite minor drawbacks in the conduct of public policy WT/ACC/COM/3 
- 22 - 
in this area, the peg has provided the main anchor for stability and has been effective in keeping 
inflation low. 
128.  Thus, convinced that the conditions for unpegging set out in the framework of the Franc 
Zone agreement have not been met, the authorities continue to view the arrangement 
as appropriate, notwithstanding signific ant pressures on the external position. 
129.  Observation of the developments in the real  effective exchange rate show an appreciation 
of 29% during 2000–2007 according to IMF estimates, mainly due to the strengthening of the 
euro against the US dollar. However, poor data quality argues for caution in interpreting the 
results. The fact remains that analysis suggests that the real exchange rate is nevertheless broadly in line with fundamentals (see Box and related selected issues paper). 
130.  The banking law has fully liberalized the foreign exchange system. Under the 
Council of the European Union Decision of 23 No vember 1998 concerning exchange rate matters 
relating to the CFA Franc and the Comorian franc, Comoros has entered into a commitment with the European Union on exchange rate matters wh ich establishes a fixed parity between the euro 
and the Comorian franc. (BCC Circular No. 02-99 on  the parity between the euro and the Comorian 
franc). The exchange rate is €1 = KMF 491.9677. Under the monetary agreement with France and in line with its relations with Franc Zone partners, Comoros has undertaken to adopt 
macroeconomic approaches that maintain the fixed parity, a fact that has repercussions on the 
definition and execution of budgetary and monetary policies. 
- Relations with the International Monetary Fund 
 
131.  The authorities and the IMF agreed that in a ddition to much needed strengthening of fiscal 
policy and implementation of reforms under Fund supported programs, debt relief would be critical in helping restore external viability over the medium to long term. Comoros faces a current 
account disequilibrium giving rise to an unstable external position. 
132.  Comoros' external position bears the stamp of the country's long-term lacklustre economic 
competitiveness as evidenced by weak export performance and growing external imbalances. 
133.  Against a backdrop of internal and exogenou s difficulties, the International Monetary Fund 
commended the Government's efforts to improve economic governance and the country's macroeconomic management, and approved Emergency Post-Conflict Assistance (EPCA) Exogenous Shocks Facility Disbursements to the country at its Executive Board meeting 
of 16 December 2008. 
134.  Cooperation with the IMF continued in 2009, resulting in a Poverty Reduction and Growth 
Facility programme and the Extended Credit Faci lity. Performance under the programme was such 
that the HIPC Initiative completion point was reached in December 2012. Comoros is one of the 
few remaining countries eligible under the HIPC initiative but qualified only last year due to an unstable political situation. 
135.  The authorities are strongly committed to st ay the course on structural reforms in order 
to provide the opportunity for long-term growth, the only means of eradicating or reducing poverty. The community of Comoros' development partners has sent a strong signal to that end and has resolved to provide the emergency suppor t the country needs to maintain the momentum 
of the reforms and prevent a return to the crises of the past. 
136.  The authorities agreed to implement structural reforms, including measures to reduce factor 
costs, to diversify the economic and export base , and to improve the business environment; these 
are key to stemming the erosion of competitiveness, boosting exports, and reducing 
external imbalances. 
- Economic performance and outlook 
 
137.  In a delicate political situation, the authorities have recently taken steps to begin addressing core economic vulnerabilities: real GDP growth that  is well below the regional average; steadily WT/ACC/COM/3 
- 23 - 
declining per capita income; rising food and en ergy costs that have worsened the external 
position; and an external debt burden far above the HIPC threshold. 
138.  To reverse the deteriorating trend, the authorities initiated measures in 2008 to contain the 
fiscal deficit and begin addressing macroecono mic and structural impediments to growth. 
Membership of the Franc Zone, the main anchor of stability, is helping to contain pressures on 
domestic prices. 
 Efforts have been made to restore fiscal sustainability. 
 There is no evidence that the real exchange rate is misaligned. 
 The authorities have started tackling structural impediments to growth. 
 Attainment of Post-Conflict and Fragile State status . 
 Access in 2008 to the EPCA and ESF facilities within the framework of relations with 
the IMF, outlook for the HIPC Initiative De cision Point, signature of a three year 
Poverty Reduction and Growth Facility programme in 2009. 
 Decision by the IMF and World Bank Executive Boards that Comoros reached the 
completion point under the Heavily Indebted Poor Countries (HIPC) Initiative in 2012. 
139.  However, Comoros faces a current account disequ ilibrium giving rise to an unstable external 
position prior to the receipt of debt relief; there is a need to stem persistent erosion 
of competitiveness with growth-supporting structural reforms. 
140.  The authorities have upwardly revised petroleum products prices and electricity tariffs and 
intend to establish a flexible-pricing mechanism for these products; this is critical to making power supply more reliable, a key growth-supporting ingredient. The authorities also plan to accelerate 
preparations for reforms of State-owned enterprises with World Bank support, and have had 
a new version of its unique development reference framework the GPRSP since 2009. It includes trade policy as an aspect of the national development strategy. 
141.  In view of the vulnerability of the Union of the Comoros, the African Development Bank has 
granted it Fragile State  status, conferring eligibility under the principal instruments for such 
States, including an initial operation following a long break in relations with Comoros in the 
amount of US$20 million by way of a grant targeted at capacity building and governance. 
Table 2: Principal macroeconomic indicators, adjustment 2006-2013 
Year 2006 2007 2008 2009 2010 2011 2012 2013 
 Indicators      Projection 
Growth in GDP (%) 1.2 0.5 0.4 1.9 2.2 2.6 3.0 3.5  
Inflation (annual variation, mean) 3.4 4.5 4.7 4.9 3.8 1.8 3.1 3.1  
Internal revenues (% of GDP) 13.6 12.7 12.4 12.7 13 13.4 13.9 14.3  
Domestic primary balance (% of GDP) -1.2 -2.2 -2.7 -1.6 -1.3 -0.8 -0.3 -0.3  
Current account balance (% of GDP) -6.1 -6.7 -8.7 -10.5 -10.3 -11 -10.4 -10.6  
Foreign exchange reserves (months 
of imports of goods and services) 7.2 7.3 5.8 6.3 6 5.6 5.2 4.8  
Terms of trade (annual variation %) -6.9 -20.3 -21.2 -17.1 -3.1 -1.4 0.3 0.7  
Official grants and loans (% of GDP) 5.9 8.3 9.1 6.1 6.3 6.5 6.7 6.9  
Sources: Statistics Directorate, Central Bank of Comoros, IMF. 
 
(d)  Foreign and domestic investment policies 
142.  The principal objectives of the Union of th e Comoros' investment policy are to promote and 
encourage an economic environment that is tr ansparent and equitable for both Comorian and 
foreign investors, and to increase the role of the Comorian private sector in the process of the country's development. To that end the National Assembly of Comoros adopted a new Investment 
Code under Law No. 07-10/AU of 31 August 2007. The new Code benefits from being based on the 
universal standard for attracting foreign direct investment and incentives for domestic private 
investment. The advantages it confers are based on the international standard, the regime preference periods are extended and bear the origin al hallmark of progressivi ty upon entry into the 
standard fiscal system. WT/ACC/COM/3 
- 24 - 
143.  Article 4 of the new Code provides that "private investments shall be made freely in the 
Union of the Comoros subject to the specific provisions on ensuring the protection of health, public health, social protection and the economic public order". 
144.  Article 5 on the rights and freedoms of undertakings, provides that "subject to compliance 
by an undertaking with the obligations incumbent upon it under Article 12 acquired rights 
of whatever nature shall be guaranteed and the undertaking shall enjoy full economic freedom and freedom to compete. In particul ar it shall have freedom to": 
- acquire any assets, rights and concessions of any nature as may be necessary 
to its activities such as land, moveable, immoveable, commercial, industrial or forestry-related assets; 
- dispose of such acquired rights and assets; 
- belong to any professional organization it chooses; 
- choose its methods of technical, industrial, commercial, legal, company and financial 
management; 
- choose its suppliers of goods and services and its partners; 
- participate in public calls for tender throughout the territory; - choose its human resources management policy and freely recruit its staff. 
 
145.  The new Law sets out the conditions that apply to foreign direct investment in any sector of economic activity. All sectors are open to investment except where the undertaking would represent a threat to national security, the envi ronment or the public health, or would violate 
domestic legislation or regulations (for a more extensive analysis of the Law on foreign 
investment, see Titles 2 and 3 of the Law). 
146.  The new investment policy ensures that the applicable procedures are open, efficient 
and transparent. Investors can easily obtain clear information on them from the National 
Investment Promotion Agency, a government service answerable to the Minister for Investment of the Union of the Comoros. 
Chart 2: Financial flows to countries in US$ millions - Comoros 
 0 20406080
1990 1995 2000 2001 2002 2003 2005 2006 2009 2010 2011
Year 
Direct investment in the re porting econom y (inward FDI )
Remittances from workers (Recei pts)
Net total for official sector (ODA)US$ millions 
 
  Source: UNCTAD Hand book of Statistics. 
 
Inward FDI could, it is estimated, increase from an annual average of 0.4% of GDP during 
2000-2007 to about 2% of GDP over the medium-term, fuelled mainly by tourism investments 
from the Gulf States (principally Qatar, Kuwait and the UAE). According to Central Bank data, FDI stood at KMF 3,099 million in 2010 and reached KMF 8,171 million in 2011. The figures in question represent injections into the reporting economy by non-residents through the BCC, 
whereas the heading "Other Investments" accounted for KMF 13,991 million in 2010 
and KMF 7,503 million in 2011, according to the data from the BCC under its lawful statutory mandate to draw up the balance of payments. WT/ACC/COM/3 
- 25 - 
 
147.  The capital and financial account grew by 17% in 2011 essentially in tandem with the consolidation of reserve assets and foreign direct investment, despite the narrowing of other investment. The capital account stood at KMF 21 billion in 2011, down from KMF 26.4 billion 
in 2010. This 20.45% drop reflects debt forgiveness of KMF 5.8 billion, much less than 
the KMF 15.5 billion obtained in 2010. By contrast, finance for development projects funded by international agencies stood at KMF 15.2 billion, a rise of KMF 4.2 billion. 
148.  In deficit since 2009, the financial account posted an improvement in 2011 when the deficit 
narrowed from KMF 13.1 billion in 2010 to KMF 5.4 billion in 2011, reflecting in large part the improvement in the surplus on direct investment and the drop in the deficit on other investments. 
149.  The large increase in flows of FDI observed in 2011, assessed at KMF 8.2 billion compared 
to KMF 3.1 billion the previous year is associated above all with imports of capital goods for works 
on the leisure port at Moroni and the rehabilitation of roadwork infrastructures. "Other investments" posted a deficit of KMF 7.5 billion compared to KMF 13.1 billion the previous 
year, reflecting the impact of debt forgiveness. 
150.  The fact remains that the current flow of FDI is subdued despite the fiscal benefits and 
concessions offered by the government and the pote ntial of sectors such as tourism and fisheries. 
FDI as a percentage of GDP has grown in relative  terms over recent years. It rose from 6.3% 
in 2006 to 10.2% in 2011. The potential for FDI nationally has suffered some setbacks because of the poor infrastructure, including ports, and perceived inadequacies in other transport routes. 
151.  Tourism, agriculture and fisheries are the destination of the majority of foreign investment. 
The principal investor countries are France, th e USA, South Africa and the countries of the 
Gulf of Arabia. 
152.  In terms of flows, the table below illustrate s the subdued rate of direct investment in the 
reporting economy although the flow has increased. Even the total flow for the official sector is 
trending downwards in close association with the tendency for a fall in public development aid. By contrast, the flow of transfers from the large Comorian diaspora in France is stable and is far 
and away the country's largest external source of finance, helping to improve the balance 
of payments, structurally in deficit as a result of long-term commercial imbalances. 
Table 3: Amounts of schedule d investments (US$ million) 
HOTELS Amount 
Hôtel Itsandra (72 rooms + 25 villas) 15 
Hôtel Moroni (56 rooms + 4 suites) 4.5 
Source: Agreements signed with the promoters, Comoros Golf Holding, DTIS estimate 2007. 
Table 4: Comparative ranking in terms of the investment protection index 
 Comoros SS Africa United States Germany 
Investor protection index 4.0 4.3 8.3 5.0 
Source: Doing Business 2013 . World Bank. 
Table 5: FDI inflows and stocks in Comoros, 2005-2011 
 Foreign Direct Investment 2005  2006  2007  2008  2009 2010 2011  
Inward FDI flows (US$ million)  0.6 1 8 8 14 4 7  
FDI stocks (US$ million)  24.2 24.8 25.6 37 51.2 55.1 61.9  
Inward FDI (% of gross fixed capital 
formation****)  2.1 1.6 1.3 7.5 19.3 4.0 6.1  
FDI stock  (% of GDP)  6.4 6.2 5.8 7.2 9.6 10.2 10.2  
Source: UNCTAD, World Investment Report. 
 
(e)  Competition policies 
153.  A draft law on competition and prices will be put before Parliament in 2013 as part of the 
programme of structural reforms and as part of the quest for compatibility with the WTO 
multilateral frame of reference. The draft law will establish the Competition Authority, WT/ACC/COM/3 
- 26 - 
an independent body that will be responsible for regulation and oversight in conformity with the 
rules and procedures that have become universal in the field. 
154.  The new competition policy rules will endeavour to have regard to the need to ensure 
diversity of production and economic, intellectual and technical progress. The key function of the 
Competition Authority will be to rule on complaints about unfair commercial practices but it will 
also be able to place draft laws and regulations before the Government in its capacity as a consultative body in the institutional landscape and a bulwark of the State governed by rule 
of law with a particular emphasis on civil society. The Authority's decisions may be appealed 
before the courts. 
155.  The new body to be established will have competence with respect to other specialized 
sectoral bodies (food, medicaments, telecommunicati ons, etc.) to conduct negotiations on quality, 
quantities and prices with the country's principal economic operators, including current and future 
concession holders of what used to be public monopolies. It will also involve scrutinizing, overseeing, monitoring and arbitrating in an in dependent, fair and equitable fashion, certain 
de facto private monopolies and oligopolies, alongside certain situations involving exclusive 
distribution rights conferred on certain importers who have behaved like monopolies and/or oligopolies that are detrimental to healthy competition and consumer purchasing power 
in a narrow market. 
156.  As part of a wide-ranging programme of structural reforms the Government proposes to: 
- strengthen and modernize the driving pub lic sectors by conferring upon them the 
competences needed to discharge their duties; 
- pay special attention to the newly established regulatory and oversight bodies whose 
competences will be clearly defined to prevent any accusations about the manner in which they are performing their task of protecting consumer interests and ensuring 
fair practice in competition matters; 
- ensure as part of its governing role that ethical principles are observed in practice 
in relations between the Sate and the market and between commercial operators 
in general. 
 3.  Foreign trade in goods and services 
157.  Comoros has a significant trade imbalance as shown by the data in the tables below. 
158.  Following various consultations with the IMF under Article IV of the IMF's Articles 
of Agreement, the authorities concurred that enhanced international trade and foreign direct investment (FDI) would facilitate economic diversification and boost growth. In line with the 
recommendations from the Diagnostic Trade Integration Study (DTIS) concluded in 2007, 
the authorities afforded greatest priority to the development of Comoros' significant tourism potential by attracting FDI into the sector. 
Chart 3: Development of external trad e of Comoros, 2000-2011 (KMF millions) 
‐100000‐50000050000100000150000
2000 2001 2002 2003 2004 2005 2006 2007 2008 2009 2010 2011KMF millions
Years
Imports Exports Trade balance
 
Source: Customs General Directorat e and Central Bank of Comoros. WT/ACC/COM/3 
- 27 - 
 
159.  The trade deficit posted a new record in 2011 of KMF 61.5 billion compared to KMF 57.5 billion in 2010 (+7%). 
160.  The rise in exports, in particular cloves, helped towards a slight improvement in the rate 
of coverage of imports by exports at 9.1% (compared to 8.9% in 2010 and 7.1% in 2009). 
161.  The services balance deficit increased by 7.5% to KMF 11.6 billion. 162.  In essence, this was due to the worsening deficit under "transport", reflecting the rise 
in maritime transport costs. 
163.  The income balance was in deficit in 2011. It fell to KMF 277 million, a 12.2% drop compared 
to 2010. 
164.  Net current transfers fell slightly to KMF 53.3 billion in 2011 compared to KMF 54 billion 
in 2010, accounting for 25.9% of GDP compared to 27.4%. The fall reflects the 17.7% drop in the 
balance of official transfers and the decrease in  budgetary assistance. In 2011 the net balance was 
KMF 21.4 billion, compared to KMF 26.3 billion in 2010. By contrast, following an 18.7% fall, 
the balance of private transfers recorded an increase of 15.2% in 2010 to KMF 49.5 billion 
in association with an 18.1% rise in remittances of funds from the diaspora, which reached KMF 38.2 billion. 
165.  Exports of services accounted for KMF 26. 14 billion in 2011 compared to KMF 24.17 billion 
in 2010. By contrast, in 2011 the balance of services posted a deficit of KMF 11.6 billion, an increase of 7.5% on the previous year. 
166.  The overall balance was in surplus in 2009, rising from KMF - 5.3 billion in 2008 to 
KMF 10.6 billion. The IMF projections were that from 2010 the overall balance would slowly return 
to deficit. 
Chart 4: Developments in exports from Comoros, 2000-2011 
 0 2,0004,0006,0008,00010,00012,00014,000
2000 2001 2002 2003 2004 2005 2006 2007 2008 2009 2010  2011Millions FC
YearsKMF millions 
 
Source: Customs General Directorate and Central Bank of Comoros. 
 
167.  The value of exports rose by 16.4%, benefi ting in 2011 from better outlets for cash crops. 
The change reflects in particular the rise in export prices for cloves despite a 27.5% drop in volume. In 2011, cloves accounted for 71.4% of Comoros' export earnings. Sales of vanilla also 
recovered (+13.27%). In 2011 the value of exports was KMF 8.91 billion compared 
to KMF 7.65 billion in 2010. WT/ACC/COM/3 
- 28 - 
168.  Comorian exports are noteworthy for the fact that they are based on just three agricultural 
products, a situation requiring an urgent response in terms of diversification strategy and efforts to improve competitiveness on the international market. 
169.  Cloves are currently the key income-generating product, accounting for over 70% of export 
earnings. As a result of the revival on external markets, there was a rise in quantities exported, 
to KMF 6.4 billion in 2011 from KMF 5.4 billion in 2010. The upturn in exports, which until that point had been on a downward trend, reflects th e improved handling of clove exports following the 
sharp drop in 2008. 
170.  The rising trend in the value of exports is confirmed in the vanilla segment, where there was 
a 13.3% rise in value from KMF 309 million in 2010 to KMF 350 million in 2011. By contrast there was little change in volume, which rose from 39 tonnes in 2010 to 40 tonnes in 2011. Exports are 
well below the 2009 figure of KMF 645 million, reflecting the ongoing crisis in the sector. 
171.  Conversely, exports of ylang-ylang fell by 22%, partly because of the economic freeze on the 
island of Anjouan, the key centre of production. The downward trend in the value and quantity 
of essences stood at –15% in 2011, posting only KMF 745 million compared to KMF 881 million 
in 2010. 
Chart 5: Export trends in Comoros, 1980-2011 
0102030405060708090100
1980
1990
2000
20012002
2003
2004
2005
2006
2007
2008
2009
2010
2011Percent (%)Exports of services as a share of total exports
Comoros
Developing economies
Economies in transition
Developed economies
 
Source: UNCTAD. 
 
172.  Chart 5 provides a comparative overview of exports of services as a share of total exports 
for Comoros, and for developing, transitioning and developed economies. Following a growth 
phase in the 1980s it reached 70% in Comoros in 2000 and then dropped sharply until 2003. After that point it picked up, rising to over 90% of the total in 2008. A downward trend then set in 
and the share for 2011 stood at 70%. In comparat ive terms, the share of exports of services 
follows an almost stable curve for developing countries (red) at less than 20% of all exports, 
similar to that of transitioning countries (green). For developed countries (purple) the share of exports of services has been stable over a long period at around 20%. 
173.  This situation is typical of a small island  economy where trade has gradually moved towards 
the services sector against the background of an underlying fall in the volume and value of its exports of goods that are predominantly agricu ltural in origin. The large share of exports 
accounted for by services consists essentially in tourism, travel and telecommunications. This is 
indicative of a potential redirection towards a services economy, as has happened in small economies all over the world (Mauritius, Dubai, Se ychelles, etc.), as part of an outward looking 
strategy seeking to diversify the economy and improve competitiveness in order to safeguard 
certain positions and niches. 
174.  Imports rose at a faster rate (+13%) than exports, principally reflecting the increase in 
imports of rice (+68% in value). The oil bill also rose by 14%, reflecting the rise in oil prices, WT/ACC/COM/3 
- 29 - 
despite the fact that the volumes imported fell by 13.7% because of low private consumption. 
Imports of construction materials rose by 17% for cement, iron, cast iron and steel. 
Chart 6: Import trends in Comoros, 2000-2011 
020000400006000080000100000120000
2000 2001 2002 2003 2004 2005 2006 2007 2008 2009 2010 2011
YearsKMF millions 
 
Source: Customs General Directorat e and Central Bank of Comoros. 
175.  The rate of coverage of imports by exports rose considerably in 2011 to 9.1%, compared 
to 8.95% in 2010 and 7.1% in 2009. 
176.  The economy is becoming more open, showing an upward trend in trade in relation to the 
rise in exports and imports. It rose from 43% in 2009 to 47.8% in 2010 and 52% in 2011. 
177.  According to data provided by the Customs Directorate supplemented by Central Bank 
surveys and estimates, the trade deficit st ood at KMF 61.5 billion in 2011 compared 
to KMF 57.5 billion in 2010. 
Table 6: Change in the principal imports of Comoros, 2007–2011 
Products Quantities  (tonnes)  Value (KMF million)  
 2007  2008  2009  2010  2011  2007  2008  2009  2010  2011  
Rice 38,281 19,404 38,362  38,338  50,468  5,871  5,114 8,297 7,254  12,168  
Meat, fish 5,612 5,808 8,199  10,936  9,991  3,349  3,799 3,821 5,184  5,285  
Flour 5,850 5,452 8,393  9,734  9,995  704 1,250 1,634 1,739  2,240  
Sugar 3,621 3,646 6,713  8,286  7,355  1,045  746 1,443 2,278  2,406  
Dairy products 1,881 1,592 2,658  2,941  3,664  1,547  1,155 1,611 1,696  2,160  
Pharmaceutical products 540 201 279  431 246 1,442  625 672 508  738 
Fabrics, made-up textiles 1,369 957 1,502  1,755  1,523  656 501 684 646  566 
Petroleum products 35,837 36,460 43,920  53,619  47,861  10,649  12,505 12,879 19,988  22,190  
Cement 22,525 63,529 120,846  138,448  145,660  2,110  3,264 5,840 5,804  6,812  
Vehicles  3,440 5,035  5,775  8,604  2,120  9,532 7,014 11,361  17,988  
Iron, cast iron, steel 2,406 4,957 9,580  9,629  9,730  863 1,856 3,332 2,919  3,406  
Other products 20,262 68,112 48,732  65,249  68,213  17,844  22,868 23,771 27,565  21,976  
TOTAL 140,055 220,796 294,219  345,142  363,310  48,200  63,213 70,996 86,482  97,935  
Source: Customs General Director ate/Central Bank of Comoros. 
 
178.  Following a 5.3% rise in volume in 2011, the value of imports grew by 13% from KMF 86.4 billion in 2010 to KMF 97.9 billion in 2011. The rise in the total value of imports related mainly to imports of rice, petroleum products, construction materials and vehicles. 
179.  Imports of petroleum products rose in va lue and quantity from KMF 10.6 billion in 2007 
to KMF 12.5 billion in 2008 despite the severe shortages in the second half of the year that seriously disrupted economic activity. WT/ACC/COM/3 
- 30 - 
180.  However, the surge in international market prices, the appreciation of the dollar in relation to 
the euro at the end of the first quarter of 2011, and the relative rise in prices per barrel the same 
year all had an impact on the rise in value of petroleum product imports. The value of imports rose by 13.6% to KMF 22.2 billion in 2011 compared to KMF 20 billion in 2010. Conversely, the 
quantities imported fell by nearly 11% because power outages caused by the electricity generating 
company and the serious deterioration of the road network reduced private consumption. 
181.  The rise in imports also reflected a rise in  imports of rice. Following the 2011 rise in rice 
prices, and despite the consolidation of the Comorian franc against the US dollar, the value of rice 
imports rose to KMF 12.2 billion, accounting for over 12% of all imports compared to 8.4% in 2010 or over 50 thousand tonnes compared to 38 thousand tonnes. 
182.  The value of imports rose by 13% in 2011 as  an unforeseen consequence of the rise in oil 
and food prices on international markets. 
183.  There was a slight increase in the quantities imported, notably because of the delivery 
in 2011 of a large order of rice and cement. 
184.  Imports of vehicles were on an upward trend and recorded a sharp rise in 2011, reaching 
a record high, in tandem with the improvement in foreign direct investment in the country which has picked up since 2007. The quantities of cement ordered have risen significantly, 
leading to imports of other construction materials. Other food products (not rice) again recorded 
a rise of near 11% compared to 2010 and accounted for 12.3% of total imports. 
Table 7: Imports of goods and services by origin (as a % of the total) 
 1998  1999 2000 2001  2002  2003  2004  2005  2006 2009 2010  2011  
European Union 47.4  41.6 39.8 43.2  42.4 37.2 41.5 19.4 23.2 22.4 23.2  29 
United Arab 
Emirates 8.5 8.7 11.8 9.5  8.5 6.8  9.4 12.7 31.3 29.3 28.4  38.7 
South Africa 9.2  21.0 15.4 11.8  14.3 14.1 11.0 15.4 8.4 2.8 3.7  4 
Kenya 7.5  5.4 6.9 5.8  5.3 5.2 7.5 1.5 0.3 1.2 0.7  0.7 
Mauritius 1.1  0.9 1.5 4.8  3.6 4.0 4.2 3.0 4.6 2.4 3.6  2.4 
Madagasca r 1.7  1.2 2.0 3.0  1.9 1.8 2.6 0.9 0.9 1.0 1.1  1.4 
Other countries 24.6  21.1 22.7 21.9  24.0 30.8 23.8 47.1 31.3 40.9 39.3  23.8 
Sources: Customs General Directorate and IMF. 
 
185.  As the table above shows, the structure of foreign trade, especially imports, has changed 
considerably. The European Union, which in the past has accounted for 50% of Comoros' imports, 
has seen its share fall significantly since 2000. Even though the proportion has subsequently 
grown slightly, the drop in imports from the European Union has been stable since 2005, at around only 20% and 25% today. 
186.  The change in the structure of foreign trade has been to the benefit of United Arab Emirates, 
whose imports have risen from 8.5% to over 30% to day. South Africa has maintained its status as 
a source of imports to Comoros. However, Kenya's exports to Comoros have collapsed. Most cement imported into Comoros used to come from Kenya and accounted for the lion's share 
of imports from that country. 
187.  The search for competitive prices, especially for raw materials and certain basic products, 
has pushed Comorian importers towards other sources such as Egypt, Indonesia and India, 
which are Comoros' suppliers of cement today. Mauritius has succeeded in increasing its imports 
to Comoros fivefold in less than ten years according to the statistics. 
188.  By contrast, Madagascar's exports to Comoros have fallen following restrictions on the 
export of live zebus under measures passed in 2002. 
189.  The measures benefited Tanzania, the count ry to which importers turned to supply the 
Comorian market with fresh meat through the import of live animals. The establishment of maritime and air links between Tanzania, Ke nya and Comoros contributed to increased trade 
and movement of persons between the countries. Tanzania remains attractive to a category 
of informal trade importers because of geographical proximity and cultural similarities as much WT/ACC/COM/3 
- 31 - 
as for the ease of obtaining an entry visa and visitor's permit at the airport and port 
of Dar es Salaam. 
190.  Another source of imports to Comoros is Brazil. The products concerned are essentially 
frozen poultry and beef. The exporters are French  intermediaries who continue to supply the 
Comorian market through purchases on the Brazilian market. European exporters have been 
forced into this route by the gradual reduction in export refunds from Brussels, a form of subsidy that had broadly sustained European exports of frozen meat to Africa in general. Since this change 
in the EU's Common Agricultural Policy to comply with the European Communities' multilateral 
commitments, the Brazilian market has proved to be  more competitive in terms of the price offer 
for frozen meat to Africa and, Comoros. 
Chart 7: Geographical breakdown of  imports into Comoros, 2009-2011 
0.005.0010.0015.0020.0025.0030.0035.0040.00
Africa Americas Asia Indian  Ocean Caribbean  &
PacificEurope Middle  and
Near EastMarket share (%)
2009
2010
2011
 
Source: Customs General Directorate. 
 
Charts 8 and 8 bis: Structure of exports by group of  products and top five partners 
 
Chart 8: Structure  of exports by group of 
products,  2010
Food products
Raw agricultural  materials
Fuel
Minerals
Manufactures
Chemicals
Machinery  and transport  equipment
Various other manufactures
 
  ‐ 500 1,000 1,500 2,000 2,500 3,000 3,500Chart8 bis: Top 5 partners in millions
of KMF, 2011
Singapore France Madagascar
Netherlands Germany
 
 
 
Source: UNCTAD Handbook of Statistics 2011, Customs General Directorate. 
 WT/ACC/COM/3 
- 32 - 
Chart 9: Geographical breakdown of exports from Comoros, 2009-2011 
 
Source: Customs General Directorate. 
 
191.  The structure of Comorian exports by prod uct and partner has undergone significant change. 
Although the United States consistently absorb ed the bulk of Comorian vanilla exports until 
ten years ago, to the tune of 80% of output, its focus for the products it imported from Comoros 
has gradually moved to other countries. Its share fell dramatically to around only 1% in 2006, 
confirming the general long-term trend. This cont ributed to the emergence of Asia, with Singapore 
ranking highest of Comoros' five export partners  in 2011; according to the BCC data, Singapore is 
the destination of 78.6% of exports, including cloves, reaffirming the number one ranking it has 
held since 2010 over Europe, ranked number two, reflecting the fall in exports of ylang-ylang 
essence, especially to France and the Netherlands.  As part of this change in Comorian exports, 
Netherlands has been more of a platform for re-export than a source of direct users. 
France, however, retains second place and absorb s the bulk of the essential oils exported by 
Comoros. Italy ranks third among the European count ries, with imports of vanilla, ylang and other 
essences. In total, the European Union absorbed up to 64% of Comorian exports but the level has fluctuated between a high of 84% of exports in 2005 and a low of 55% in 2001. By contrast, 
since 2010 exports to Africa and islands in the Indian Ocean have risen, and this area now ranks 
third on the list, whereas exports to the American continent are suffering from the fallout of the crisis affecting Comorian vanilla which is losing market share. 
4.  Domestic trade in services 
192.  The services sector plays a vital role in the Comorian economy, especially tourism and 
related services. Given the importance of foreign capital to development, and in step with other 
countries in the region, the Union of the Comoros has established a new investment regime 
intended to make investing in the country more  equitable, open, transparent and attractive. 
Comoros has a single framework for foreign investment: the Investment Code adopted and enacted in September 2007. 
193.  The efforts made by Comoros in recent years have led to some success in this field: there 
have been transfers of ownership of the esta blishments formerly known as Hôtel Ylang and 
Itsandra, now reopened as Le Moroni, and Itsandra Beach Hôtel, together with a clear rise in their 
classifications to three and four stars. Both sites received investment from two foreign promoters, 
one from France/Madagascar, the other from Kuwait. 
194.  Comoros has considerable attractions for tourism but they are underdeveloped; the absence 
of "Comoros" as a destination among major tour operators is a handicap to the national supply 
of tourist services and vice-versa. Indeed, the accommodation capacity, estimated at 1,026 beds, 
is very low; there are only a few establishments that meet international standards for accommodation and comfort and the annual occupancy rate is below 40%. As one of the 
priority axes of the Growth and Poverty Reductio n Strategy Paper (GPRSP), tourism should have a 
better outlook, especially following the establishment of a major international hotel group with the WT/ACC/COM/3 
- 33 - 
arrival of another pending to take over the operation of the "Galawa" site. The statistics show that 
flows of arrivals at the border have started to rise again following the drop in 2009 resulting from the temporary halt in flights by the airline "Yém énia". Over 50% of customers are Comorians from 
the diaspora, most of whom are resident in Europe, especially France, whereas people on business 
trips or political visits account for 21%; leisure tourists account for only 16%. 
BORDER ARRIVALS BY REASON FOR VISIT 
REASON 2008  2009  2010  2011  
Leisure  2,800 2,612 2,373 3,965 
Business 4,194 2,963 3,251 3,501 
Family visit 6,297 4,478 7,990 9,537 
Other 1,462 1,343 1,637 1,762 
TOTAL  14,753  11,396  15,251  18,765  
Source: National Tourism and Accommodation Directorate. 
 
195.  The supply of banking services cont inues to improve, and the greater openness 
to competition is signalled by the establishment of the banks Exim Bank as a Tanzanian subsidiary 
of an Indian firm with a presence in East Africa, and the Banque Fédérale du Commerce , 
owned by Kuwaiti private interests. 
196.  The Central Bank of Comoros, the successor to the Comoros Establishment of Issue, 
Institute, was established on 1 July 1981. It is  managed by an Executive Board on which France 
sits as part of the arrangement for it to provide an unlimited guarantee for the currency issued by the BCC. Law 80-09 and the BCC statutes confer upon the Board the role and fundamental 
duties inherent in the BCC's status as a central bank and body of issue alongside other ancillary 
duties of general concern. 
197.  The State used to exercise a very limited, non-competitive degree of direct and indirect 
control over the financial sector until very recently (in the 2000s) through the country's 
main commercial bank, the Banque pour l'Industrie et le Commerce  (BIC) (Bank of Industry 
and Commerce) in which the State still has a 33% shareholding and the local private sector 16%. 
The State has a 50% shareholding in the country's second-largest bank, 
the Banque de Développement des Comore s ((BDC) (Bank of Development of Comoros), whereas 
the BCC, the European Investment Bank and the French Development Agency hold the remaining 50%. 
198.  The financial sector has developed considerably since 1993. Indeed, under Laws 80-07 
and 80-08 and Decree 04-069/PR on the regulation  and control of Banks, Decentralized Financial 
Institutions (IFD) and Other Financial Establishments, the duty of the BCC is to regulate and 
oversee banking and financial activity on the national territory. At 31 December 2010, in 
conformity with instruction No. 004/2004/COB on the categorization of banks and financial establishments, the Comorian bankin g and financial system comprised: 
i. Four banks: 
- the Banque de Développement des Comores  (BDC); 
- the Banque pour l'Industrie et le Commerce  (BIC-Comores); 
- Exim Bank – Comores, a local subsidiary of Exim Bank Limited (Tanzania); 
- the Banque Fédérale du Commerce  (BFC Comores) (Federal Trade Bank). 
 ii. Two non-profit-making decentralized financial institutions (IFD): 
- the Union des Mutuelles d'Epargne et de Crédit ya Komor  (MECK), (12 affiliated 
Meck networks); 
- the Union régionale des Sanduk d'Anjouan  (32 affiliated branches). 
 
iii. Five financial intermediaries (IF): 
- the National Postal and Financial Services Company (SNPSF); 
- the Société Comores Express  (money transfer); 
- Money Gramm (money transfer); 
- Western Union (money transfer); - the Maison Comorienne des Transferts et des Valeurs  (MCTV-SA). WT/ACC/COM/3 
- 34 - 
 
199.  All these financial establishments are subject to ongoing controls, especially the requirement to make a monthly financial statement purs uant to Letter-Circular No. 04/2008/COB. 
200.  The first concession to a private operator has been awarded in the Telecommunications 
services sector, thereby opening up to competition a sector that had previously been broadly 
dominated by the main public company, Comores Télécom . Following a failure by the new operator 
to comply with the specifications, the State revoked the concession. 
201.  The other services subsector is the trade in electricity services, which is still the subject 
of a State monopoly. A farm-out arrangement with a company established under Comorian law, Eau et Électricité des Comores  (EEDC), a subsidiary of the French multinational Vivendi , ended in 
failure, forcing the authorities to resume control of the service in the name of the public-service 
mission incumbent upon all States. No private promoter has applied for the concession because 
of ongoing problems in this subsector. 
202.  The World Bank, which supplied privatizat ion support services through its specialist 
subsidiary the IFC, did not include MAMWE, the main public company in the subsector, 
in its programme of services. 
203.  By contrast, the State revoked the port handling service contracts that were initially awarded 
to a local subsidiary of the French Group Mer Australe , and then to Gulfcom Company Limited , 
a subsidiary established under Comorian law of a consortium from the Gulf between Groupe 
Gulftainer  and Al Marwan Contractors on the grounds of failure to comply with the specifications. 
Since 2012 the Bolloré Group has held the concessi on through its specialist subsidiary Bolloré 
Logistics. 
204.  The domestic trade in services is otherwise dominated by rapidly expanding trade in imports 
and distribution driven by low domestic supply capacity. 
205.  Activity in this sector relates to both the commercialization and distribution of food 
and market garden produce from local farms. It provides substantial income to a chain of local retailers, mainly women, and has developed over re cent years as part of efforts by professionals 
to provide a structure in the sector in the form of a National Union of Farmers of Comoros, 
a National Federation of Farmers of Comoros – Women Farmers and a Young Farmers' Association which provide training services to members and sales opportunities through points of sale supported by French cooperation efforts, the ILO/UNDP and IFAD. 
5.  Information on financial movement s related to nationals working abroad, 
remittances, etc. 
206.  Migrants' remittances are a significant and growing source of income and capital for several 
developing countries. In Comoros, they are the main source of external finance and account for 
around 23.2% of GDP. The remittances, which originate essentially from the Comorian community resident in France, are on an upward trend and rose from over 15 billion in 2003, to more than 
double that figure in 2005 and neared KMF 50 billion in 2008 according to data from the BCC. 
Informal networks are the most commonly used means of transfer, with visitors to Comoros acting as intermediaries. 
207.  Locally, a significant proportion of the transfers is channelled by financial establishments 
through manual exchange transactions at banks, while the remainder is hoarded and most often 
enters informal trade. The estimated value of euro notes, both hoarded and in circulation, 
is KMF 6 billion (or €12 million). 
208.  The preference for the inform al channel can be explained by: 
- the origin of the funds, associated with the traditional practice of tontines; 
- the relatively high cost of transfers through formal channels; 
- the poor access to banking services, accentuated by the narrow banking system 
and financial establishments' very limited geographical coverage; 
- the lack of knowledge about tr ansfer mechanisms and pathways; 
- the high number of low value remittances of between €50 and €200. WT/ACC/COM/3 
- 35 - 
 
209.  The remittances are the main source of inco me for many families, and are most often used 
to pay electricity or telephone bills or school fees. Large remittances are essentially a pool of subscriptions paid by people from the same village for village associations to fund social 
activities, build community schools, dispensaries, libraries, sports centre facilities, single family 
homes or just to fund the "grand mariage". So these resources principally fund household expenditure and community investment and are only associated to a lesser degree with savings 
and productive investment. 
210.  Remittances via formal pathways are essentially channelled by fund transfer companies 
and only a fairly small amount is channelled th rough the banks. In 2005 the amount of transfers 
through the formal pathway was KMF 7.3 billion compared to KMF 6.4 billion in 2004 
and KMF 5.2 billion in 2003. According to the UNCT AD Handbook of Statistics (2012) that figure 
was US$12 million in 2011. 
211.  The short-term outlook for expansion of the banking system, including the establishment 
of new commercial banks, the authorization of new fund transfer companies and the effective 
integration of the first micro-finance network into the banking environment are likely to encourage transfers through formal financial channels. 
212.  The proper integration of the first micro-finance network into the banking system contributed 
to the number of accounts opened by non-reside nt Comorians and helped to increase transfers 
because: 
- the geographical coverage of micro-finance networks is high; 
- accounts can be credited from abroad. 
213.  Initiatives to encourage and develop a partnership between networks of microfinance 
institutions and French non-profit-making bodies are under way with a view to better organization 
of the pathways, reduced transfer costs and accust oming migrants to use the formal route because 
of the ubiquitous nature of branches in French te rritory. In addition to the advice it can provide, 
the Central Bank can participate in the channels through the accounts of microfinance institutions 
that it has on its books, enabling it to consolidate foreign assets and restrict the hoarding and 
circulation of euro notes. 
214.  In terms of outlook, development finance from this source, supporting families who have 
remained in the country, runs the risk of drying up over time. Another factor is the deterioration 
in the world economic situation caused by the considerable slowdown in growth and the rise 
in unemployment abroad among the older generation of migrants nearing retirement. Furthermore, the second-generation migrants do not appear to have their parents' reflexes 
towards their country of origin because they are more integrated, and are likely to be less and less 
inclined to send remittances. 
215.  In 2008 the AfDB conducted a study on the im pact of migrant workers' remittances on the 
African economy. Remittances from nationals of four African countries, Morocco, Comoros, Senegal 
and Mali, were the focus of the study. In the report, the AfDB notes "the social, economic and financial importance of migrant remittances in recipient countries", which represent between 9% and 24% of GDP, i.e. between 80% and 750% of the development assistance received by such 
countries. Remittances via informal channels are still very important, accounting for between 25% 
and 80% of the total, depending on the country concerned. 
216.  The impact of remittances from the very large Comorian diaspora is very significant 
(the number of Comorians and persons of Comorian origin abroad is equivalent to 50% 
of the de jure  population), to the point that the diaspora is recognized as a 5
th island in the 
archipelago. It is both a genuine, recognized and influential social, economic and political force. 
217.  There are around 200,000 expatriate Comorians in metropolitan France when counted 
individually or as members of the considerable numbers of associations of varying levels of formality (based on membership of a village community), and they remit the equivalent of 20% 
of GDP annually; in 2011 this equated to the Stat e budget and 50% of the balance of payments. WT/ACC/COM/3 
- 36 - 
218.  This situation affects Grande Comore in particular (90%). The bulk of remittances is used as 
income and emergency support for families who are often called on to subsidize a migrant's departure as part of a wider strategy. Another sign ificant share is to fund traditional ceremonies, 
principally the "Grand Mariage", a genuine vehicle for social mobility for an individual and all his or 
her relatives. The remaining share is used to build dwellings (a long and difficult process because 
of the lack of long-term credit) and in productive activities that are difficult to manage from abroad. 
219.  Alongside this support for consumption that helps to increase the trade balance deficit, 
migrants' associations pay to finance social investments (dispensaries, schools, water or electricity supplies, rural roads) demanded by the grass roots communities who have identified a need for them and subsequently bring them into being. 
220.  Moreover, aid to households generates help that is not of the kind conducive to actively 
trying to find a productive activity that generates income and savings to cover emergencies. 
221.  The effect on household savings is low, including on micro-finance deposits. Western Union 
has an exclusive agreement with the SNPSF, a public sector finance establishment whose role is to 
develop a dynamic savings policy and act as a conduit for around 25% of remittances; 65% of remittances are made in notes through friends or relatives. The remainder is channelled through 
the banks. To a certain extent this availability also explains why at present the demand for credit 
has been satisfied and is only moderate in level. 
Table 8: Changes in migrants' re mittances, 1987-2011 (US$ million) 
1987 1988 1999 2000 2001 2002  2003  2004  2005  2006  2007  2008 2009 2010 2011  
7 7 8 10  10 16 16  15 12 12 12 12 12 12 12  
Sources: Migration and Remittances Factbook 2008, World Bank, UNCTAD Handbook of Statistics 2012. 
 
222.  The data supplied through the World Bank Factbook sets out the remittances recorded 
by official channels. There is no dispute however that the real volume of remittances is very high 
if undeclared remittances are taken into account. In respect of Comoros, that reality is confirmed 
by data from the exchange office of the BCC, which ended with a relatively high inflow through all channels at its windows, even if a significant proportion was hoarded (data and information for the 
box below supplied by the BCC). 
- Migrants' remittances 
 223.  Migrants' remittances are a significant and growing source of income and capital for several 
developing countries. In Comoros they are the main source of external funding, accounting 
for around 15% of GDP. The remittances, mainly from the Comorian community resident in France, were estimated at KMF 20 billion in 2005. Informal networks are the most commonly 
used means of transfer, with visitors to Comoros acting as intermediaries. 
224.  Locally, a significant proportion of the transfers is channelled by financial establishments 
through manual exchange transactions at banks, while the remainder is hoarded and most often 
enters informal trade. The value of hoarded euro notes in circulation is estimated at KMF 6 billion. 
225.  The preference for using informal channels to send remittances can be explained by: 
• the origin of the funds, associated with the traditional practice of tontines; 
• the relatively high cost of transfers through formal channels; 
• the poor access to banking services, accentuated by the narrow banking system 
and financial establishments' very limited geographical coverage; 
• the lack of knowledge about transfer mechanisms and pathways; 
• the high number of low-value remittances of between €50 and €200. 
 226.  The remittances are the main source of inco me for many families, and are most often used 
to pay and electricity or telephone bill or school fees. Large remittances are essentially a pool 
of subscriptions paid by people from the same village for village associations to fund social activities, (building community schools, dispensaries, libraries or sports centre facilities). They may also be used to construct single family homes or just to fund the " grand mariage ". So these WT/ACC/COM/3 
- 37 - 
resources principally fund household expenditure and community investment and are only 
associated to a lesser degree with savings and productive investment. 
227.  Remittances via formal pathways are essent ially conducted by fund transfer companies and 
only a fairly small amount is channelled thro ugh the banks. In 2005 the amount of transfers 
through the formal pathway was KMF 7.3 billion compared to KMF 6.4 billion in 2004 
and KMF 5.2 billion in 2003. 
228.  The short term outlook for expansion of th e banking system, including the establishment of 
new commercial banks, the authorization of new fund transfer companies and the effective 
integration of the first micro-finance network into the banking environment are such as to encourage transfers through formal financial channels. 
229.  The actual integration of the first micro-fi nance network into the banking system contributed 
to accounts opened by non-resident Comorians and helps to increase transfers because: 
- the geographical coverage of micro-finance networks is high 
- accounts can be credited from abroad. 
 
230.  Initiatives to encourage and develop a pa rtnership between networks of micro-finance 
institutions and French non-profit-making bodies are under way with a view to better organization 
of the pathways, reduced transfer costs and accust oming migrants to use the formal route because 
of the ubiquitous nature of offices in French territo ry. In addition to the advice it can provide, the 
Central Bank can participate in the channels through the microfinance institutions' accounts on its books, enabling it to consolidate foreign assets, re strict hoarding and the circulation of euro notes. 
Table 9: Purchases by the Central Bank of  euro notes and remittances through banks 
and accredited intermediaries 
 KMF million 
 2003 2004 2005 
Central Bank 10.9 16.3 18.3 
Banks, Transfer agencies  5.2 6.4 7.3 
Source: Central Bank of Comoros. 
 
6.  Information on growth in trade in goods and services over recent years and forecasts 
for years to come 
231.  Growth in trade in goods and services would appear to be sustainable and to favour Asia and 
the Middle East. Where intra-regional trade is concerned, the change in trade since 2007 has 
focused Comorian importers on other sources, seeking better competitiveness/prices, to address the spike in prices for this raw material. Following a significant decline in exports from Madagascar 
to Comoros, mainly of live animals for slaughter, has undergone a considerable revival. 
232.  Trade between South Africa and Comoros has remained stable. The absence of a direct link 
with this traditional trading partner would appear to have restrained any growth in volume. 
The search for a fairly close, less costly source of supply has redirected flows of certain imports 
from Mauritius. The absence of a direct air link and difficulties in maritime routes affect a flow in trade that could have shown sustained growth for Mauritius. 
233.  China, whose products were mainly from the United Arab Emirates, is also using Comoros as 
a result of redirecting/diversifying its sources of supply in search of more competitive prices. The same can be said of Brazil in respect of imports of meat from South America following the dismantling of the export refunds mechanism (an ex port subsidy) that had been in place in the 
European Union for a long time as a support measure for exports of agricultural origin. 
234.  Information on the growth in trade in goods and services by economic zone appears in the 
table above. It illustrates the key change in Como ros' structure of trade with the world, namely 
a renewed focus on Asia to the detriment of the European Union which used to account for 53% 
of Comoros' imports compared to less than half currently. WT/ACC/COM/3 
- 38 - 
235.  Comorian exports, including vanilla, previously focused on the United States, France and 
Germany, show a clear trend towards the European market. Targeting a quality focused segment and facing stiff competition from Madagascar, Indonesia and others, vanilla has carved itself a European niche (Netherlands, France and German y) but the quantities exported have collapsed 
from 250 tonnes in the 1980s to less than 50 tonnes today. Comoros has lost the US market, 
where demand is huge. The United States used to absorb up to 80% of exports of vanilla from Comoros. Its share has fallen to 1% today. 
236.  The fact remains that the dynamics of trade growth are heavily dependent on diversification 
of products, export stimulation and the adoption of an appropriate trade policy that indirectly facilitates trade. With regard to Comoros, the straightforward process for issuing an entry and residence visa for business together with competitiveness costs of passenger transport, efficient 
intermediation in respect of carriage of goods, have  been determining factors at each stage. In an 
environment where there is stiff international competition and rising tensions that affect prices the consequence is an ongoing search for the best price, encouraging open trade practices and new 
horizons. 
237.  The Union of the Comoros has recently been declared eligible for duty free access to the 
United States market under the United States African Growth and Opportunity Act (AGOA), 
a factor that should further stimulate Comorian exports by encouraging diversification of the 
export base to take advantage of the creati on of new market opportunities. The accession 
of Comoros to the World Trade Organization should enable the country to benefit from access to Members' markets free of quotas and duties pursuant to the relevant provisions of the 
multilateral framework on LDCs and small, vulnerable island economies. 
238.  Comoros' external trade in goods and services bear the stamp of falling exports. 
The available data reveal this to be a long-term trend. Stiff international competition in the 
country's key products is one factor in the fall in volume and value. The revival, essentially in the 
value of exports, particularly between 2004 and 2007 benefited from the contraction of competitors' supplies because of fires and cyclones. In 2011 by contrast, the revival was 
attributable in essence to the increase in the expo rt price of cloves despite a 27.5% fall in volume. 
239.  When the competitor countries regained th eir original position, the value of Comorian 
exports fell, confirming the overall long-term tren d of the falling competitiveness of the country's 
principal export products, namely vanilla and cloves. 
240.  However, the Union of the Comoros has a comparative advantage in terms of the quality 
of its products and know-how in preparing them for export. Not to mention its rich volcanic soil. 
241.  Confident in these comparative advantages, the country needs a bolder stance to revive 
exports in the quest for competitiveness in a segment where market practices have become 
increasingly open since the 1990s. The alternativ e is to undertake an outward looking strategy 
to produce other goods and services targeting the most traditional external markets, including the 
regional COMESA market which has a population of more than 400 million people. 
242.  Other available routes are the American market with the benefits under the AGOA initiative 
in 2008, the European Union with the Everything But Arms initiative and the Economic Partnership Agreement. Membership of other shared economic areas encompassing other countries such as the 
League of Arab States and the Islamic Conferen ce and, to a lesser extent, the Indian Ocean 
Commission, also present opportunities to support growth in exports of goods and services. 
243.  Imports of goods and services have remained  steady with average growth of 7% per year. 
The sustained growth in imports of goods and servic es is the economic response to weak domestic 
production in the face of domestic demand bu oyed by the dynamics of a rise in population 
of 2.7% annually. 
244.  Over the single period of observation from 2007 to 2011, imports of goods and services grew 
by 103% from 138 to 280 million dollars. 
245.  The Government of the Union of the Comoro s has expressed the wish that accession to the 
World Trade Organization will stimulate and accelerate export growth in the future. From that WT/ACC/COM/3 
- 39 - 
point of view, anchoring the Comorian franc in the euro area provides an anchor for 
macroeconomic stability, attracting certain investors who may become established in the country and make it a base for products for export, but is also a disadvantage because of the fixed parity system, which does not provide all the flexibility needed to strike a better balance between 
competitiveness and exchange rates. 
246.  The fact remains that as a net importer of goods and services, fixed parity between the 
Comorian franc and the euro helps to assuage/alleviate the effects of downturns in the 
international market, sheltering the small, vulnerable island economy from powerful exogenous 
shocks. 
III.   FRAMEWORK FOR MAKING AND EN FORCING POLICIES AFFECTING FOREIGN 
TRADE IN GOODS AND TRADE IN SERVICES 
1.  Powers of executive, legislative and judicial branches of government 
247.  The Constitution of the Union of the Co moros was enacted on 23 December 2001, and a 
revised version was approved by referendum on 17 May 2009 and entered into force on 23 May 
under Decree No. 09-066/PR of 23 May 2009. The aim of the review is to endow the Comoros' new 
institutional architecture, the product of a lengthy national reconciliation process, with greater stability, and lessen the tensions between the various power authorities as demonstrated in 
practice since 2001. 
248.  The supreme authorities are the President of the Union of the Comoros, the National 
Assembly, the government and the courts. The former presidents of the autonomous islands elected by universal suffrage by their respective island's citizens become governors elected by 
universal suffrage. The island assemblies have become island councils with deliberative powers 
among their scope of action, which is reduced from  those of regional authorities. Article 9 as 
revised sets out the islands' scope of action in the following areas: 
- Administration of local authorities; 
- Organization of administrative, commercial or industrial establishments and bodies of 
interest to the island other than State companies; 
- Urban and rural police; 
- Fairs and markets; - Study allowances and island grants; - Road networks; 
- Development of secondary routes; 
- Island land development; - Construction, equipment, maintenance and management of teaching establishments and 
staff, at pre-school, primary and secondary levels; 
- Basic local vocational training; - Small-scale fishing; 
- Agriculture and livestock farming excluding strategies and research; 
- Construction, equipment, maintenance and management of basic healthcare 
establishments and staff. 
 
Areas other than those referred to in Article 9(1) of the constitution are the responsibility of the 
Union.  
249.  The Constitution provides for the separation of political powers. The President of the Union is 
the President of the Republic, Head of State and of Government; he is elected by popular suffrage 
following a vote between the islands of the Union fo r a four-year term of office on a ticket that 
includes three vice-presidents, one for each other island; the president and vice presidents are 
invested by the Constitutional Court and swear an oath before it; their term of office is non-renewable and they can be re-elected once only. 
250.  Legislative power is exercised by the unicameral National Assembly of 33 members elected 
for a five-year term. The texts of laws approved by the National Assembly are brought before the 
President of the Union who may enact them or retu rn them to the Assembly for a second reading. 
The texts returned by the President of the Union must be approved by the National Assembly by WT/ACC/COM/3 
- 40 - 
a vote with a two-thirds majority for constitutional matters or by a simple majority for other 
matters before having the force of law. 
251.  Relations between the legislative and regu latory authorities are the subject of the new 
Title IV introduced in the recent constitutional review. The new title provides as follows: 
"In addition to the areas within the remit of the National Assembly pursuant to other articles of the 
Constitution, the law of the Union lays down rules on:  
- Civil rights and fundamental guarantees co nferred on citizens to exercise public 
freedoms; the constraints upon the person of citizens and on their property; 
- The system governing political associations and parties and the status of the opposition; - The nationality, status and capacity of persons, family law, succession and gifts; 
- The determination of crimes and offences and the penalties that apply to them; criminal 
procedure; amnesty; the creation of new types of court; 
- Labour law, trade union law, social security and protection law; 
- The tax base, the rate and means of collection of taxes of all kinds; the currency 
production system. 
 
The law also determines the rules relating to: 
 
- The Customs Service Administration; - The management of State-owned property and the land register; 
- The management of State-owned companies; 
- The system of property ownership; rights  in rem and civil and commercial obligations; 
- The system of election to the Assembly of the Union; 
- The creation of categories of public legal entities; 
- The staff regulations for government employees and members of the military and the 
safeguards afforded to them; 
- The nationalization of businesses and tran sfers to the private sector of property 
belonging to public sector companies; 
- Expropriations on grounds of public interest; - The law shall lay down the fundamental principles governing: 
- the general organization of defence and national security; 
- the general organization of administrative, social and financial inspections; - education and national public qualifications; 
- information and new information technologies". 
 The judicial system of the Union of the Comoros comprises the following bodies: 
 
- The Common Court of Justice and Arbitration (CCJA) of the Organization for the 
Harmonization of African Business Law (OHADA) Sitting in Abidjan, the CCJA is the highest commercial court of the States Parties to the OHADA of which Comoros was 
a founding member in 1993. It is the court of final instance, acting as a supreme court 
for all the commercial courts of the member countries. It also intervenes in matters of arbitration in cases where the parties to a dispute have directly appointed it as the 
arbitration centre; 
- the Supreme Court of Justice comprising a cassation chamber and an audit chamber; - the constitutional court; 
- the court of appeal of Comoros; 
- the three courts of first instance - one for each island: Moroni, Mutsamudu and Fomboni; 
 
a. magistrates courts; 
b. labour courts. 
 252.  Other courts may be established under law, for example arbitration bodies and 
dispute-settlement bodies with smaller territorial jurisdictions than other courts. One such example 
is the Court of Arbitration and Mediation of Comoros (CACOM), a commercial arbitration court established in 2011 in operation since February 2013. 
The courts in Comoros are governed under Law No. 87-021 of 23 September 1987 establishing 
"the organization of the courts […] and the fund amental principles applicable to disputes […]" WT/ACC/COM/3 
- 41 - 
and the Law of 30 December 1992 on the operatio n of courts in Comoros with the exception 
of Kadhis courts.  253.  The President of the Supreme Court of Just ice is appointed from among the Supreme Court 
judges by the President of the Union after consultation with the Judicial Service Commission. 
254.  The Supreme Court is the highest court in the Union in judicial, administrative and auditing 
matters in the Union and the Islands. Its decisions are not subject to any appeal and are binding 
on the executive, legislature and all courts in the territory of the Union. 
255.  The Constitutional Court  rules on the constitutionality of the laws of the Union and Islands in 
accordance with Article 31 of the Constitution of the Union. It monitors the regularity of electoral procedures both in the Islands at Union level, including referendums. It is the jurisdictional 
authority on electoral matters. It is the guaranto r of fundamental human rights and civil liberties. 
The Constitutional Court is the guarantor of th e division of competences between the Union and 
the Islands. It is responsible for ruling on conf licts of jurisdiction between two or more Union 
bodies, between the Union and the Island s, and between the Islands themselves. 
256.  The system comprises courts of first instance, one for each of the islands in the Union, and 
the Supreme Court of Justice is the court of last resort. The courts of first instance are divided into 
chambers, including a commercial chamber. 
257.  The Supreme Court of Justice, the Constituti onal Court and the Court of Appeal sit in the 
capital, Moroni and have jurisdiction over all the national territory. 
258.  The Law provides for the possibility of mobile hearings for courts of first instance to bring 
justice closer to the people in certain matters. 
259.  The matters ruled on by the courts of first instance may be appealed to the Court of Appeal 
of Comoros and the Cassation Chamber at the Cour t of Justice of the OHADA, in that order. 
260.  The Union of the Comoros has a law on commercial arbitration (the OHADA Uniform Act on 
Arbitration) and procedural texts on the recognition and enforcement of Comorian and foreign arbitral awards. Additionally, a Court of Arbitr ation and Mediation (CACOM) has been operational 
since February 2013. 
261.  The aim is to provide a framework for the resolution of certain conflicts which are outside the 
overloaded criminal justice system while offering a pragmatic, less costly, rapid and independent approach through mediation or arbitration as agreed by the parties with a panel of mediators or 
arbiters that they accept. WT/ACC/COM/3 
- 42 - 
Figure 1: Judicial system of Comoros 
 
 
262.  In Comoros, the judiciary is independent of the legislature and the executive in accordance 
with Article 29 of the Constitution of the Union. In the performance of their duties, judges are subject only to the authority of the law. Trial judges cannot be removed. The President of the 
Union is the guarantor of the independence of the ju diciary. He is assisted by the Judicial Service 
Commission. 
2.  Government entities responsible for making and implementing policies affecting 
foreign trade 
263.  Trade policy matters are the responsibility of  the Ministry of the Economy and Trade, which 
is responsible for coordinating with the other Ministries with responsibility for trade-related matters, namely: 
- Ministry of Finance and the Budget; 
- Ministry of Transport and Tourism; - Ministry of Land Development and Equipment; 
- Ministry of Health; 
- Ministry of Justice; - Ministry of the Interior; 
- Ministry of Agriculture, Fisheries and the Environment; 
- Ministry of National Education; and - Ministry of External Relations and Cooperation with responsibility for the Arab World, 
the Francophonie and the Diaspora. 
 Supreme Court of Justice 
Competence in judicial, 
administrative and auditing 
matters, reviews through a 
cassational procedure the 
decisions of lower courts CCJA at Abidjan 
Court of Cassation 
in commercial litigation Constitutional Court 
Competence 
in constitutional 
matters 
Court of Appeal of Comoros  
Reviews on appeal the decisions 
of the courts of justice of first 
instance. Enforces or annuls 
arbitral awards 
Courts of First 
Instance  
Moroni, 
Mutsamudu, 
Fomboni Magistrates' 
Courts  
Hear and rule 
on matters 
involving under 
KMF 3 million Court of 
Arbitration of 
Comoros  
Arbitration and 
mediation in 
commercial 
disputes (Moroni, 
Mutsamudu, 
Fomboni ) Other courts  
Hear and rule 
on other matters 
specially 
delegated to 
them WT/ACC/COM/3 
- 43 - 
264.  In formulating trade policy and to help the authorities in all trade negotiations the 
government has established a multisectoral framework, the National Forum on Trade Policy Development (FNDPC). It comprises representatives of all the ministries with an interest in the 
subject-matter under discussion, the principal econ omic sectors through their socio-professional 
organizations and representatives of development partners with a resident mission in the capital. 
265.  The Government also solicits the views, as the case may be, of industry associations, the 
Chambers of Commerce, and the private sector, and local island communities. In the light of this 
framework of study and consultation with stakeholders, it is then the job of the Council of Ministers 
to formulate trade policy, provide guidance and adopt negotiating positions in regional and multilateral trade negotiations. 
266.  As part of a funding package to provide a technical assistance programme funded by the 
European Union and administered by the COMESA Secretariat, a decision was taken to study 
certain specific subjects related to the impact of the EPA and WTO commitments. 
267.  The aim was to improve the formulation of reform programmes in the areas of study such as 
taxation, national capacity buil ding and expertise, and adjustments to the legal and regulatory 
framework. The plan envisages requesting the assi stance of other development partners in order 
to have complete study documents upon which to base effective public policy on trade policy 
matters. 
268.  The Government would like to have the assistance of development partners to provide the 
FNDPC with adequate means to fulfil its mandate and mission as a single intersectoral consultation and study group on trade matters. 
269.  In addition to its own operations, the forum should be able to launch studies upon which to 
base the opinions and suggestions that it provides  to the ultimate decision makers. The FNDPC has 
a specialist group on WTO matters, the Integrated Framework and the Aid-for-Trade programme. 
This theme group, one of whose focal points is the WTO, will: 
(1) formulate trade policy initiatives and draw up the Forum's recommendations for the 
Council of Ministers; 
(2) coordinate the implementation of trade policy decisions made by the Council 
of Ministers; 
(3) act as coordinator on WTO matters in close cooperation with the National Working 
Party on WTO Accession, for example by supplying in due time replies to the questions 
raised by the Working Party on the Accession of Comoros at the WTO; 
(4) prepare notifications to the WTO; and (5) perform such duties in relation to the WTO as deemed necessary by the Government. 
 
3.  Division of authority between central and sub-central governments 
270.  The system of government of the Union of th e Comoros is a unitary presidential system with 
a federal basis. The Islands are established as autonomous regional authority units which govern 
themselves freely within the framework of the stat utory laws adopted by them in conformity with 
the fundamental principles of the Constitution of the Union. The island authorities formed by each 
of the islands in the Union of the Comoros have other intra-island sub-authorities, namely regional 
and communal authorities. 
271.  The central government has competence in political, legislative and administrative matters 
of national scope, external relations, exercises all sovereign powers and fulfils the public service 
missions incumbent upon the sole depository of na tional sovereignty. The island authorities are 
answerable to an elected governor who is assisted in his duties by an executive body of ministers. 
272.  The islands also have a directly elected deliberative council authorized under the Constitution 
to deliberate only on the matters devolved upon it under the Constitution provided that the 
regulations in question are not incompatible with the Constitution or with the laws and regulations enacted by higher authorities. WT/ACC/COM/3 
- 44 - 
273.  The Ministry of the Interior oversees the regi onal authorities. In the light of the experience 
following the constitution of 23 December 2001, in particular the tensions between the various levels of government, a new title was incorporated into the newly amended version of the Constitution enshrining a framework of regular consultations between the President of the Union, 
the Governors and the President of the National Assembly. 
4.  Any legislative programmes or pl ans to change the regulatory regime 
274.  The Government's economic liberalization reform programme and the WTO accession 
process necessitate the drafting and/or modifi cation of existing laws and regulations. 
Against that background the Law on competition and prices has been put before the Assembly of 
the Union for adoption.  
275.  The following regulatory provisions are in preparation pursuant to new laws whereas others 
may be adopted as part of a procedure to repeal existing older texts or review/amend regulations 
currently in force: 
- Decree establishing the OHADA National Commission (CNO); 
- Order establishing the Court of Arbitration of Comoros (CACOM). 
 
276.  Further details on proposed legislative or regulatory changes have been provided in the 
appropriate sections of this Memorandum. 
5.  Laws and legal instruments 277.  All laws and legal instruments are published in the Official Journal of the Union of the 
Comoros. 
6.  Description of judicial, arbitral or  administrative bodies or procedures 
278.  In Comoros the settlement of disputes is a matter for the courts and the Public Prosecutor 
represents the State, brings criminal proceedings and defends democratic rule of law, 
citizens' rights, the public interest and all other interests that fall within his jurisdiction by virtue of the Constitution or the law. As part of the Judicial Service Commission, the legal profession 
is authorized to participate, autonomously and in conformity with the law, in the implementation 
of criminal policy defined by policy-makers (see Ar ticle of the Constitution on the Judicial Service 
Commission). 
279.  In line with the new Constitution of the Union of the Comoros of 2001, a law on the 
organization of the courts was enacted in 2005 establishing a Supreme Federal Court, 
Courts of Appeal, and Courts of First instance on each island in the Union, and specialist courts (labour, commercial, administrative courts, etc.). 
280.  In the same year a new law set out the status of the judiciary. It is based on the universally 
recognized principles for the proper administration  of justice and the independence of the judiciary 
(judges cannot be removed, establishment of a Judicial Service Commission). The new 
Code of Civil Procedure adopted under Ordinance No. 01-016 CE was adopted in 2004 by means 
of a law. It provides for the court of cassation, arbitration and informal procedures. 
281.  Comoros is a party to the MIGA and the IDRC under the guarantees and securities to foreign 
investors and the Government of the Union of the Comoros set out in the MIGA-backed IDRC. 
282.  The Supreme Court and the Court of Cassation have been set up to ensure a fair trial. 
In terms of investment and business law, delays the formation of case law and the uniform application of the rules of law. A single court of appeal sitting in the capital has been established 
and rules in appeals. This situation is the result of non-specialization of judges; the same judges 
oversee the operation of specialist chambers (administrative, civil, criminal, commercial and social). There is a similar situation in the courts of first instance. WT/ACC/COM/3 
- 45 - 
283.  The situation is noteworthy both for the positive developments in the legal framework 
in Comoros and for the shortcomings, especially in terms of training, diversity of countries where officials are trained and the absence of specialization. 
284.  The shortcomings are reflected in a patent lack of consistency. The Ministry of Justice 
is planning a further reorganization of the judici al machinery, capacity building, specialization 
of judges and a recruitment policy based on a more rational cooperation. 
285.  The authorities of the Union of the Comoro s, buoyed by their voluntarism and commitments 
to proceed with reforms and joining the multilat eral trade framework administered by the WTO 
request technical assistance to bring the judicial apparatus into line, aware that this is the way to integrate the country into the world economy and attract flows of foreign direct investment. 
IV.  POLICIES AFFECTING TRADE IN GOODS 
1.  Import regulations 
(a)  Registration requirements  for engaging in importing 
286.  Comorian law requires all businesses engaging in import operations to register with the 
business taxation service and obtain a tax identification number (NIF), a pre-requisite for the 
customs clearance procedure for goods. 
287.  Pre-requisites for the importation of superior quality rice are for importers to pay an annual 
duty of KMF 2 million to the General Tax and Property Administration (AGID). 
288.  The AGID levies a special activity licence fee on the importation of alcoholic beverages on an 
annual basis of KMF 1 million, KMF 750,000 for distributors and KMF 500,000 for bars and 
restaurants. 
289.  The Trade and Personal Property Credit Regi ster (RCCM) is held by the registrar of each 
court of first instance ruling in trade-related ma tters, supervised by the president or a judge 
assigned to that role. 
290.  Since 2012, Administrative Procedure Centres for Businesses (CFAE) streamlining the 
procedure for business start-up within a single window have been set up in Chambers of Commerce, Industry and Agriculture and at the National Investment Promotion Agency (ANPI). 
As a result a business can now be set up in the Union of the Comoros in under 72 hours. 
291.  Currently, all traders currently must hold  a professional card issued to him by the 
Ministries of Finance of the autonomous islands. 
292.  There is free access to membership of ch ambers of commerce under the 1995 law on the 
statutes of the Union of the Chambers of Commerce, Industry and Agriculture (UCCIA). 
293.  Operating authorizations are issued by the ministerial department relevant to the regulated 
activity, including: 
• Education; 
• Health; • Fisheries for foreign investors; 
• Hotels and catering; 
• Hydrocarbons; • Banking. 
 
294.  Once the competent authorities have issued the authorizations, the holders may engage in 
their activities in their respective fields. Wh ere an authorization is issued to a commercial 
business, the operator may engage in activity as an importer. WT/ACC/COM/3 
- 46 - 
(b)  Characteristics of the national tariff 
295.  The import regime in force in the Union of the Comoros has undergone significant 
liberalization since the 1990s and continues to develop. Previously, imports were subject to compulsory prior registration requirements, quantitative restrictions, as well as multiple taxes and 
rates of duties, which for the most part were very high. Since the beginning of the 1990s, the 
Union of the Comoros has lifted all quantitative restrictions on imports under the structural adjustment programme signed with the IMF. 
296.  It was also during that period, as part of the structural adjustment programmes (PAS) 
supported by the World Bank and the IMF, that the country conducted genuine reform of customs 
tariffs. As a result the number of tariff rates has gradually fallen. 
297.  The aim of the reform was to mobilize fiscal revenue: social products are therefore subject to 
lower duties than "economic" products, which in turn are subject to lower duties than "fiscal" 
products. 
298.  The tariff is essentially defined by the chapte rs of the harmonized nomenclature, very rarely 
at lower levels (sections, etc.) Economic classification of goods is not a practice that Comoros 
currently engages in. 
299.  Indirect taxation is based on the levying of duties and taxes at import by Customs, 
and a system of taxation at import and export, including: 
(1) the single import tax (TUI) based on the c.i.f. value in four bands, namely 0%, 50%, 
25% and 30%; 
(2) the specific single tax (TUS), levied on weight, volume and units; 
(3) special tax on tobacco and alcohol at rates of 180% for tobacco, and at 200% 
and 230% for Customs headings 22-03 to 22-06, and 22-07 to 22-08 respectively; 
(4) a single administrative charge (RAU) at two rates: 1% for fully taxed imports and 3% 
for exempt imports. The RAU is paid to the Financial Administration Equipment Fund 
and is calculated on the basis of customs receipts; 
(5) the regional cooperation tax (TCR), levi e d  a t  a  r a t e  o f  1 %  o f  t h e  c . i . f .  v a l u e  
of imports; 
(6) the single tax on petroleum products including a normal rate of KMF 230 per litre 
of petrol, a reduced rate of KMF 211 per litre  of petrol, a normal rate of KMF 115 per 
litre of diesel fuel and a reduced rate of KMF 95 per litre of diesel fuel; 
( 7 )  t h e  s i n g l e  r i c e  i m p o r t  t a x  a t  a  r a t e  o f  K M F  4 0  p e r  k i l o  o f  o r d i n a r y  r i c e ,  
and KMF 150 per kilo of superior quality rice; 
(8) tax at a single 5% rate calculated on the f.o.b. value applies to exports of essential 
oils, vanilla and cloves. 
 300.  The above levies are protection charges because they apply only to imports: they are 
in principle cumulative duties that make clear the level of nominal tariff protection per product. 
The TUI, RAU and TCR are ad valorem  taxes, whereas the TS is a specific tax levied in accordance 
with weight, volume or units. 
Since 2007, under successive finance laws, the TUI has had three different rates: 0%, 5% 
and 20%. 
 301.  Overall indirect taxation accounts for up to two thirds of State revenue, illustrating the high 
dependency on imports and exports. 
302.  Customs duties are generally applied on an ad valorem  basis (calculated as a percentage 
of a good's value). Recent reforms have brought th em more into line with the aims of the COMESA 
common external tariff (CET). Three rates: 0%, 5% and 20%, were adopted under the 2007 
finance law. The fall in fiscal revenue was offset by extending the consumption tax (TC) and excise duties. WT/ACC/COM/3 
- 47 - 
303.  The reforms mark a step in the right direction but the tariff structure is still inconsistent and 
there is more work to do to make tariffs a reasonable economic incentive to promote sustainable development. 
304.  A tariff structure that encourages production should be progressive with end consumer goods 
subject to higher taxes than inputs and capital goods. Progressivity has reversed under the various 
successive finance laws since 2007. The result is that commercial activities are promoted to the detriment of production. The non-progressive nature of tax rates is unable to provide effective 
protection for Comorian industries. 
305.  Moreover, Comoros acceded to the COMESA FTA in 2006 and notified the application 
of a 100% tariff reduction on products originating in the region under the COMESA CET: 0% on capital goods and raw materials, 10% on intermediate products and 25% on finished products. 
306.  In addition to import duties, the TC, the Advance Tax Payment (AIT) and the additional tax 
levied by the Chamber of Commerce, Industry and Agriculture (CCIA) are levied at Customs. The TC is charged at a 10% rate on the basis of th e c.i.f. value plus the TUI or the TS. The rate of 
AIT and the CCIA additional tax is 1% of the c.i.f. value of imports. Ad valorem  duties apply to 
many products and rates vary from 5% to 250%. 
307.  The reforms at the beginning of the 1990s we re introduced as part of the PAS, but the 
recent reforms aim to bring the country in line with the objectives of the COMESA CET. As a result, 
although in 2001 there were three TUE rates of 20%, 30% and 40%, the current rates are 0%, 5% and 20%. The 2007 finance law reduced the maximum rate from 30% to 20%. The expected fall in fiscal revenue from the dismantling of tari ffs has been offset for a number of years by the 
enlarged scope of application of excise duties. 
Table 10: Tariff structure of Comoros, 2006 and 2007 
Unweighted tariff rate (TU and RAU, excluding hydrocarbons) (%) 
 
 2006 2007 
Capital goods 29.7 20.8 
Intermediate products 27.7 19.4 
Consumer goods 26.9 18.0 
TOTAL  27.6 19.6 
Sources: Customs General Directorate, DTIS Mission, United Nations BEC. 
 
308.  The figure for the unweighted average tax sh own in the table above gives only a rough idea 
of the fiscal burden on imports because, firstly, many tariff lines are not the subject of importations, and secondly, many importations are exempt, including end consumer goods. Based 
on the TUI and the RAU actually paid, the weight ed tariff average was 12.6% in 2006, much lower 
than the unweighted rate. 
309.  Unfortunately the Union of the Comoros does  not have a calculation of the average tariff 
rate. Consequently, figures are not available for either the overall tariff rate or for agricultural 
imports. The calculations here are based on calcul ations performed as part of the DTIS and on the 
figures involved in drawing up this report. 
310.  An analysis of tariffs based on duties and charges paid, and having regard therefore to 
exemptions, shows that there is no progressivity because intermediate consumption is taxed at a higher rate than end consumption. Failure to  implement progressivity and the wide range in 
rates (from 0% to 30% in 2006) for each of the categories of goods cannot definitely deliver 
a positive effective protection rate (TPE) for all Comorian industries. The tariff structure, in 
addition to the country's other structural constraints, does not incentivize local production and encourages the development of strictly commercial activities. 
311.  According to the rationale of progressive tariff rates that reflect the openness of trade 
practices, the 0% and 5% TUI rates should apply to staple goods, capital goods and raw materials, and the 20% rate to end consumption. WT/ACC/COM/3 
- 48 - 
312.  The Comorian tariff does not follow that logical structure at present. Each category of goods 
is subject to the three TUI rates (Table 10). Close to 20% of end-consumer goods are taxed at rates under 20%. Over 80% of intermediate consumption and nearly 90% of capital goods are theoretically taxed at the 20% rate. These inconsistencies are essentially the result of defining the 
tariff in line with chapters because a chapter mo re often than not covers the three categories 
of goods. 
Table 11: Distribution of rates by category of goods (tariff line) (%) 
TUI Capital goods Intermediate products End-consumer goods 
0% 10.4 14.6 18.4 
5% 0.5 2.9 1.4 
20% 89.2 82.4 80.4 
Source: Ministry of Finance and the Budget, Finance Law 2007. 
Table 12: Tariff structure of Comor os based on duties and taxes paid 
 2006 2007 2008 
Capital goods 6.1 5.8 7.0 
Intermediate products 14.4 14.9 15.0 
End-consumer goods 11.2 11.1 17.13 
Vehicles 28.9 23.7 29.70 
TOTAL  12.6   
Source: DTIS, 2007 and Memorandum on the Foreign Trade Regime, 2009. 
 
- Customs tariff nomenclature 
 
313.  Under Law No. 90-022/AF, the Union of the Comoros adopted the Customs nomenclature based on the Harmonized Commodity Description and Coding System (HS). As a member 
of COMESA and the alignment of COMESA's REC nomenclature, Comoros uses the 2002 version 
of the HS. Since February 2008 the Customs authorities have been using ASYCUDA++ software, an upgrade to ASYCUDA 2.7 as a result of an  assistance package from COMESA and UNCTAD. 
314.  The COMESA nomenclature (HS, 2002 version), based on the World Customs Organization 
model, provides a logical structure within which over 1,200 headings are grouped in 96 Chapters, 
the latter being themselves arranged in 21 Sections. The HS comprises over 5,000 separate groups of goods identified by a 6 digit code, the fi rst four digits thereof correspond to the relevant 
heading number, while the fifth and sixth digits identify the one and two dash subheadings 
respectively. The new software is more effective and is used by most COMESA countries. 
Table 13: Revenues collected and ex penditure by the State, 2005-2011 
 2005 2006 2007 2008 2009 2010 2011 
Tax revenue  17,797  17,259  16,678  18,288  20,515 22,449 23,520  
Direct and indirect taxes  4,305  4,784 7,147 6,790 10,867 11,514 12,412  
International trade  10,989 8,533 5,984 9,169 9,648 10,935 11,108  
Non-tax revenue 6,175  4,296  4,482  5,091  5,887 6,426 11,273  
        
Total revenue  23,972  21,555  27,852  23,379  26,401 28,875 34,793  
Budgetary expenditure        
 Staff 12,872  13,205 13,084 15,690 17,034 18,500 18,409  
 Goods and services 5,167  5,548 6,351 8,122 7,447 7,553 7,662  
 Transfers 2,879  3,413 3,858 2,678 5,325 3,578 3,889  
Interest on the public debt 1,047  724 1,169 1,217 1,069 1,036 952  
Other current expenditure  1,411  996 2,020 2,092 3,365 2,448 4,874  
Total expenditure 20,918  23,931  26,482  29,799  34,240 33,115 35,785  
Balance  -3,054  -2,376  1,37 -4,087  -7,839 -4,240 -992  
Source: Ministry of Finance and the Budget, BCC Annual Reports. 
 
315.  The advent of the system presented an oppo rtunity to review and streamline the procedures 
and organization of customs by making ambitious efforts to computerize the processing chain in 
full. After a few stumbling blocks when the new operating system went live, the software has attained near-optimum operational capacity. A training programme was provided by COMESA, 
which continues to provide assistance by way of systems monitoring and evaluation during the WT/ACC/COM/3 
- 49 - 
launch phase. Progress among users in coming to  grips with the system would appear to be 
satisfactory. 
316.  There are several advantages to the implem entation of the ASYCUDA++ system in the Union 
of the Comoros: 
- facilitation and streamlining of customs formalities and procedures; 
- monitoring of handling; - traceability of declarations; 
- rapid processing; 
- securitization of State revenue; - maximization of customs receipts and associated duties, reflected in a 5% increase 
in 2008 compared to 2007; 
- risk management and better monitoring. 
 317.  Upon completion of the work to install fi bre optic cables linking the islands to make the 
transmission service more efficient, the Web Transit Data Transfer module will enter into service, 
enabling ASYCUDA++ to perform at optimum level; current use of the software does not exploit it to its full potential. 
- Types of duty 
 318.  Among the three types of duties – ad valorem , specific and combined (an ad valorem  duty as 
well as a specific element), the Union of the Co moros uses three types of duty rate: the single 
import tax, the specific tax on weight and volume and the fiscal special tax at 180% for tobacco 
for tariff headings 22-03 to 22-06 and 250% for tariff headings 22-07 and 22-08. 
319.  In response to Customs bottlenecks the authorities, keen to safeguard the current import 
revenue upon which the State budget depends, reached an agreement with the private sector and 
introduced a flat tax system on goods from certain sources. The finance law currently in place sets the following flat taxes: 
- As in all countries, customs duties raise revenue that feeds into the general State 
budget of the Union of the Comoros. As a net importer of goods and services, the tax base of the Union of the Comoros essentially relies on import duties. Duties apply to 
imported goods in line with the rates referred to in the customs tariff of the Union of 
the Comoros, Chapters 1 to 96, sections I to XXI. 
 - In addition to customs duties, imported goods may also be subject to certain domestic 
charges levied at customs that must be paid before clearance is granted, for example 
consumption tax and certain excise duties introduced following accession to the COMESA FTA in 2006. This group of taxes ( listed and examined in paragraph 1(d) 
below) will be withdrawn once value added tax (VAT) enters into force. To that end, 
a law on VAT and implementing regulations must be adopted as part of the fiscal transition recommended in the 2007 DTIS and the IMF by way of a response to the challenges of integrating the Comorian economy into globalization. 
 
- MFN rates  
320.  The Union of the Comoros applies MFN rates to non-COMESA imports of goods 
on a four-band COMESA CET adopted at Nairobi in May 2008 by the Council of Ministers regardless of the country of origin: 
• capital goods: 0%; 
• capital goods: 0%; • intermediate products: 10%; • finished products: 25%. 
 
- Preferences  
321.  The Union of the Comoros is a member of the Indian Ocean Commission and COMESA to 
which it has notified a preferential regime consisting in a tariff reduction of 80% on originating WT/ACC/COM/3 
- 50 - 
products for the IOC and 100% for COMESA as part of the accession to the FTA notified in 2006. 
The other trade arrangement is the Economic Partnership Agreement: Comoros has signed an interim version that provides for a reduction of 80% implemented on a progressive basis over a period of fifteen (15) years. Under the EPA Como ros excludes 20% of its trade with the European 
Communities because of the sensitivity to State revenue of products in the notified tariff lines. 
(c)  Tariff quotas, tariff exemptions 322.  The Union of the Comoros does not apply tariff quotas on imports. 
(d)  Other duties and charges 
323.  In addition to duties and other charges, im ports may also be the subject of various charges 
to certain trade organizations (COMESA, IOC and WT O )  o f  1 %  o f  t h e  c . i . f .  v a l u e ,  a n d  a  s i n g l e  
administrative fee against which various contributions are allocated under the finance law in force. 
The contributions are levied as follows, pursuant to the finance law in force: 
 
- 2% by way of budgetary revenue: Title I, Chapter 20, Article 1 and paragraph 04 
"Administrative fee contribution"; 
- 2% paid into the special allocation account established under Article 5 above under the 
heading Customs equipment; 
- 1% paid into the Chamber of Commerce account opened in the Treasury accounts. 
 (e)  Quantitative export restrictions 
324.  Under the structural adjustment programme there have been no quantitative restrictions 
on imports, or quotas in force in Comoros since the 1990s, (Order No. 99-001/MECIA/Cab, 
abolishing import and export licences). Licensing procedures are examined in point (f) below. 
325.  Sections I to XXI of the HS nomenclature 2002 version in force in the Union of the Comoros 
and the products described in them are free of quotas. Notwithstanding, some goods listed below 
are subject to international trade restrictions relating to: the application of Security Laws and Regulations; the control of arms, ammunition  and other war equipment and military items; 
the protection of human, animal or plant health or life; protection of public morality; the transfer 
of gold, silver and precious and semi-precious stones; the protection of national artistic and cultural property; the control of narcotics, hazardous and toxic waste, nuclear materials, radioactive products or any other materials used in the development or exploitation of nuclear 
energy. However, the Union of the Comoros is not a member of certain conventions 
on endangered fauna and flora but pursuant to the recommendations of the World Customs Organization and trade-related provisions with non-party States it is authorized to apply these 
conventions nonetheless. 
(f)  Import licensing procedures 326.  It is not currently necessary to obtain pr ior authorization to engage in external trade. 
It should be noted that an import licence for superior quality rice was introduced in 2012 under the 
finance law. There is one exception to that rule. Since 2005 the finance law in force has provided for the issuance by AGID of an import licence fo r alcoholic beverages. The import and sales licence 
is issued annually subject to payment of a duty of: 
i. KMF 4 million for importers; 
ii. KMF 500,000 for distributors; and 
iii. KMF 250,000 for bars and restaurants. 
327.  As part of the necessary reforms undertaken in cooperation with the Bretton Woods 
Institutions and the WTO with a view to the acce ssion of Comoros to the WTO and the requirement 
to be in line with the rules of the multilateral framework, the authorities intend to establish an 
adequate framework to manage both the licensing regime and the award of licences by the various 
competent authorities authorized to that end in each case. WT/ACC/COM/3 
- 51 - 
328.  The objective is to move away from viewing licences as a source of fiscal revenue and 
towards economic regulation and control through objective, transparent, equitable criteria. 
329.  Under the regime currently in place an import licence is valid for one year and may be 
renewed upon payment of a renewal fee. The le vel of the fee depends on the nature of the 
sections to which the licence in question relates. The fees raised revert to the competent authority 
in accordance with the provisions of the finance law in force. 
- Authorization procedures for industrial enterprises 
 
330.  Authorization procedures for industrial ente rprises are governed by the laws and regulations 
in force. All industrial enterprises must be entered on the Register of Commerce, Companies and Cooperatives pursuant to the relevant provisions of OHADA by submitting the authorization issued 
by the Ministry of Indust ry and the other documents required by the law and regulations in force. 
Registration is subject to the proper completion of a form by the company in question. 
- Authorization procedures for enterprises in the tourism or transport industries 
 
331.  Procedures in these fields are governed by the law and regulations in force in the Union of the Comoros on enterprises in the tourism industry. All persons, whether Comorian nationals 
or otherwise, intending to engage in tourism or transport-related activities in the Union of the 
Comoros must apply for an authorization to that end to the competent departments of tourism or transport at the relevant Ministry. 
332.  Under the system set out in the estab lishment agreement between the authorities and 
certain operators that promote the sector, an agreement that is part of a strategic investment may 
confer specific advantages and privileges upon tourism-related enterprises in respect of imports (machines, equipment, construction materials, etc.) that fall within their field of operations. 
(g)  Other border measures 
 None. 
 
(h)  Customs valuation 
333.  The Union of the Comoros is not yet a Member of the WTO and is not a signatory to the 
Agreement on Implementation of Article VII of  the General Agreement on Tariffs and Trade 
(Customs Valuation Agreement). Neither is Comoros on the Committee on Customs Valuation of 
the World Customs Organization (WCO), either as  a member or an observer. The Union of the 
Comoros is a member of the WCO, however. The Brussels Definition of (Customs) Value (BDV) 
acts as a basis for calculating customs duties and other customs charges. The Union of the 
Comoros uses the c.i.f. value for imports, and the f.o.b. value for exports. 
334.  In applying the BDV in its customs valuation procedures, Comorian Customs focuses on a 
number of key elements: (1) sale; (2) price; (3) date; (4) place; (5) quantity; and (6) commercial 
level. In conformity with the BDV, the Customs value of an imported good is its "normal value". 
In other words, the price of those goods when a sale is made under competitive conditions between a buyer and an independent seller. Comori an Customs determines the value of imported 
goods as of the date of presentation of the paperwork. In determining the customs value, 
the Customs Authorities take into consideration that: 
- the goods are delivered to the buyer at their point of entry into the country; 
- the seller includes in the price all of the ex penses related to the sale of the goods and 
the delivery of the goods to the entry point; and 
- the buyer is responsible for the payment of  in-country duty expenses, and any other 
charges that are payable. Duties and other taxes or charges must be excluded from 
the "normal value." 
 335.  Disputes arising from customs valuation deci sions are reviewed and decided by the Valuation 
Service of the Customs Authority in its capacity as the administrative department with jurisdiction 
to address the parties and call upon qualified personnel. Judicial appeals of customs valuation WT/ACC/COM/3 
- 52 - 
disputes, if made, fall within the jurisdiction of the administrative court or the special fiscal and 
customs court where jurisdiction is assigned to the special courts under the relevant provisions of the law on special courts. Appeals are made following the Code of Criminal Proceedings and the Ordinary Courts in force in the Union of the Comoros (see Figure 1 of this document). 
336.  A new Customs Code is being drafted. It is envisaged that the draft Code will include the 
provisions of the WTO Customs Valuation Agreem ent. However, the Union of the Comoros will 
require a transition period, during which it will draft the applicable laws and regulations relating to 
the GATT valuation system. Technical assistance from developed countries, the country's 
development partners and specialist international organizations will be needed. Similarly, training for customs agents responsible for valuation would be essential alongside assistance in drafting the implementing regulations and interpretative notes. 
337.  The Union of the Comoros has acceded to th e Kyoto Convention; the Convention was ratified 
on 23 May 1991 and entered into force on 21 August 1991. It has not yet acceded to the Istanbul Convention, but its customs legislation and re gulations and practices are based on the two 
Conventions. In a similar fashion, Comoros applies the HS without being a Contracting Party to the 
associated Convention. 
338.  The Union of the Comoros also applies a reference price and a minimum taxable price for 
certain imported goods as part of efforts to combat fraud and guarantee State revenue. 
(i)  Other customs formalities 339.  Except for limited cases, namely objects for personal use belonging to passengers and 
returns to family members not of a commercial ch aracter and of minimum value as set out in a 
regulatory note from the General Customs Administration that are the object of a simplified 
"summary" declaration, all imported or exported goods must be the subject of a detailed declaration. 
340.  This declaration must detail certain essential elements, namely: the description of the goods; 
type of duty; country of origin; country of expo rtation; freight; intended use; characteristics 
(weight, length, area, number, etc.); and, value. 
341.  With respect to imports, the declaration must be accompanied by the following documents: 
- declaration of release for consumption; 
- certificate of origin; - commercial invoice, attested by the portfolio service of a first-tier local bank or the 
external trade directorate; 
- air waybill (where the goods are carried by aircraft); - bill of lading (where the goods are carried by sea); 
- phytosanitary certificate (for plant products); 
- health certificate (for animal products); - insurance certificate. 
 
342.  After the delivery of the declaration, there are a number of administrative formalities to complete to confirm that there are no obstacles to admission. The formalities are specifically the responsibility of the customs authorities and assume that the party making the declaration is able 
to supply the necessary documents related to the declaration. The formalities also require 
submission of any supplementary documentation and documents whose disclosure or submission is mandatory. The customs clearance procedure can be described as follows: 
- The forwarding agent or the owner of the goods to be customs cleared recovers the 
manifest from the Customs General Directorate or at one of the centres. The manifest permits a declaration to be made of all the goods to be customs cleared. 
- The Customs Brigade signs ( Visa Ne Varietur ) the manifest after checking the goods 
and cross checking against the declaration on the manifest. 
- The manifest is then entered into ASYCUDA, the customs transactions processing 
system. WT/ACC/COM/3 
- 53 - 
- The manifest is then forwarded to the acce ptance department which examines its form 
and its substance. 
- The following stage includes various registration measures (dating and numbering) 
and a check on the accuracy of the declaration, one of the first phases in the customs 
clearance process for products. 
- The declaration, whether amended or not, is then submitted to a dual conformity 
control the results of which show whether customs formalities have been correctly 
followed, calculate the amount of duties and charges payable and arrange for 
payment to be made. 
- The forwarding agent or the owner finally pays the customs charges and upon 
payment the good can exit customs. 
 
343.  All the customs regimes introduced by th e Customs Cooperation Council, and subsequently 
by the World Customs Organization, are applied in  the Union of the Comoros, in particular the 
regimes detailed below. 
344.  Exemptions, the result of legal provisions, s eek to encourage economic activities in specific 
productive sectors (industry, fisheries, agricult ure, tourism, transportation and communications); 
the development of national infrastructures (ports , airports and roads); and certain agencies and 
persons who are essentially importers (the State, th e diplomatic corps, international organizations, 
charitable bodies, grant and aid institutions, gifts, aides, travellers, emigrants returning definitively, etc.). 
- Customs bonded warehouses 
 345.  The customs bonded warehouses regime allows the storage of goods in a specific location 
under customs control until payment of custom s duties and taxes and the storage of goods 
imported under special economic policy measures. 
346.  Under the Law on the Customs Code in the Union of the Comoros, the Customs bonding 
regime (storage warehouse) entails the authority to place goods in establishments subject to 
customs authorities' control for a specified period. 
347.  Joint orders from the Minister for Finance and the Budget and other relevant Ministers 
determine the categories of warehouse in which merchandise may be stored. 
348.  The 1992 Customs Code of the Union of the Comoros provides for three different categories 
of warehouse: 
- government warehousing to meet general needs; 
- private warehousing, granted to a physical or legal person, or industrial or commercial 
enterprises for specific needs; 
- special commodity warehousing, authorized by an order in council of the Minister for 
Finance and the Budget after consultation with other relevant Ministers to store 
certain categories of goods the storage of which presents particular dangers or requires special conservation facilities; 
- industrial warehousing (Articles 131 to 136 of the Customs Code), an establishment 
under the control of the Customs authorities where enterprises active in exports or in 
both exports and the domestic market can receive authorization to release goods conditionally relieved from payment of import duties and taxes. 
 
349.  Under the Customs Code, especially Article 112(3), unless otherwise provided for, warehousing: 
- suspends the implementation of customs duties, taxes, prohibitions and other 
economic, fiscal and customs measures to which the goods are subject other than the goods referred to in Article 114(2) thereof; 
 
- entails in whole or in part the effects of export for the merchandise referred 
to in Article 114(2) and ensures satisfaction of the conditions to which treatment of goods as exports is subject. WT/ACC/COM/3 
- 54 - 
 
- Free-zone enterprises  350.  Strictly speaking there is no legislation an d therefore no regulations on free-zone enterprises 
in the Union of the Comoros. There is nothing in the OHADA Uniform Acts in this regard. 
Consequently the States parties to OHADA pass legislation on free-zone enterprise regimes, usually to supplement the general provisions of the Investment Code. 
351.  To fill the existing legal void and supplement the new Investment Code the authorities of 
Comoros will adopt a legislative and regulatory framework for free-zone enterprises as part of a comprehensive strategy to attract investme nt, especially foreign direct investment. 
352.  To that end the legislation will incorporate the now universal definition of free-zone 
enterprises, namely that free-zone enterprises are enterprises created to produce and trade in 
goods and services exclusively for export. 
353.  Generally two categories of free-zone enterprises will have legal recognition: 
- suppliers of services; and 
- producers of goods. 
 
354.  Production free-zone enterprises operate as  industrial warehousing under the Customs Code. 
In conformity with the rules in that regard, the Ministers for Finance and Trade may by joint 
act authorize a free-zone enterprise to sell up to 15% of its previous year's output on the local market. 
- Temporary admission 
 355.  Articles 139 to 148 of the Comoros Customs Code lay down provisions on the terms and 
conditions of the temporary admission proced ure. There are two categories of temporary 
admission: 
- the temporary admission of goods intend ed for re-export without modification; 
- the temporary admission of goods for in ward processing, namely after having 
undergone manufacturing, processing or further working in the customs territory. 
 356.  Article 139(1) states that goods that may be imported under the temporary admission 
procedure subject to the conditions laid down in  Chapter IV of the Customs Code are designated 
by orders of the Minister for Finance and the Budget. 
357.  It also states that nonetheless, decisions taken by the director general of Customs may 
authorize temporary admission operations other th an those provided for in the orders issued 
pursuant to Article 139(1) in exceptional circumstances or on grounds of experimental interest. 
358.  The orders or decisions referred to in Article 139(1) and (2) state: 
a. the nature of the further working, processing or manufacturing that the goods are to 
undergo and, in the latter case, the products eligible for offset; or 
b. the conditions in which the goods must be used in their current state. 
359.  Save application of the provisions of Article 139(2) the goods imported under the temporary 
admission procedure are conditionally relieved from payment of import duties and taxes. 
Furthermore unless authorized by the customs au thorities, goods imported under the temporary 
admission procedure and, where appropriate, the products resulting from their processing or 
further working may not be the subject of any transfer under that procedure. 
- Temporary export 
 
360.  Article 155 of the Customs Code of Comoros provides for a temporary export procedure. 
Although that Article does not identify any temporary export categories, case law and practice in this area distinguish two such categories: WT/ACC/COM/3 
- 55 - 
- temporary export of goods for re import, without having undergone any modification; 
and 
- temporary export for outward processing. 
 
361.  Article 155 on the temporary export procedure refers to orders of the Minister for Finance 
laying down: 
a. the conditions in which the customs authorities may authorize temporary exportation of 
products sent outside the customs territory in order to undergo further working; 
b. the terms under which the said products are to be subject to payment of entry duties 
and taxes at re-importation. 
- Prior export authorization and drawback 
 
362.  In respect of drawback (Articles 151 and 152), the procedure provided for in Article 139-1 on authorized use of the temporary import procedure provides for the total or partial reimbursement 
of customs duties and taxes borne by inputs used in exported goods. 
363.  Eligibility under the regime means the exporter must: 
a. justify the prior importation for consumption of the products released; 
b. satisfy the special requirements laid down by the Chief Customs Officer. 
(j)  Preshipment inspection 364.  The Union of the Comoros does not conduct preshipment inspection. However, Comorian 
Customs usually check the origin of exported goods that may be eligible for preferential treatment 
at their destination. 
(k)  Application of internal taxes on imports 365.  As discussed in paragraph 1(b) above, there are seven basic internal taxes applicable to 
imports to Comoros. As stated previously, this group of taxes will be eliminated within the 
time-limits laid down in the reforms planned by the Comorian authorities upon implementation of the value added tax (VAT). 
366.  The consumption tax – a domestic tax applied to certain imported products and to certain 
domestically produced products as they exit the factory is based on the c.i.f. value plus customs 
duties. The applicable rates are 7% and 10%. Some socially oriented products such as rice are 
exempt but are instead subject to a special ad valorem  rate, and a specific rate is applied to the 
physical unit of the taxable merchandise: 
i. rice: KMF 40 per kilogramme for ordinary rice and KMF 150 for superior quality rice; 
ii. petroleum products are subject to  two rates, normal and reduced: 
 
a. normal rate of KMF 230 per litre of petrol; b. reduced rate of KMF 211 per litre of petrol; 
c. normal rate of KMF 115 per litre of diesel; and 
d. reduced rate of KMF 95 per litre of diesel. 
 367.  General services tax, including customs services  tax, in the form of a fee applied to the c.i.f. 
value of the imported good to cover administrative costs. It is charged at 5%, consolidates several 
payments and is subject to post collection fiscal equalization. 
368.  Community levy – 0.6% ad valorem  charge levied on the c.i.f. value of imports of all origins 
to generate revenue for contributions to certain international trade organizations, principally 
COMESA and the WTO. 
369.  There is no environmental protection tax. Instead a proportion of the RAU is allocated to the 
Town of Moroni, the country's capital, by way of a contribution by the national authorities to waste 
management. WT/ACC/COM/3 
- 56 - 
370.  Stamp duty – not levied on import and export documents; under Article 219 of the 
Customs Code "customs proceedings and submissions and operations in lieu are exempt from stamp and registration duties". 
371.  However, stamp duty has been levied since 2007 on all administrative acts except those 
in the field of external trade. The duty is levied  by the General Directorate of Taxation through the 
purchase of a fiscal stamp at a flat rate of KMF 500. 
372.  In 2009, a duty-free shop opened as pa rt of the process to develop the principal 
international airport. It is not subject to a duty-free levy on commercial operation. It has been 
suggested that such a levy could be charged at the rate currently applied in other countries, equivalent to a 4% ad valorem  charge on the gross value of g oods traded by the duty-free shop. 
(l)  Rules of origin 
373.  Comorian customs legislation includes a rule of origin of general scope that applies 
to countries that are not eligible for the prefer ential treatment referred to in Articles 44 to 46 
of the 2002 Finance Law. 
374.  Article 85 of the Customs Code provides th at where, upon examination of the goods, the 
customs authorities dispute the statements in the declaration on the type, origin or value of the goods, the dispute is to be resolved in conformity  with the provisions of Title 14 of the Code where 
the declarant does not accept the customs authorit ies' assessment. However, there are no grounds 
for recourse to this procedure where the law provides for a special procedure to determine the type, origin or value of goods. 
375.  The Union of the Comoros is a member of the Indian Ocean Commission (IOC) and COMESA. 
In 1999, Comoros notified to its IOC partners a tariff preference consisting in a reciprocal 80% 
reduction on products originating from other member  States. Additionally, as part of the accession 
of Comoros to the COMESA free trade area in 2006, a reciprocal 100% reduction was notified to 
the other member States of COMESA. 
376.  In both the above cases Articles 44 and 45 of the 2002 Finance Law No. 01-007 provides 
that goods imported into the member countries of the IOC and COMESA will be eligible for the 
preferential tariff on a reciprocal basis where the goods in question satisfy the rules of origin 
criteria adopted by the organizations' member countries. 
377.  The applicable preferential tariff rates are se t out in an order of the Minister responsible for 
the budget. This procedure comprises drawing up a negative list of products excluded from the 
scope of the preferential tariff by order of the Minister responsible for the budget. 
378.  As regards COMESA, notification of a reductio n on the basis of rules of origin is one of the 
stages in the process towards full integration of the economies in the region through entry into the 
Customs Union and subsequent adoption of the CET. 
379.  By signing the treaty establishing COMESA, the COMESA member States have all agreed to 
work towards the common external tariff adopted by the Council of Ministers in Nairobi, Kenya, in 
May 2008. It should be recalled that the COMESA CET is based on four bands, as specified above 
in this document. 
380.  As is the case with the free trade area, until Comoros notifies accession to the COMESA 
Customs Union, it will not be possible to apply the CET because it must be adopted by the national 
parliament and replace the Customs Code currently in force. 
381.  However, under the terms of accession to the free trade area, Comoros applies the COMESA 
"rules of origin" and has introduced the dedicated certificate of origin. Pursuant to the COMESA 
Protocol on rules of origin, in determining eligibility for the preferential tariffs of the common 
market, goods will be accepted as originating in a Member State for the purposes of eligibility on the basis of the five following criteria or methods: 
• The goods have been wholly obtained or pr oduced in a member St ate or come from it; WT/ACC/COM/3 
- 57 - 
• the goods have been produced in a member State and the c.i.f. (cost, insurance, 
freight) value of the imported materials does  not exceed 60% of the total cost of the 
materials used in the production of the goods; 
• the value added resulting from the process of production performed by a producer of a 
member State on imported materials must account for at least 35% of the ex-factory 
cost of the goods; 
• as a result of the process of production, the goods are classified under a tariff heading 
other than the tariff heading under which they were imported; 
• the goods are of particular importance to the economic development of the member 
States, and contain not less than 25% of value added. 
 
382.  The Council of the Common Market provided for in Article 7 of the Treaty has drawn up a list 
of products ranging from railway rolling stock to industrial boilers, via machines used in textiles production, extractive industries, agriculture, etc. 
383.  Where two or more countries have taken part in the production of the goods, the origin of 
the goods should be determined according to the substantial transformation criterion. In that case, the country of origin is regarded as being the country in which the last substantial manufacturing 
or processing, deemed sufficient to give the commodity its essential character, was carried out. 
384.  The criterion of sufficient processing may give rise to:  - a change in nomenclature classification; 
 - further manufacture or further processing; 
 - the rule of ad valorem  share. 
 385.  In fact, both the Union of the Comoros and the other countries party to the COMESA Protocol 
follow the principles set forth in the WTO Agreemen t on Rules of Origin as the COMESA Protocol is 
in conformity with WTO standards. 
386.  It is envisaged that the new Customs Law will contain provisions that are fully compliant with 
the WTO Agreement on Rules of Origin, should the accession process to the COMESA Customs 
Union be delayed for any reason by the national authorities of Comoros. 
(m)  Anti-dumping regime 387.  The anti-dumping regime in force in Comoros is governed by the country's undertakings to 
COMESA, the Cotonou Agreement and the EPA in which the anti-dumping system is fully 
compatible with the WTO anti-dumping rules. 
388.  However, for the purposes of clarity on certain specific considerations, the system could be 
enhanced through the adoption of supplementary re gulations with assistance from the WTO to try 
and keep the procedural legal framework in step with the trade policy changes involved in the accession process. 
(n)  Countervailing duty regime 
389.  The countervailing duty regime in force in Comoros is governed by the terms of its 
undertakings to COMESA and the EPA. It will be st rengthened upon accession to the WTO. Specific 
considerations, while providing compatibility with the WTO multilateral framework and other 
undertakings, may be taken into account as part of a programme focusing on the legal framework 
of trade policy. 
(o)  Safeguard regime 
390.  There is no national legal or regulatory basis underpinning the safeguard regime. Only 
international commitments in this field have legal force in Comoros. It is the job of the national authorities to adopt a legal framework that affords both the required level of compatibility and 
a local procedural framework for this aspect of the trade policy regime. It should be noted that no 
actions have been brought and no enquiries op ened in the Union of the Comoros under this 
provision. WT/ACC/COM/3 
- 58 - 
2.  Export regulation 
(a)  Registration requirements  for engaging in exporting 
391.  Registration requirements for engaging in exports are identical to those for imports 
(see section IV.1(a) above). Exports of goods must comply with formalities for exchange 
transaction controls, and must also comply with all quality requirements, rules of origin or other 
standards imposed by law or by international accord subscribed to by Comoros. 
(b)  Customs tariff nomenclature, types of duti es, duty rates, weighted average of rates 
392.  The customs nomenclature for exports is the same as that for imports (see section IV.1(b) 
above). 
393.  Exit duty is levied to reflect the competitiveness of products for export. It has varied over 
time between 5% and 15% in line with the international economic situation. Downturns in the 
international markets have often led the authorities to withdraw this duty, including during budget 
implementation, to support the competitiveness of exports. 
394.  Export duties have not been levied on vanilla or cloves for several years. The additional tax 
has continued to be payable at a rate of 0.5%. It is not regarded as an export tax but as 
a resource collected by Customs that reverts to chambers of commerce under the current legislation. 
(c)  Quantitative export restrictions 
395.  Following trade liberalization measures taken in 1990, Comoros no longer applies 
quantitative export restrictions. As a signatory to the Washington Convention (International Convention on Endangered Species of Flora and Fauna, signed on 23 November 1991, entered into 
force in national positive law on 21 February 1995) , the Union of the Comoros prohibits the export 
of endangered species of flora and fauna. 
(d)  Export licensing procedures 
396.  Where export-oriented commercial enterprise s are concerned, following the liberalization 
measures implemented since the first structural adjustment programme at the beginning of the 1990s, export transactions have not been subject to any licence or prior authorization 
in the Union of the Comoros. There is no ex port licence document proper. The General Tax 
and Property Administration levies only a trade tax specific to taxpayers engaged in imports and exports. 
397.  There are plans, however, to introduce an import and export licensing regime administered 
by the external trade services in order to regulate  the economy and control the flow of lawful trade 
that is being undermined by a growing informal sector. 
(e)  Other measures 
398.  Comoros does not apply a system of minimum export prices, nor does it participate in any 
voluntary export restraints or orderly marketing arrangements. 
(f)  Export financing, subsidy and promotion policies 
399.  The only incentives to export or re-export in Comoros are those contained in the Customs 
and Investment Code and those specifically provided for in the finance law in force; the latter may provide for a zero-rating or a reduction in exit duty (no subsidies). However, as part of the accession of Comoros to the WTO, there are plans to  adopt a specific law on incentives to export 
or re-export goods and services. 
400.  The Union of the Comoros promotes its exports and re-exports through the Chamber 
of Commerce, Industry and Agriculture (a publ ic sector professional body under the law), 
the Economic Interest Grouping " Maison des Épices ", which acts as an umbrella for WT/ACC/COM/3 
- 59 - 
socio-professional organizations in the sector s and industries concerned, and the National 
Investment Promotion Agency. 
401.  The competences provided for by the statutes of these various structures include: identifying 
national products or enterprises with export potential, organizing seminars and conferences 
on technical training, participating in trade fairs, researching potential export markets, 
and supplying market data to interested entities. 
(g)  Export performance requirements 
402.  The Union of the Comoros has no export performance requirements other than the statutory 
obligation to surrender foreign exchange from export transactions within 30 working days calculated from the date of receipt of the foreign exchange to the exchange office at the Central Bank of Comoros, in conformity with the external  trade and exchange control regulations, and the 
legislation on financial relations with other countries. 
(h)  Import duty drawback schemes 403.  The import duty drawback scheme is gove rned by Article 151 of the Customs Code, which 
provides that "total or partial refund of customs duties and taxes levied on inputs for the 
manufacture of goods for export is allowed in accordance with the procedure provided for under Article 139-1 above on authorization of the use of the temporary admission procedure". 
404.  Eligibility for the refund provided for in Article 151 of the Customs Code requires applicants 
to be in compliance with the conditions set out in Article 152: 
(a) justify the prior importation for consumption of the products in question; 
(b) satisfy the special obligations impose d by the head of the customs service. 
 
405.  In the Union of the Comoros "drawback" means any arrangement, including temporary duty-free admission, for the refund of all or some of the duties applicable to imported 
raw materials, provided that the arrangement expressl y or in effect allows such refund if goods are 
exported but not if they are retained for home use. 
406.  The relevant provisions (temporary importat ion, free zones, drawback, etc.) of the Customs 
Code is the sole frame of reference for drawback in force in the Union of the Comoros and offer all 
the advantages anticipated by applicants under this regime. 
407.  Importation free of all or some customs duties  and taxes is allowed, in accordance with the 
procedure provided for in Article 139-1 of the Customs Code on authorization of the use of 
temporary admission procedure for products of the same type as those supplied for use in the 
manufacture of previously exported goods (Article 149). 
 To be eligible for the duty-free regime, the importer must, pursuant to Article 150: 
 
(a) justify the prior exportation; (b) satisfy the special obligations impose d by the director general of Customs. 
 
3.  Internal policies affecting foreign trade in goods 
(a)  Industrial policy 408.  The Government's industrial policy emphas ises agribusiness and export led growth to add 
value to agricultural production and satisfy dome stic demand and, ultimately, external demand. 
One of the objectives of the policy is to st imulate the development of an industrial and 
entrepreneurial sector that is capable of spurring growth and creating the conditions necessary for 
modernization and business competitiveness. 
409.  Enterprises properly registered in Comoro s are eligible for a number of incentive schemes. WT/ACC/COM/3 
- 60 - 
410.  Registered enterprises and their approved pr ojects are entitled to exemptions from Customs 
duties, consumption taxes and general customs emoluments on the import of construction materials, machinery, equipment, instruments and utensils, handling and transportation equipment, when destined for authorized industrial projects. 
411.  Industrial enterprises benefit from an exemption from the diverse profits tax (IBD) for the 
first three years of their existence (Decree Law No. 108/89 of 30 December, Official Journal 
No. 52, first Series of 30 December 1989). 
(b)  Technical regulations and standards 
412.  A Standardization Office was established in 2013 at the Ministry of Production. Consequently, 
the Union of the Comoros does not yet apply technical regulations to domestic or imported goods (except for the sanitary and phytosanitary measures discussed in section IV.3(c) below). 
413.  The Union of the Comoros would recognize products certified in other countries provided the 
certification was valid and from an authorized certifying body. 
414.  Document WT/ACC/8 has been notified to the Ministry of the Economy and Foreign Trade. It 
is envisaged that ACC/8 data will be complied and available for examination at the first Working 
Party meeting on the accession of Comoros. 
415.  Application of technical regulations and standa rds is currently very low. Technical assistance 
would therefore be particularly important and useful. 
(c)  Sanitary and phytosanitary measures 416.  Food products imported into the Union of the Comoros are subject to inspection by the 
health authorities. A phytosanitary report on plants and plant products must be submitted to the 
health inspector. The certificate issued by the offici al services of the country of origin must certify 
that the goods were examined in detail, either in  their totality or on the basis of representative 
samples, and that they are considered free from plagues and diseases to agricultural products. 
It must also certify that the product was shipped in accordance with the sanitary and 
phytosanitary rules in effect in the importing country. 
417.  A certificate from the manufacturer must also accompany the phytosanitary product stating 
that the living matter and other constituents of  the commercial preparation correspond, with 
regard to its identity, quality, purity and composition, to the requested product. It must also certify that it is in conformity with the directives of FAO's 1986 international code of conduct for the distribution and use of phytosanitary products. 
418.  Likewise, the import of animals, foods or products of animal origin must always be 
accompanied by a phytosanitary certificate issued by the veterinary health authorities of the country of origin. This certificate should note the sanitary status of the goods and the epizootologic 
situation of the importing country. It must also certify that the goods in question meet the 
established technical standards for the import of these products. 
419.  Under the laws and regulations in force, the export and import of plants and plant products 
such as seeds, fruits, plants, flowers are subject to sanitary control at the maritime or air port of 
entry open to international traffic. These products are subject to inspection to look for the presence of plant or animal organisms or pathogen ic agents that are harmful or potentially harmful 
to plants and/or plant products in the national territory. The health inspector may decide to take 
samples for laboratory analysis, and, if necessa ry, quarantine the product. If an inadequate 
sanitary status is confirmed, the product may be subject to decontamination or disinfection, or returned to the country of origin. The control points are the responsibility of the Plant Protection 
Services of the Agriculture Directorate. 
420.  Additionally, in conformity with the regulati ons in force in the Union of the Comoros on the 
import, commercialization and use of sanitary and phytosanitary products, the imported products 
must be included in the country's list of approved products. They must also be transported in their 
original, intact packaging. Upon arrival, the sanitary and phytosanitary inspector must first verify WT/ACC/COM/3 
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that the products conform to the import authorization issued by the competent authorities. 
Where the products do not conform to the import authorization, the sanitary and phytosanitary products inspector may order their return to the country of origin, within the time-limit laid down to that end. 
421.  The regulations in force authorize the government to take all the measures necessary to 
prevent the propagation, appearance, and eradicat ion of the zoonoses most hazardous to humans, 
as well as diseases regarded as serious for livestock. To facilitate controls, the import of animals, 
food and animal products can occur only at the entry points established by the 
Ministry of Agriculture veterinary services. Immedi ately after arrival on the national territory, the 
Official Veterinarian conducts sanitary checks. The regulatory framework in this area requires revising to bring it into conformity with universally accepted standards and procedures. 
(d)  Trade-related investment measures 
422.  The Union of the Comoros has no trade-related investment measures dealing with currency 
or trade balancing requirements. Further, there are no local content requirements on production as 
a condition of investment or trade. Consequently  no trade-related investment measures are in 
force in Comoros. 
(e)  State trading practices 
423.  At independence the Union of the Comoros relied on State control to meet its economic 
objectives, and the Government established a number of State enterprises. Since 1990, the emphasis has shifted to private sector led growth, and the Government has privatized or awarded concessions in respect of approximately six State enterprises. A few State enterprises remain, 
however: Comores Télécom; SCH, ONICOR, MAMWE, SNPSF, COMAIR, APC, AL WATWAN, PNAC. 
PNAC was a body established to produce generic drugs, and import and distribute pharmaceutical products to ensure universal access to essential medicines. 
(f)  Free zones 
424.  The Union of the Comoros has no specific legislation in this regard but has undertaken to 
change this situation and supplement the Invest ment Code by introducing a free-zone regime. 
However, Article 205, Chapter XI of the Customs Code provides for a free maritime port zone. 
That Article states that "In any maritime port a proportion of the port buildings named 'maritime free zone' may be removed from the Customs regime". 
425.  Currently there are no active free zones in the Union of the Comoros. 
(g)  Free economic zones 
426.  There are no free economic zones in the Union of the Comoros. (h)  Trade-related environmental policies 
427.  The Union of the Comoros does not levy any environmental protection taxes on imports that 
are not packaged in biodegradable material. In view of the environmental issues increasingly r a i s e d  b y  p a c k a g i n g  o f  t h i s  k i n d  t h e r e  i s  a n  u r g e n t  n e e d  t o  a p p l y  a n  ad valorem  tax 
to non-biodegradable packages and interior wr appings and to non-biodegradable packages and 
interior wrappings imported for the purpose of packaging goods for domestic consumption. The tax would be based on the c.i.f. value of the imported goods. 
428.  At present, there is no domestic production of non-biodegradable materials in Comoros. 
In the event that biodegradable materials go into domestic production, Article III (national 
treatment) will be taken into consideration. 
(i)  Mixing regulations 
 None. 
 WT/ACC/COM/3 
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(j)  Government-mandated counter trade and barter 
429.  The Union of the Comoros does not have government-mandated counter trade or barter. (k)  Trade agreements leading to country-specific quotas allocation 
430.  The Union of the Comoros is not signatory to any trade agreement that imposes 
country-specific quota allocation. 
(l)  Government procurement practices 431.  Government procurement practices in the Union of the Comoros, including the relevant 
general legal regime, are set out in Law No. 11-027/AU of 29 December 2011 on government 
procurement and public service concessions. 
432.  Tendering procedures for public works projects are set out in Law No. 11-027/AU 
of 29 December 2011, referred to above. Generally , construction contracts are awarded only after 
a public bidding process has taken place (except in exceptional cases where the Law allows 
the competent authority to directly select a supplier without issuing a call for tenders). 
(m)  Regulation of trade in transit 
433.  Trade in transit is governed by Chapter II, encompassing Articles 105 to 111 of the Customs 
Code of Comoros. Apart from the trade in transit within Comoros customs territory, transit involving more than one customs territory with goods coming and going by sea or air is 
insignificant or nil. However it is envisaged that the Customs Law currently in preparation will 
include the basic WTO rules concerning regulation of trade in transit. In the event that Comoros 
adopts the COMESA CET, it should be noted that pr ovisions in conformity with the basic WTO rules 
concerning the regulation of trade in transit have been incorporated. 
4.  Policies affecting foreign tr ade in agricultural products 
434.  The Union of the Comoros enjoys a favourable climate in the intertropical zone with 
abundant rainfall resulting in significant plant cover. However, demographic pressures reflected in 
growing urbanization and growing pressure on plant cover has reduced the arable area and plant 
life. Like other tropical island groupings, the Comoros islands have a rich but vulnerable ecology that has suffered serious adverse effects as a result of climate change and various pressures 
within Comoros over recent years. 
435.  Only 35.87% of the land is arable, of whic h only 23.32% is under permanent cultivation. 
Other available land covers 40.81% (2005). In addition there has been serious erosion of the soil and inadequate cultivation methods (lack of terrace farming, especially on Anjouan where the 
relief lends itself particularly to this method). Because firewood is the main source of energy for 
households, even in urban areas, the forests have  been under severe pressure in recent years, 
not helped by the natural growth in the population. Deforestation has remained fairly high despite 
some reforestation measures. 
436.  In response to the strong pressure on  the forest, the authorities promoted the use 
of kerosene through the zero rating of import taxes and sales of the product at a loss by the main 
State-owned company, offset until 2008 by margins on other petroleum products. Since 2008, 
in the wake of the international energy crisis, the State-owned company secured the recovery of all charges associated with kerosene transactions. This led to a slight increase in the product price, but it was still affordable to most of the population. 
437.  Despite many efforts to improve agricultural production, Comoros' domestic output is still 
unable to meet the population's needs. The country continues to be dependent on agricultural food 
imports, essentially rice, beef, goat meat and poultry, to fill the gap. 
438.  Agriculture plays an important role in the country's economy, accounting for 40% of the 
economy, or between 46% and 52% of GDP, and em ploying around two thirds of the workforce. 
The three agricultural export products supply 80% of the foreign exchange flows into the country. WT/ACC/COM/3 
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439.  The bulk of State intervention in agricultur e consists in general public services such as 
interventions to conserve natural resources, promote conditions conducive to modernization of the sector, publicity for techniques and promotion of better seeds to encourage the development of private initiative and subsectors. It is vital for LDCs to conserve their right to establish subsidy 
programmes in the future appropriate to the important subsectors of the agricultural sector, 
including export support measures in conformity with the relevant provisions of the WTO Agreement on Agriculture: Article 6(4)(b) and Article 9(4). 
440.  A further aim of State intervention is to favour the creation of the institutional conditions to 
facilitate economic activities in the sector, especially through the establishment of occupational streams to act as points of contact with the authorities and development partners. In support of domestic production, the State facilitates the import  of agricultural inputs, including by exempting 
such imports from customs duties and taxes. 
441.  The authorities also support the developm ent of the poultry subsector to improve food 
security by reducing imports. To help achieve that  end, in the absence of domestic production of 
feed, imports of feed products are zero-rated as a sectoral development support measure. 
442.  Rising temperatures combined with increased rainfall could accelerate the erosion process. 
The principal consequence is likely to be a fall in agricultural output. Less rainfall would also be 
likely to result in a fall in agricultural output. 
443.  Annual field crops are most exposed to climatic hazards because they have little or no tree 
or ground cover. This type of crop is currently  expanding on Moheli and Anjouan, reflecting the 
increased food requirements. 
444.  The intercropping system (agroforestry an d under natural forest) should provide better 
resistance to climate variation than monocropping or open field food cropping. 
445.  The small coastal plains where monocultures are found will be threatened by underground 
and surface salt water intrusion. The monoculture of coconut palm trees and ylang-ylang are found 
in the coastal plains, while clove and vanilla grow in the lowland areas. Given their economic importance, the global impact of any loss of earnings resulting from even a partial decrease in 
production and export would seriously damage the country's economy. 
446.  Comorian farms will also be prone to damage from the proliferation of plant diseases and 
pests that climate change will bring. The incidenc e of most plant diseases and pest breeding is 
stimulated by heavy rainfall and extended periods of drought. 
447.  Other factors of vulnerability of the Comorian farms are their small size (0.25 ha to 2.00 ha) 
and their poor equipment (mostly hoes and bush knives or machetes), which make them unable to adapt to change quickly. The use of agricultural in puts is very small and most food crops and crops 
for export are farmed without the use of any fertilizers or phytosanitary products. 
448.  Adaptation measures to cope with the adverse impacts of climate change on agricultural 
production relate to: (1) management of cultivat ed land; (2) management of soil fertility and 
combating plant diseases and agricultural pests; (3) using agrometeorologic information in 
agricultural calendars, and developing micro climates; (4) increasing agricultural production; (5) adopting suitable crop varieties; and (6) providing financial assistance to farms and promoting small rural irrigation by building a rainwater catchment basin. 
449.  Studies show that the supply of drinking water in the islands is currently insufficient to meet 
population needs, and will be further stretched between 2025 and 2050. Current demand is 28,600 m
3/day. It will be 46,498 m3/day in 2025 and 79,200 m3/day in 2050. If maintained at 
a constant, supply will be 6,501 m3/day. 
450.  Already scarce, water supply in Grande Comore and Moheli is threatened by the fragile 
equilibrium between fresh water/salt water, potential contamination of underground water by the 
septic tanks that are buried deep in the ground (Moheli); inadequate water pumps in 
Grande Comore; and the decrease in the amount and overall quality of ground water in Anjouan 
and Moheli. WT/ACC/COM/3 
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451.  Rising temperatures could bring an increase in evapotranspiration and negatively impact the 
underground water supply. The potential fall in underground water resources could result in the over-exploitation of coastal aquifers, especially in Grande Comore, and could easily undermine the fragile equilibrium between freshwater and saltwater. 
452.  Sea level rise could also co ntribute to the disequ ilibrium. The impact of tides on underground 
water results in change in water salt content. Specific sectoral adaptation strategies include various measures. 
453.  The Growth and Poverty Reduction Strategy Paper (GPRSP) includes specific actions to 
ensure better conservation of soils by expandin g terrace farming, building dikes along certain 
places in the coastal strip and by repopulating many slopes with trees. 
454.  Comoros is party to the bulk of international conventions on the environment: biodiversity, 
climate change, Kyoto Protocol on Climate Ch ange, Desertification, Endangered Species, 
Hazardous Chemicals, Law of the Sea, Protection of the Ozone Layer, Marine Pollution, and Coastal Protection. 
(a)  Imports 
455.  As mentioned in 3(c) above, the Union of the Comoros maintains a system of sanitary and 
phytosanitary controls. 
456.  However, because of limited institutional and human resource capacities, the system of 
controls at the borders is not efficient despite th e presence of dedicated services at the maritime 
ports and airport. The competent services do no t regularly draw up a list of prohibitions and 
restrictions on the import of plants, plant products and products that are harmful to life, or of 
products that are or may be carriers of organisms harmful to health. 
457.  Comoros has stepped up its bilateral cooperation with Tanzania and Madagascar, the 
principal countries of origin of agricultural imports, whether animal or plant based, to prevent 
certain confirmed sanitary and phytosanitary risks, particularly in relation to imports of live 
animals. 
458.  Under that framework the Government, acting on the precautionary principle may, by way of 
an absolute or relative prohibition, prohibit or restrict the import of animals, foods or products of 
animal origin on sanitary, phytosanitary and public health grounds. 
459.  Form WT/ACC/4 has been forwarded to the Mi nistry of Agriculture and Fisheries. It is 
envisaged that ACC/4 data will be complied and available for examination at the first Working 
Party meeting on the Union of the Comoros accession. 
(b)  Exports 460.  All Comorian exports are of agricultural origin and consist e ssentially of vanilla, clove and 
ylang-ylang essence. Even the minor exports are of  agricultural origin, including those bound for 
the island of Mayotte still under French administration. 
(c)  Export prohibitions and restrictions 
461.  There are measures to protect human, animal or plant health or life; the environment; 
and endangered species of animals and plants. 
462.  Chapter V incorporating Sections 1 and 2 of the Comoros Customs Code contains provisions 
on prohibitions, in particular under Articles 21 to 23. Article 21 covers prohibitions on imports and 
exports. It states that in applying the Code, "'prohibited goods' means (a) goods in respect 
of which, for whatever reason, authorization for importation or exportation is prohibited; and (b) goods which are subject to quality and packaging controls or specific procedures". 
463.  In accordance with the second and third subp aragraphs of that Article, the prohibition relates 
to goods that are not accompanied by a certificate of registration and to goods accompanied by an WT/ACC/COM/3 
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invalid certificate (licences or the like). It further states that all certificates authorizing import or 
export may not, under any circumstances, be collat eralized, sold, assigned or, in general, used in 
any kind of transaction by the nominal owners. 
(d)  Export credits, export credit  guarantees or insurance programmes 
464.  The Government of the Union of the Comoros envisages supporting exports through tools 
such as export credits, export credit guarantees or insurance programmes but has no such measures in place currently. 
(e)  Internal policies 
465.  The Government of the Union of the Comoro s allocates a significant share of the official 
development aid it receives to agriculture, especi ally with partners such as the European Union, 
the FAO and the IFAD. The Government of the Union of the Comoros has approached several of its 
partners for support and they have undertaken to provide enhanced aid in various sectors, 
including agriculture and fisheries. In 2007, the Arab Authority for Agricultural Investment and 
Development awarded a credit for KMF 2 billion to support agriculture. 
466.  In terms of internal policies, the authorities do not have the resources to provide direct 
support and therefore they provide for fiscal incentives including tax allowances, and a zero rate of tax on imports. The sums involved in these domestic support policies have not been estimated 
precisely and involve a very wide range of exemptions 
467.  The funds allocated to the sector cover agricultural extension and dissemination/distribution 
of inputs and seeds, research, market surveys and dissemination of information, conservation 
of natural resources and similar activities. 
5.  Policies affecting fore ign trade in other sectors 
468.  In 2008, the Union of the Comoros was certified as eligible for the apparel benefits under the 
African Growth and Opportunity Act, which allows preferential access for textile exports to the 
United States. It is also eligible for quota-free/duty-free access the Chinese market pursuant to 
the Memorandum of Understanding under the Strategic Partnership with Africa. 
469.  Within the framework of ACP/EC Cotono u Partnership Agreement of 2000, the Interim 
Economic Partnership Agreement and the future full EPA, products originating in the Union of the 
Comoros enjoy preferential treatment in the European Union market. Under the EPA, the 
Union of the Comoros has undertaken to gradually liberalize over fifteen (15) years 80% of its trade with the EC, free of quotas, quantitative restrictions and tariffs, with a list of sensitive 
products that account for only 20%. 
(a)  Textiles regime 470.  The textiles regime in no way affects export trade because the country does not have any 
industry in this area. However, the sector is regarded as offering a potential niche for 
diversification because of Comoros' comparative advantage in terms of labour cost factors over other countries in the subregion. The Union of the Comoros is a net importer of textile goods and 
does not provide any value added for export purposes. 
(b)  Policies affecting foreign trade in other major sectors 471.  The following products enjoy fiscal and other incentives: - Fisheries products 
 
472.  There are 427 km of coastline. There is sm all-scale and coastal fishing. The inshore grounds 
are fragile and overfished. Fishing techniques are primitive and not very diversified. 
473.  There are no trawlers or cold-storage facili ties that would enable industrial fishing to be 
conducted in some areas. Estimates put the number of vessels at 4,500, of which 1,500 are WT/ACC/COM/3 
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motorized. There has been a revival of interest among fishermen for pelagic fishing around the fish 
aggregating devices (FAD), thus developing small-scale deep-sea fishing. In 2002, fish production was estimated at 15,300 tonnes compared to 14,000 tonnes in 2001 and 13,200 tonnes in 2000. In addition to a short continental shelf (except on Moheli) where the fish are, the low power of 
vessels' engines (25 hp maximum) makes fishing very difficult and unproductive during the dry 
season. 
474.  The Islamic Federal Republic of the Como ros and then the Union of the Comoros reached 
agreements with the European Union on fishing rights in its exclusive economic zone. Quotas rose 
from 4,700 tonnes to 6,000 tonnes in 2006 for 17 longliners and 40 seiners. The resources in the zone are also plundered by foreign ocean-going vessels. Shipowners may not fish within ten nautical miles of each island or within a 3-mile radius of the FADs. 
475.  As a result, in 2004 the Comorian State was able to recover over €200,000, enabling it to 
modernize traditional fishing and help train fishermen, assist delegates from the Union to defend Comorian interests at various international fisheries organizations and to help in scientific research 
into fisheries and support for fishery surveilla nce bodies. Under the new agreement between the 
EU and the Union of the Comoros in 2005, financial compensation to the Comorian State was allocated as follows: €390,000 from the European Union and €210,000 from the shipowners. 
476.  Fish products accounted for 3% by weight of national exports in 2001, or about 234 tonnes, 
and their principal destination is the European Union. Exports amounted to 635 tonnes in 2006, with a value of US$1,228 million according to FAO data. 
477.  Fisheries received significant technical assistance between 1981 and 1985: there were 
five principal projects in the sector: Japanese projects (three JICA projects from 1981 to 1989), 
the African Development Bank project (1982 to 1985), the FAO projects (1986 and 1987), 
the small-scale fisheries projects by the Europe an Development Fund (EDF) (1987 to 1993) and 
the EDF funded " Assistance Thonière " projects (1988 to 1995). 
478.  There was almost no external aid for fi sheries between 1995 and 2002 when an FAO TCP 
set about recasting the legal framework and draw ing up an operational strategy for fisheries 
management (TCP/COI/202). The principal activiti es of the World Bank's Emergency Economic 
Recovery Credit Project (until 31 December 2002) include the installation of maritime security 
equipment on each of the three islands. 
Chart 10: Fish production in Comoros, 1950-2006 
 
Source: FAO Fishery Statistics. 
 WT/ACC/COM/3 
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479.  The above information from the FAO database shows the annual volume of aquatic species 
caught in Comoros for commercial, industrial, recreational and subsistence purposes over a period of almost 60 years. During that time, production rose from 1,000 tonnes to 16,000 tonnes, in line with the natural growth in population, and the catches under the main fisheries agreement with 
the EU. Meanwhile, illegal fishing continues in the country's territorial waters. 
V.  TRADE-RELATED INTELLECTUAL PROPERTY REGIME 1.  Overview 
(a)  Intellectual property policy 
480.  The Government considers the introduction of a national system of industrial property 
protection as one of the most important measures needed to promote profitable businesses. The Union of the Comoros accordingly acceded to the Convention Establishing the World 
Intellectual Property Organization by means of  instrument No. 163/MIREX of 22 December 2004. 
481.  This led the Union of the Comoros to deposit with WIPO the instruments of accession to the 
following conventions and treaties: 
- Paris Convention for the Protection of Industrial Property (1883), as revised at 
Brussels (1900), at Washington (1911), at The Hague (1925), at London (1934), at Lisbon (1958), and at Stockholm (1967), and as amended 1979; 
- Berne Convention; 
- Patent Cooperation Treaty (PCT), Washington, 1970, as amended in 1979, modified 
in 1984 and in 2001; 
- Protocol Relating to the Madrid Agreement adopted in 1989, entered into force in 1996 
(international registration of marks). 
 482.  The aim of joining the multilateral WIPO fram ework is not only to guarantee to national and 
foreign enterprises their rights concerning the issuance of certificates, registration of trademarks, 
patents, and industrial designs, but also to prepare the Union of the Comoros for the process 
of accession to other instruments on intellectual property, the Global Protection System 
and Classification, principally under other treaties. 
483.  The aim of government policy on copyright and related rights is to protect Comorian 
creativity and inventiveness, and to stimulate and promote the creation and production of intellectual works in the domains of literature, arts, and science. The accession of the Union 
of the Comoros to the African Intellectual Property Organization (OAPI) could help to strengthen 
the policy. Comoros has been a member of the OAPI since 2012. 
484.  It should be noted that the process of drafting  Comorian intellectual property legislation is in 
its infancy. Nonetheless, the foundations for that legislation are in place, namely: Law No. 64-1360 
of 31 December 1964, on Trademarks and Servic e Marks and its Implementing Decree No. 65-621 
of 27 July 1965, setting out measures to prevent abuse of IP rights, and the Law of 14 July 1909, 
on Designs and Models, detailing the methods for enforcing IP rights, and its Implementing Decree 
of 26 June 1911 on Industrial Designs and Models. 
485.  This body of texts, contained in Volume  2 of the Compendium of Laws and Regulations 
of Comoros, published by Presses Universitaires Aix Marseille , 1995, is the sole regulatory and 
legal framework in this field. It constitutes an integral part of the positive law inherited from the 
French colonial period and is affirmed in a post-independence national law upholding the full validity of laws and regulations that are not incompatible with the principles of national 
sovereignty, the fundamental rights and free doms guaranteed by the Constitution, and 
any successor laws and regulations, until such time as a new text is adopted. 
486.  It therefore makes sense to supplement the national legal and regulatory framework in line 
with accession to WIPO and the assistance it has provided in establishing national bodies in this 
area. Decree No. 10/173/PR of 26 November 2010 established the Comorian Intellectual Property 
Office (OCPI). Its role is to make findings on industrial and commercial property, copyright and related rights. However, OCPI is encountering serious difficulties in becoming operational and the WT/ACC/COM/3 
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Union of the Comoros is requesting technical assistance to that end from relevant bodies, including 
the World Intellectual Property Organization. 
(b)  Agencies responsible for polic y formulation and implementation 
- Industrial property 
 
487.  The ministerial department with responsibility for industry proposes and implements government policy on industrial property matte rs. Under Decree No. 99-086/PR of 22 July 1999 
repealing Decree 96-176/PR, the national director ate for industry attached to the ministerial 
department is responsible for: 
- establishing an environment conducive to the creation and development of industries; 
- fostering the creation of favourable conditions for the development of industrial 
enterprises, local and foreign investment, integration of the country's industry into the 
activities of the various sectors of the Comorian economy; 
- establishing links between the various indu strial projects for economic development 
and funding bodies; 
- overseeing product standardization and promoting product features; - providing industrial and technological information, and promoting technological 
innovation, invention and creation (patents, licences, industrial designs and models, 
etc.); 
- designing training programmes and refresher courses for staff; - designing and supporting sustainable industrial, economic and commercial 
development in cooperation with other relevant departments through industrial 
development and public welfare. 
 
488.  Since the accession of Comoros to WIPO and with a view to the country's accession to the 
WTO, the directorate has focused on: 
- supporting the Government in negotiations with the two international reference 
organizations that address industrial property matters; and 
- ensuring the registration, granting and prot ection of industrial property rights and 
ensuring compliance with the legislation in force. 
 
489.  It should be noted that because of the fail ure to implement the laws and regulations in this 
area, no trademarks, geographical indications, indu strial designs or patents have been registered 
since independence. An industrial property rights registration, granting and protection service has 
been set up with major involvement by national stakeholders. Generally, the need for registration 
and protection is huge both nationally and internationally in view of the level of fraud and counterfeiting. 
490.  Decree No. 10/173/PR of 26 November 2010 establishing the Comorian Intellectual Property 
Office (OCPI) incorporated a Copyright and Related Rights Division into the Office. The role of OCPI, a government body attached to the Ministries  of Culture and Industry, and the focal point in 
relation to WIPO, includes responsibility for monitoring compliance with legislation on copyright 
and related rights in the Union of the Comoros. 
491.  Its duties are as follows: 
- to propose, coordinate and implement policie s on culture, protection of copyright and 
artistic creativity, genetic markers and folklore; 
- coordinate policy on matters relating to underwater heritage and marine 
archaeological research, the conservation and restoration of public property (in 
coordination with the relevant department); and 
- manage assistance programmes with the United Nations Organization for Education, 
Science, and Culture, and other international organizations specializing in culture (in coordination with the Ministry of Foreign Affairs, Cooperation, and the Diaspora). 
 WT/ACC/COM/3 
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492.  The Minister responsible for Culture oversees several institutions including the National 
Centre for Scientific Research and Documentation and the National Institute for Research incorporating the National Museum of Comoros and the National Archives. 
(c)  Membership of international intellectua l property conventions and of regional or 
bilateral agreements 
493.  The Union of the Comoros has been a member of WIPO since 22 December 2004 and has 
actively participated in WIPO activities, first as  an observer and subsequently as a full member, 
especially in activities held in Geneva and regionally in conjunction with COMESA. 
494.  The Union of the Comoros is not party to any regional or bilateral agreement on industrial 
property but has received training delivered by the French Association on Standardization in the framework of the country's bilateral cooperation with France. 
495.  Concerning copyright and related rights, the Union of the Comoros became a party to the 
Berne Convention in 2004 and intends to accede to the Rome Convention in the near future. 
(d)  Application of national and MFN treatment to foreign nationals 
496.  Article 1 of the Decree implementing Law No. 64-1360 of 13 December 1964 on Trademarks 
and Service Marks provides that natural or legal persons resident or with headquarters or industrial or commercial premises in the Union of the Comoros must register their trademarks or 
service marks either with the Institute or the Registry of the Commercial Court or, where none 
exists, the court of major jurisdiction, in the di strict where their residence or headquarters is 
located. Natural or legal persons that do not satisfy that condition must deposit their trademarks or service marks with the Institute by registering a Comorian address. 
497.  The matter of a registered address is not discriminatory in itself. The rules provide equal 
treatment to all persons subject to the sole legal condition of a registered address in the territory under a national procedure. Accession to WIPO an d the adoption of its principal instruments will 
take precedence over that clause. Regarding foreign nationals, the reciprocity regime applies in 
the framework of bilateral relations with other countries. 
498.  The pending legislation on industrial pr operty will provide for equal rights for all 
beneficiaries, whether national citizens by birth or  foreign citizens, as specified in the Investment 
Code. It will also reflect one of the principles of the Paris Convention, to which the Union of the Comoros acceded in 2004. 
499.  With respect to copyright and related rights, Comorian law in force does not permit 
discriminatory treatment on the ground of the right holder's nationality, nor does it permit special 
treatment for the citizens of any particular country. 
(e)  Fees and charges 
500.  Fees and charges on industrial property ar e not subject to any implementing text and are 
a priority in the establishment of an adequate legal and institutional framework that complies with international commitments and the national objectives to promote the country's economy and 
industry, especially with regard to attracting investment. 
501.  The Government is aware of the need to have such a framework as a foundation for the fees 
and charges applicable to intellectual property in the broad sense and to apply more appropriate legislation and regulations. A decree having the force of law will rapidly plug the void and allow the 
adoption of further texts. By way of illustration, the first fees and charges could enter into force 
under the Finance Law following formal accession to the WTO. WT/ACC/COM/3 
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2.  Substantive standards of protection 
(a)  Copyright and related rights 502.  Books II and III of the Intellectual Property  Code inherited from the French colonial 
administration provide for copyright, related ri ghts and associated general provisions. The law 
enacting the Code encompasses all the aspects and parameters identified in international 
conventions on copyright and related rights matters. 
503.  In general, copyright holders, in the areas of literature, arts or science, are guaranteed legal 
protection against any type of unauthorized use. Pr operty rights are inalienable, and Comorian law 
provides that an author is to enjoy the exclusive right for life to exploit his artistic work in any form whatsoever and to obtain monetary advantage therefrom. 
504.  Article L.123.1 provides that upon the author's death his successors will continue to enjoy 
that right for the remainder of the calendar year of the death and the 70 years that follow. 
(b)  Trademarks 505.  Provisions on the registration process and the mechanisms for protecting trademarks are set 
out in the Industrial Property Code (Book VII of the Code, Chapters I to VII). Under the Code, 
anyone who adopts a trademark to distinguish his/her business product shall be entitled to the exclusive use of the mark for as long as s/he complies with all legal requirements, particularly with 
respect to registration. 
506.  Under the Code (Article L.712.2), ownership of a trademark is acquired through registration. 
A trademark may be acquired in co-ownership. The term of registration is ten years from the date of application, renewable indefinitely. 
507.  A foreigner wishing to register a trademark must make an application to the OCPI. 
The application must be drawn up in one of the country's official languages (Comoran, Arabic or French) on the specified form and must be a ccompanied by the documents set out in the Code 
and its implementing legislation. Following submission of the application, a notice is published in 
the appropriate Bulletin to allow objections from  anyone who may be adversely affected in the 
event of approval of the application. The time-limit for the submission of objections is 60 days 
calculated from the date of publication of the notice in the Bulletin. 
508.  Upon expiry of the time-limit for the submission of objections, the competent institution 
examines the application essentially by comparing the trademark in respect of which the application was made and those already register ed. Upon completion of that examination, 
the outcome is published and the application is pr ocessed. Registration of the trademark confers 
ownership rights on the holder for the designated products and services. 
(c)  Geographical indications 
509.  A single section of Title II of the Code and Chapters I and II provides for geographical 
indications. The definition is as follows: "Appellation of origin is the name of a country, region or locality used to designate a product originating th erein, the quality and characteristics of which are 
due to the geographical environment, including natural and human factors". 
510.  Registered right holders are guaranteed protection for appellations of origin under the 
provisions of the Industrial Property Code and ma y bring civil actions before the district courts. 
(d)  Industrial designs 
511.  The process of registration and protection of industrial designs is the subject of Book V of the 
Code. The filing of an application for industrial designs must be submitted alongside the required 
items. Following submission of an application as prescribed a notice is published in the appropriate 
Bulletin indicating the object, utility and novelty of the industrial design for which registration is 
sought. This allows persons who may be adversely affected by the granting of registration to express their objections. The time-limit for submission of objections is 60 days calculated from the WT/ACC/COM/3 
- 71 - 
date of publication in the Bulletin. Upon expiry of the time-limit, in the absence of any objections, 
the application is duly examined, documented and processed. 
512.  Registration of a design or model confers upon the right holder a monopoly of exploitation 
for a maximum period of 25 years. 
513.  The term of registration is five years from the date of application, renewable for periods of 
five years up to a maximum of 25 years. 
(e)  Patents 
514.  Book VI, Title 1, Chapters I to VII of the Co de deal with patents. The filing and instructions 
for applications for patent registration and protection are the subject of Chapter II. The request for patent must be made in an application, accompanied by the elements indicated in Articles R612-1 to R612-25 of the Code. When the inventor or his legal representative files 
a patent application, he receives a receip t for submission of a patent application. 
515.  Once filed, the application is considered by the competent departments to decide whether to 
prohibit disclosure and exploitation. Authorization is acquired automatically in the event that the 
authorities fail to reply within five months of the application. 
(f)  Plant variety protection 516.  The Code makes no reference to this new area. It is envisaged that it will be the subject of 
a regulatory text pursuant to the Law introducing the Code. 
(g)  Layout-designs of integrated circuits 517.  The existing version of the Code makes no reference to this area. The recently amended 
French version takes it into account. Comoros should be guided by it and adopt regulations to 
supplement the intellectual property machiner y in respect of technological developments. 
(h)  Requirements on undisclosed information 518.  The Code in force does not include any specific provision on business secrets or test data. 
However the legal framework contains provisions for penalties against unlawful access to secrets. 
For example, that protection is provided for in conformity with the general provisions of the Penal Code which refers to offences involving theft, in particular Article L.331-1 by way of taking 
by fraud . 
519.  In practice, unlike patents, business secrets are protected without the need for registration, 
in other words protection of business secrets is not subject to formal procedures. Consequently a business secret can be protected for an indefinite period of time (for as long as it is undisclosed). 
Additionally, the protection does not (or may not) involve any cost. 
520.  Moreover, the WTO legal framework of reference in the subject, in particular Article 39 of the 
TRIPS Agreement will help to supplement the nati onal legal framework, as it does for other 
Members. The relevant multilateral framework that will become an integral part of national positive 
law once accession has occurred sets out some guidelines for the application of measures protecting the secrecy of "undisclosed information": 
(a) the information must be secret in the sense that it is not, as a body or in the precise 
configuration and assembly of its components, generally known among or readily accessible to persons within the circles that normally deal with the kind of information in question; 
(b) the information must have commercial value because it is secret; and 
(c) the information must have been subject to reasonable steps under the circumstances, 
by the person lawfully in control of the information, to keep it secret. 
 WT/ACC/COM/3 
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(i)  All other categories of intellectual property 
521.  The Code on Intellectual Property in force in Comoros does not cover the following categories 
of industrial property: 
- genetic resources; 
- traditional knowledge and folklore. 
 522.  The category "genetic resources" is not covere d by the legislation in force in the Union of the 
Comoros on intellectual property because it has only recently emerged as an issue. It is among the 
new issues facing the world and is also one of the major trade concerns on which WIPO has made efforts to establish an operational legal framework that has regard to the concerns that have emerged as a result of developments in science and technology. 
523.  The national programme to adjust the legal intellectual property framework subsequent to 
accession to WIPO and the WTO will necessarily have regard to this new category in order to provide protection to the genetic resources of  local biodiversity, where there are a number 
of endemic varieties that are evidently of scientific and commercial interest. The Union of the 
Comoros awaits the conclusions of the work to formulate the model clauses for contractual arrangements granting access to genetic resources and the distribution of the resulting benefits. 
524.  The category "traditional knowledge and folklore" is not covered either and is also among the 
new issues facing the world that are at the heart of  WIPO's work to provide answers to the parties' 
many complaints on this matter. 
525.  However, in the light of the work done by WIPO in the field, status reports on traditional 
knowledge and folklore drawn up on the basis of factual data provided by States show that the 
traditional intellectual property system can to a certain extent support those forms of knowledge that are the product of peoples' inventiv eness and therefore in the public domain. 
526.  Work to define the components of traditional knowledge that may be protected by 
i n t e l l e c t u a l  r i g h t s  i s  u n d e r  w a y  a t  W I P O  a n d  w i l l  i n  t i m e  e n a b l e  t h e m  t o  b e c o m e  p a r t  o f  t h e  positive law of the country concerned, either as a party to any arrangements on the matter or 
through the adoption of domestic legislative and/or regulatory provisions while maintaining 
compatibility with the WIPO multilateral contractual framework. 
527.  The idea and objective is to incorporate them into the state of the art research conducted 
prior to the granting of a patent. This would be a valuable contribution to addressing the 
complaints triggered by the granting of patents for subject matter that is part of traditional 
knowledge. 
3.  Measures to control misuse of intellectual property rights 
- Industrial property 
 528.  Measures in this area are contained specifical ly in Titles I to VII of the Industrial Property 
Code under the heading "Disputes". Chapters I to VI of Title III relate to procedures and penalties. 
529.  Criminal provisions are set out in Chapter V; they confer upon criminal investigation officers 
and upon property rights holders or their profe ssional bodies the capacity to bring proceedings; 
they further provide for the legal channels to protect those rights and obtain a ruling on offences 
including counterfeiting, which is the subject of a preventative provision (Chapter VI). 
- Copyright and related rights 
 
530.  The measures are an integral part of the Books on these rights and consist in general 
provisions (Book, Chapter I, Articles L.131-1 to  L.131-8), and provisions peculiar to certain 
contracts (Articles L.132-1 to L.132-34). Sections 1 to 5 of Chapter II provide for specific 
protection for publishing contracts, audiovisual productions, advertising commissions and pledge 
of the right to operate software. WT/ACC/COM/3 
- 73 - 
531.  Title II of Book I on copyright contains th ree chapters on economic and moral rights and 
term of protection (exclusive right for 70 years). 
4.  Enforcement (a)  Civil judicial pr ocedures and remedies 
532.  The Intellectual Property Code on copyrigh t and subsequent regulations state that civil 
liability in the event of violation of the rights provided for in the law is not dependent on the 
bringing of criminal proceedings against the cause of the infringement and may therefore give rise 
to separate civil and criminal procedures inter alia  in respect of seizure for counterfeiting, 
attachment and resale royalties. The procedures are initiated by the commissaires de police  (police 
superintendents) and examining judges in response  to a complaint by the author or any right 
holder or successor in title. The criminal law provides for three years' imprisonment, along with a 
fine of up to several million Comorian francs, fo r the offence of counterfeiting as duly determined 
by the competent judiciary police officer. 
(b)  Provisional measures 
533.  The legislation in force in the Union of the Comoros, including that on industrial property, 
includes all the safeguards provided for all types of  property in general and industrial property in 
particular. The legislation in force includes measures to combat unfair competition and other acts 
that may prejudice the establishment, products, serv ices or reputation of competitors. The illicit 
appropriation, use or disclosure of business secrets constitute industrial property offences and are 
punishable under the legislation in force. 
534.  The draft new Code must provide for offences infringing intellectual property in the broad 
sense, and include measures duly tailored to the country's situation. It will have regard to 
developments in behaviour and the extent and freque ncy of offences that were not included in the 
current legislative framework. 
(c)  Administrative pr ocedures and remedies 
535.  Since the intellectual property-related services  sector is not operational in the Union of the 
Comoros and the country's institutional capabilities and human capital are poor, no administrative 
procedures or remedies have been implemented. However, the judicial services, the police and the 
gendarmerie have responsibility for the protection  of private property and ensure compliance with 
that principle by enforcing the law through the courts. The new law on intellectual property will deal with all aspects of this matter. 
(d)  Special border measures 
536.  The Industrial Property Code does not prov ide for any special border measures to prevent 
entry into the local market of counterfeit products or products that violate the principles 
of industrial property protection. The customs serv ice will need to receive training or advice to 
identify the relevant legal provisions in this field. 
537.  The law in force in the Union of the Comoro s authorizes the imposition of penalties against 
anyone who imports, sells (or puts on sale by an y means) or distributes to the public any copied 
or counterfeit work whether the product was prepared in the country or abroad (see Book III, Chapters I to VI of the Code for the penalties that apply). 
538.  Coordination between Customs and the Mini stry of Industry will have to increase. 
By contrast, generic pharmaceutical products are subject to rigorous controls; they can be 
marketed only after the central pharmacy has checked them. 
(e)  Criminal procedures 
- Industrial property 
  See section 5(b) above. WT/ACC/COM/3 
- 74 - 
 
- Copyright and related rights  539.  The counterfeiting or copying of protected works are punishable offences, thus the courts 
may act in response to a formal complaint. In the event of infringement, the Law on Copyright 
provides for confiscation and the purchaser may be  ordered to pay damages to the person entitled 
to resale royalties. 
5.  Laws, decrees, regulations and other legal instruments relating to the above 
- Industrial property 
 
• Decree No. 65-621 of 27 July 1965 implementing Law No. 64-1360 
of 31 December 1964 on Trademarks and Service Marks, as amended by the Law 
of 23 June 1965; 
• Paris Convention for the Protection of Industrial Property of 20 March 1883, 
as amended; 
• Madrid Agreement Concerning the International Registration of Marks 
of 14 April 1891, as amended. 
 
- Copyright and related rights  
• Law No. 57-298 of 11 March 1957 on literary and artistic property; 
• Copyright and related rights are governed by  Books I to III of the Intellectual Property 
Code; 
• Decree No. 95-385 of 10 April 1995 on the regu latory part of the Intellectual Property 
Code; 
• Decree No. 58-446 of 19 April 1958 implementing Law No. 57-298 of 11 March 1957 
on literary and artistic property; 
• Decree No. 58-447 of 19 April 1958 implementing Law No. 57-298 of 11 March 1957 
on literary and artistic property; 
• Decree No. 65-464 of 10 June 1965 on the choice of experts in patent disputes; • Articles 1 to 3 of Decree No. 67-181 of 6 March 1967 implementing Law No. 64-689 
of 8 July 1964 on the application of the princi ple of reciprocity in matters of copyright 
protection; 
• Decree No. 69-190 of 15 February 1969 on the seizure for counterfeiting procedure in 
matters relating to patents; 
• Decree No. 69-975 of 18 October 1969 on compulsory licences, automatic licences, 
the expropriation of inventions and various procedural provisions. 
 
6.  Statistical data on applications for and the granting of intellectual property rights, 
as well as any statistical data on IPR enforcement 
540.  There are no statistical data available; the Intellectual Property Code has not been 
implemented even though it formally exists as a legacy of colonial positive law. 
VI.  TRADE-RELATED SERVICES REGIME 1.  Overview 
541.  This section provides an overall descripti on of the general market and the regulatory 
structures in the principal service sectors. Document W/120 is an official WTO document 
classifying the services covered by the General Ag reement on Trade in Services (GATS) using the 
Central Product Classification nomenclature (CPC) drawn up by the United Nations. This paragraph 
gives the impression that it relates to a list classifying the service sectors in Comoros. 
542.  Services form one of the largest sectors of  the Comorian economy and are highly illustrative 
of the developments in the country's macroeconomic structure over recent years. During the first 
ten years of the 2000s the sector accounted for 74.5% of GDP (2003). WT/ACC/COM/3 
- 75 - 
543.  The Government's strategy for growth in this sector has been to privatize many of the 
service providers and to open the market to free and fair competition. Foreign investment in Comoros' services market is an integral part of that strategy. Pursuant to the new Foreign Investment Law adopted and enacted in September 2007, foreigners may invest in and work in 
nearly every service sector. 
544.  The five most significant service sectors are telecommunications, construction and civil 
engineering, tourism and related services, transport, and financial services. A description of these 
sectors is provided below." 
Table 14: Distribution of econom ic activity by sector in 2008 
Distribution of economic activity by sector Agriculture Industry Services 
Value added (as a % of GDP) 47.0 12.3 38.0 
Value added (annual growth, %) 3.0 3.0 14.6 
Table 15: Contribution of services to GDP, 2003-2011 
Breakdown of services 
contribution to GDP 2003 2004 2005 2006 2007 2008 2009 2010 2011 Contrib. 
as % of 
GDP 
Electricity, gas, and water 2146 2,262 2,333 2,486 2,676 2,495 2,630 3,027 3,158 +0.10 
Construction and public works 8411 8,862 9,143 9,741 8,639 9,696 10,220 9,942 10,373 +0.20 
Commerce, restaurants and hotels 35,417 37,317 38,500 41,016 45,830 54,068 48,095 54,153 56,501 +1.10 
Banks, insurance, real estate business and services to 
enterprises 6,225 6,559 6,767 7,209 6,882 7,524 7,930 12,552 13,096 +0.30 
Transport and telecommunications 7,139 7,522 7,761 8,268 8,352 8,154 8,594 9,062 9,455 +0.20 
Government 19,264 20,297 20,940 22,309 22,534 21,301 22,451 24,372 25,429 +0.50 
Other services 743 783 807 860 869 896 944 994 1,037 +0.00 
(Less) imputed banking output (3,595) (3,788)  (3,908)  (4,164)  (4,206)  (4,346)  (4,580)  (5,321) (5,552) -0.10 
Source: Central Bank of Comoros. 
 
545.  The data from the World Bank and the International Monetary Fund, and the Central Bank of 
Comoros, respectively, in the two tables above show different figures for the services contribution 
to GDP. The plus differences in the BCC data are due to the fact that the BCC includes government services and imputed banking output when drawing up the national accounts. 
- Telecommunications services 
 
546.  The telecommunications services sector is growing, especially mobile network services. In 2012, Comores Telecom had a fixed telephony network with 20,000 subscribers, a prepayment 
card platform for the fixed network (Nafassi), an internet hub of 4,000 subscribers, including 
300 ADSL subscribers, and a GSM mobile network (HURI) with 300,000 subscribers. The introduction of a 3G network in 2013 will help to promote broadband in the country. 
547.  In terms of human resources, at 31 December 2012, Comores Telecom had a total staff 
of 1,400. 
548.  All fixed and mobile telephony services have seen an explosion in demand. This has 
prompted the principal public operator in the sector to make significant investments: introduction 
of a "CDMA" wireless network, fibreoptic wiring of the three islands and interconnection using the 
international undersea fibreoptic network EASSy (E astern African Submarine System) as part of a 
fibreoptics project to connect countries in Eastern Africa, including the Indian Ocean. Teledensity 
in Comoros has grown significantly from 0.72% in 1995 to 0.90% in 1998 and 4.5% in 2005. 
At 31 December 2012, teledensity was 42% (fixed and mobile). The launch in 2007 of the EASSy project (9,900 km, 320 to 640 Gbps exploitable over 25 years) offers the prospect of extending 
and enhancing the wired network in the Southern and Eastern African region along an axis that 
extends from South Africa to Sudan, including the Union of the Comoros. WT/ACC/COM/3 
- 76 - 
549.  There is just one provider of telecommuni cations services on the local market: Comores 
Telecom S.A., providing a range of services including fixed and cellular telephony, telegraph and prepayment card services, as well as electronic and internet services. Comores Telecom S.A. is a public enterprise that emerged from the separation of telecommunications, postal and financial 
services supplied by the former national posts and telecommunications company. The State holds 
the entire share capital of KMF 600 million. 
550.  The Ministry responsible for telecommunications is currently in charge of regulating all 
telecommunications activities in the Union of the Comoros. Decree No. 065/PR of 23 June 2009 
implementing ICT Law No. 007/AU of 15 January 2008 established the National Information and 
Communications Technologies Regulatory Authority (ANRTIC) after the sector was opened to competition. 
551.  Most importantly, the Ministry has responsibility for policy in a sector whose strategic thrusts 
include the establishment of a regulatory framew ork for its development. Moreover, the sectoral 
policy statement of 2012 for the period ending in 2015 advocates the development of 
communications infrastructures and its use in applications such as electronic administration, 
telemedicine, distance learning, e-commerce and cyber security. 
552.  Furthermore, between 2012 and 2017, the Union of the Comoros will receive US$22 million 
in funding from the World Bank as part of the Regional Communications Infrastructure Program, 
Phase 4 (RCIP 4). The funding will go to establishing a second international submarine cable connection, creating an environment conducive to development of the sector, supporting sectoral reforms and stimulating demand for broadband capa city. Technical, legal and economic work is 
under way with a view to privatizing the historic operator and updating the regulatory framework. 
553.  Additionally, work is currently proceeding to migrate to digital broadcasting by 2015. 554.  Finally, the Union of the Comoros fully endorses the World Summit on the Information 
Society (WSIS) Agenda; and the WTO recommendations on basic telecommunications is one of the 
reference documents underpinning the current rest ructuring process under way in this sector. 
555.  Under Article 11 of Organic Law No. 05-003/AU of 1 March 2005 on the implementing 
procedures for Article 9 of the Constitution on posts and telecommunications: "the Union shall 
organize the regulatory structure and establish th e general approach to the development of posts 
and telecommunications while ensuring a balanced geographical spread of services. The Islands shall take individual decisions and shall determin e the implementing procedures that fall within 
their purview in line with population needs. The Union, in cooperation with the Islands, shall 
contribute to equipping the Islands in posts and telecommunications matters. The Union and the Islands have joint technical, administrative and financial liability for the public companies in these 
fields. The laws on those companies sh all be adjusted to that effect". 
- Construction and related engineering services 
 
556.  The construction and related engineering serv ices sector used to be heavily dependent on 
the State, but the State has gradually withdrawn in favour of private players under the first IMF structural adjustment programme. Today all public works (roads, buildings and others) that were traditionally carried out by the State are conducted by private enterprises that have emerged or 
consolidated their initial subcontracting position. 
557.  This trend in terms of direct government intervention in the sector reflects a refocusing of 
State functions: regulation of activities in the fields of construction, supervision, control of 
performance of public contracts and related standards. 
558.  The construction sector is booming in Comoros through a network of SMEs. The Entreprise 
Générale de Terrassement (EGT) is the sector's largest employer, providing over 400 jobs. It 
specializes in terracing, road-building, crushing  and supply of granulates, brick making and 
construction in direct calls for tender by the Government or as part of projects financed by the development partners. Four other slightly smaller enterprises have also positioned themselves in the same niche. In road building, however, only two other competitors have offered their services 
recently (CBE and Ets A.WADAANE). WT/ACC/COM/3 
- 77 - 
559.  There is little reliable information available on the construction sector. However, as part 
of the process of drawing up the national accounts,  a task which falls both to the Office of the 
Commissioner for the Plan and the BCC (the latter in particular in relation to the balance of payments) and as part of a plan to enhance statis tical services, the Government is making efforts 
to collate information and establish a database that covers all activities. 
560.  The Urban Development Commission, an administrative body empowered to issue 
construction permits on the island for which it is responsible is answerable to the 
Ministry of Infrastructure and Transport. It is responsible for enforcing the law and regulations on 
construction activities in the Union of the Co moros. It issues the necessary authorizations 
and coordinates urban development and region al planning policy. There are three other 
governmental bodies in the sector and they also  are answerable to the Ministry responsible for 
infrastructure: the Infrastructure General Directorate, the Transport General Directorate, and the 
National Public Works Laboratory. There is a trade association for construction enterprises within the two major private sector confederations: the Comoros Employers' Organization and 
the Comoros Private Sector Federation. 
561.  The principal legislation in the sector is as follows: 
- Law No. 86-017/AF enacted in 1997 on the Urban Planning and Habitat Code; 
- Decree No. 05-077/PR of 1 August 2005 on the Government Procurement Code; 
- Law No. 07-010/AU of 31 August 2007 on the Investment Code; - Uniform Acts of the OHADA, including the provisions on companies. 
 
562.  The responsible Ministry has revised the Ur ban Planning and Construction Code to improve 
the legal framework underpinning the sector. It was adopted by parliament in December 2011 and enacted in February 2012. The previous document had proved to be too complex and difficult to 
implement. A study of it was commissioned. Conducted by a specialist international firm, the aim 
of the study was to formulate a plan that would: 
 Contribute to a revision of the document with the support of the various technical 
services involved; 
 Apply measures using simple public awareness-raising and communication campaigns 
to facilitate their implementation; 
 Adopt measures better suited to the socioeconomic and cultural realities of Comoros. 
 
 The study consisted of four phases:  
Phase 1: Diagnostic study – Critical  analysis of the Code in force. 
Phase 2: Consultation with local decision make rs and meetings on the ground with working 
groups. 
Phase 3: Formulation and drafting of institutional rules and definition of the general framework 
for potential buildability. 
Phase 4: Drafting and editing of the applicable regulations based on the basic planning, 
regulation and authorization rules. 
 
563.  This Code is a significant effort at sectoral reform that will have to be pursued in the context of WTO accession and the EPA by way of comprehensive legal and technical assistance to adjust 
the national legal framework. 
564.  In conformity with the existing regulations, foreign enterprises that establish an office in the 
Union of the Comoros have full access to the construction market and are subject to the same laws 
and regulations as local enterprises. 
- Tourism and related travel services 
 565.  Tourism is one of Comoros' most important service sectors and alongside fisheries and 
agribusiness is named as one of the engines for future growth in the Strategic Framework for 
Growth and Poverty Reduction (SCLP). A high priority for the development of the country 
as a whole, development in this sector has not mirrored that of neighbouring countries in the 
Indian Ocean, despite its confirmed assets and potential. Although tourism has been the main 
sector of economic growth and development for ne ighbouring islands over the last two years, its WT/ACC/COM/3 
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development has experienced a marked decline, reflecting the political and institutional instability 
that has adversely affected existing investment and dissuaded potential investors. Neighbouring 
islands' performance in this sector has grown almost threefold in 20 years from just over 800,000 arrivals in the 1990s to close to two million today. 
566.  According to the available statistical data, demand for tourism stood at 19,551 arrivals 
in 2005, a 37% leap on 2003. However, a comparison with the figure for 1998, when there were 27,474 visitors, is illustrative of the gradual decline that the country was to undergo. The 
closure of the Galawa resort, the country's largest, was a decisive factor. The resort had managed 
to diversify tourist clientele, who were from South Africa (38% of arrivals in 2000), Europe (mainly France, Germany, Great Britain and Italy) and the United States. The closure changed the structure of arrivals. 
567.  Today around 50% of tourists are from metropolitan France. Almost as significant is local 
tourism: 40% of tourism arrivals in 2005 were from the islands of Réunion, Mayotte and Madagascar. The trend is particularly striking in the case of tourists from Réunion, and arrivals 
from the island doubled between 2000 and 2005. Maur itius is not part of the trend, accounting for 
less than 1% of tourist arrivals in 2005. 
568.  Reasons for visiting have changed sharply si nce the closure of Galawa. Although leisure and 
relaxation tourism accounted for close to 55% of visits in 2000, that proportion has fallen since 
2005 to around only 14%. By contrast, the share of family tourism, generally visits by the 
diaspora's descendants, has undergone a 65% increase in arrivals to become the mainstay of the sector. Following the same trend, business travellers have doubled over the same period, 
reflecting the country's new attractiveness to business in a dynamic of exploration and increased 
contacts that has benefited the sector. 
569.  The contribution of the sector to GDP is estimated at less than 3% (compared to 2.2% 
in 1996) and, at 880 beds, hotel capacity is fairly low compared to that of the neighbouring islands 
of Mauritius and Seychelles, which have 11,000 and 4,000 respectively. However, real progress is demonstrated by the increase in the number of beds from 350 in 1986 to 880 at the end 
of the 1990s, following investment of around KMF 12 billion over that period, principally from 
abroad. 
570.  Revenue from the sector was US$12 million in 2000, compared to US$6.8 million in 2004, an 
enormous fall of 42% in a short period. The sector  generates over a thousand direct jobs and more 
in associated indirect employment. As a cross-cutting sector, it has an impact on directly related 
sectors such as transport, accommodation and catering, agencies, commerce, agriculture, handicrafts and telecommunications. 
571.  The services provided are varied and include incoming services, accommodation and 
catering, travel agencies, tour guides, transport,  sport and excursions. There are around 30 travel 
and tourism agencies, and the two principal ones  are subsidiaries of the Mauritian companies 
ARI Maurice Limited  and Maurice Tourisme Services ; there are 17 hotels and establishments 
offering accommodation distributed unevenly across the three islands. Dozens of guest houses have sprung up in response to demand from certai n categories of visitor. The job of tour guide has 
emerged and there are around 50 practitioners. 
572.  Over recent years the Government has encouraged the development of the tourist industry 
in Comoros. This was reflected in the assignment sale of the Galawa complex with over 200 rooms to the Emirati Group Dubai World . The Itsandra Hotel, taken over by private Kuwaiti interests in 
the Comoros Gulf Holdings  company, reopened in 2008 following renovations costing US$2.2 
million that raised it from a three-star to a four-star classification with 22 rooms and 12 villas, including six suites, and two restaurants capable of catering for up to 380 people. 
573.  The Comorian Government has signed a contract with the Qatari company Retaj Marketing 
and Project Management to take over Hotel Le Moroni in exchange for an investment of at least US$10 million. 
574.  However, there are a number of constraints on growth, particularly in relation to inadequate 
communication infrastructure (roads), the limited availability of energy and a regular supply of WT/ACC/COM/3 
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drinking water; furthermore, the cost of overco ming them is deemed high. The authorities are 
endeavouring to work through these issues, convinced that they are key to accelerating the attractiveness of the sector to investment. Public investment in tourism is under way in connection with these priority projects and their contracted  promoters. The situation is similar in related 
sectors such as telecommunications and energy. 
575.  The other barrier to the sector's success is transport links. The authorities have approved 
investment to improve security in the air and on the ground with high-performance equipment 
financed by the French Development Agency and aw ard of the concession for air navigation safety 
to ASECNA. All current promoters in the sector have undertaken to promote balanced development of the sector across the islands by providing appropriate services to tourists on the other islands. This entails including the development of inter-island transport infrastructure in promoters' public 
investment-related plans. 
576.  It should be noted that tourism enterprises are also adversely affected by a limited market, 
an obsolete intra-island transport network, and an underdeveloped, inadequate inter-island 
transport network, and staff in need of extensive professional training. 
Table 16: Trends in the tourism sector  of Comoros - Principal indicators 
 2002 2003 2004  2005  2006  2007  2008  2009 2010 2011  
Tourism revenue in 
(KMF million)* 33,000 35,417 37,317 38,120 42,361 45,830 54,068 48,095 54,153 56,501 
Contribution to GDP 
(%) 25.6 25.6 25.6 25.3 26.6 27.6 30.9 26.1 27.5 27.5 
Contribution to the 
services sector (%) 54.3 54.3 54.3 53.8 56.1 57.1 61.7 57.6 56.5 56.5 
Source: Central Bank of Comoros. 
* These figures comprise activities classified as "commerce" included as a matter of course under the generic heading "services in commerce, accommodation and catering " in the national accounts drawn up by the Central 
Bank of Comoros. 
 
577.  The Government offers various incentives to help overcome certain obstacles to growth in 
a limited domestic market. Through the new Nati onal Investment Promotion Agency (ANPI), the 
ministerial department in charge of investment, which has responsibility for developing tourism, administers incentives policies and instruments. Foreign nationals who wish to invest in or run 
tourism projects must first obtain investor status from the ANPI under its investment authorization 
procedure that grants access to the benefits of the new Code. The investor can subsequently apply 
to the Ministry of Tourism for a tourism operator's licence. In conformity with the Investment Law, 
an investor is eligible for certain concessions under an incentive scheme that essentially relies on 
a system of derogations that include: 
- exemptions from customs duties and taxes on materials and equipment for hotel and 
tourism projects; 
- exemptions from, among other things, taxes on profits and dividends, property, 
inheritance and real estate; the exemption applies for up to ten years or longer depending on the geographical area affected by the investment in the aim of 
encouraging more balanced development; and 
-  the right to transfer all profits abroad. 
 
578.  Foreign workers recruited to work on an authorized investment project are eligible for the 
following benefits and guarantees: 
- the right to transfer abroad freely 100% of salaries paid in national currency in foreign 
currency; and 
- the right to transfer abroad freely salaries corresponding to leave spent in a foreign 
country. 
 
579.  The Investment Code provides for two systems of incentives (A and B) depending 
on the amount of the investment, namely from KMF 5 million to KMF 100 million, and over KMF 100 million. WT/ACC/COM/3 
- 80 - 
580.  The principal incentives are a reduction in the single administrative charge (RAU), exemption 
from turnover tax, and deduction of the authorized  investment from taxable profits. The system A 
and B incentives apply for seve n and ten years respectively. 
581.  The Code also provides for incentives to enterprises that invest in rural areas. The benefits 
are as for those under systems A and B but the exemptions apply for two further years. 
582.  Tourism falls within the remit of the Mini stry of Transport and Tourism. In conformity 
with the country's current administrative system there are four bodies with responsibility for 
tourism: a National Directorate of Tourism and Hotels at Union level. It has representation in each 
of the autonomous islands. 
583.  There are three organizations involved in organizing and developing tourism. They are: 
• the Comorian Tourism Association: an umbrella grouping for hoteliers and 
restaurateurs; established in 1995; 
• the National Tourism Office; • the National Travel Agency Federation: a grouping of around ten local services mainly 
based on Moroni that offer the following tourism products: 
- rambling, including rambles lasting a whole day or half a day 
- Karthala discovery including a two-day ramble and one night's bivouacking; 
Moheli marine park discovery, cultural sites and visits to ancient monuments, 
Sultans' Palace, beaches, snorkelling and diving. 
 - Transport services 
 
584.  Transport services are particularly important to Comoros because of its island nature and mountainous topography, the fact that its population is dispersed and its dependence on food 
imports. The country has a strong tradition of maritime transport and maritime migration, and 
since independence successive governments have made efforts to introduce the infrastructure required to link the islands by air and sea, as well as providing intra-island road connections in 
an attempt to reduce regional isolation, free up the transport of agricultural output towards urban 
areas, and the movement of goods and people from urban to rural areas. 
585.  Each island in the Union of the Comoros now has at least one inter-island shipping port. 
Only the islands of Grande Comore, Anjouan and Mayotte have port infrastructures that connect 
them directly to the outside world. Of the thr ee international ports, Moroni, on Grande Comore, 
is inadequate because its shallow water location leaves it unable to accommodate large cargo vessels. This forces these vessels to unload at mooring points several metres away from the 
quays, thereby increasing costs and increasing unloading times. As a result the insurance premium 
for Moroni as a destination is very high to take account of the associated risk factors. 
586.  The country has an international airport on  Grande Comore capable of accommodating all 
large and long-haul carriers; it meets the standa rds required for air navigation and safety. The 
other two islands in the Union of the Comoros each has a secondary airport that do not have runway lighting for night flights. 
- Maritime transport services 
 
587.  The maritime transport sector has been fully liberalized since the State's divestiture in the 1990s; small, private, domestic short se a shipping companies service the inter-island 
requirements for both goods and passengers. 
588.  Comorian vessels are registered pursuant to the 2002 law and under that law vessels flying 
the Comorian flag must not be more than 30 years old. 
589.  The maritime register of Comoros includes foreign vessels of various origins that are 
registered under a flag of convenience. There are also other categories, however. In total there are 550 registered vessels including local craft engaged in inter-island and subregional traffic. The register includes pleasure craft, oil tanker s, some cargo and passenger vessels and fishing 
boats. WT/ACC/COM/3 
- 81 - 
590.  Two private companies established under Comorian law ( Spanfreight  and Anjouan 
Stevedoring ), but which are in fact subsidiaries of a major Kenyan company registered in 
Mombasa, tranship goods from Mombasa, Dar es Salaam, Longoni (Mayotte), and Mutsamudu 
mainly to Moroni but also to Mutsamudu (Anjouan), a port with a strategic location as a freight 
hub. Both companies have two container vessels and one conventional freight vessel. 
591.  Additionally, the major international maritime shipping lines (MAERSK–SEALAND, CMA-CGM, 
MSC and SEAL/DAL) only very indirectly have business in Comoros, preferring to conduct 
transhipment at the ports of Mombasa, Dar es Salaam, Port Réunion, Longoni (Mayotte), and 
Mutsamudu (Anjouan) and Mauritius for delivery to the port of Moroni, which handles over 75% of the country's external trade. The disadvantage is  that it is not a deep-water port, preventing 
offloading at berth. This reduces vessels' offloa ding performance, increases costs, and generates 
breakages. At the same time the port does not attract the major lines, which prefer to 
sub-contract with short sea shipping companies that specialize in this type of transhipment. 
592.  A few low-tonnage Comorian vessels (up to 1,000 GRT) totalling 139,779 GRT/205,369 DWT 
provide a regular flow of goods and passengers to Madagascar and Tanzania and from those two 
countries to Comoros. In the past, the State owned up to four vessels, all of which foundered in various incidents: El Mabrouk , the LCT, the Kamar Al Koweït , the Choungui . 
593.  Like 32 of the world's countries, Comoros manages a flag of convenience register with an 
estimated 87 vessels registered in 2008 ( The World Factbook ); capacity: 368,000 tonnes 
deadweight. The fleet registered at Comoros averages 25 years in age and numbers 87 vessels in all (Bangladesh 2, Bulgaria 2, Cyprus 1, Greece 6, India 2, Kenya 1, Kuwait 1, Lebanon 4, 
Norway 1, Pakistan 4, Philippines 1, Russia 12, Sa udi Arabia 1, Singapore 1, Syria 4, Turkey 8, 
Ukraine 8, UAE 7, US 2). The other types of ve ssel calling at Comoros are: bulk carriers 15, 
carriers 2, chemical tankers 5, container carrier s 2, passenger transport 1, passenger/cargo 1, 
oil tanker 9, refrigerated cargo vessels 5, roll on/roll off 8, specialist tankers 1. 
594.  The vessels are registered through a subcontracted company. Until 2006 the Greek firm 
INSB was responsible for registering Comorian vessels, paying fees to the IMO and returning flag 
duties to the Comorian State. 
595.  A lack of transparency in the fee transfer s along with administrative problems forced the 
Maritime Transport Directorate to put out a call for tenders in 2006 with a view to selecting a new 
service provider. As a result the company Union Marine Classification , which has offices 
in Dubai and Sharjah, was retained and sinc e 1 January 2007 has been granting nationality 
to vessels flying the Comorian flag. A financial return of US$9,000 per quarter has been recorded. 
596.  However, the information notified by the new provider ( List of vessels registered into 
Combronde International Shimon Registry ) is unsatisfactory, often lacking in detail and 
in particular failing to include flag de-registrations. 
597.  As part of the process of restructuring the Ministry and enhancing the operational capacity of 
the directorate within the ministry, the Government intends to make the supply of more rigorous 
statistics a requirement in an attempt to improve public governance, especially with regard to 
income transparency. 
598.  There are no restrictions on this sector of  activity. Thus Comorian and foreign operators are 
able to supply maritime transport services. Likewise there are no constraints on foreign 
participation either in the vessel maintenance and repair sector or in the towing sector. WT/ACC/COM/3 
- 82 - 
Table 17: Cost of maritime transport and tr anshipment of a 20-foot container (in KMF) 
France/Comoros  2,100,000 to 2,850,000 
Réunion/Comoros  375,000 to 450,000 
Dubai/Comoros  1,200,000 
Mombasa/Comoros  640,000 
Madagascar/Comoros  75,000 
Moroni/Fomboni and Mutsamudu/Fomboni  56,000 
Moroni/Dzaoudzi  119,000 
Moroni/Mutsamudu  105,000 
Direct ship-to-ship transhipment  67,455 
Ship-to-shore transhipment  89,941 
 
- Air transport services  
599.  Since the State's divestiture of the sector  and the dismantling of the national airline 
Air Comores in the 1990s, inter-island and regional air transport has been provided by private companies established under Comorian law that  are essentially under foreign ownership. 
Chief among them are Comores Aviation and Comores Air Services. The foreign companies 
Yemenia, Kenya Airways, Air Austral and Air Madagascar provide international services and 
medium and long-haul flights. Air Tanzania flights ended in 2008 following the airline's collapse. Comores Aviation, a company governed by Comorian private law, took on the weekly transport 
link to Dar es Salaam and Zanzibar. 
600.  Moroni's International Prince Said Ibrahim Airport (AIMPSI), around 20 km outside the 
capital of the island of Grande Comore, generated traffic of 132,000 passengers in 2006 (national 
and international flights) and only 1.2 tonnes of freight compared to 0.8 tonnes in 2001, 2002 and 
2003. Air freight is developing slowly with aircraft performing international combi flights, in other words carrying passengers and their luggage as well as freight. The airport separates domestic (inter-island) traffic from international traffic. The airports on Anjouan and Moheli do not meet 
international standards. 
601.  The prospect of new hotels opening has led to expressions of interest from other 
international airlines in establishing connections there to respond to future demand. 
602.  There are no constraints on transport links to Comoros for airlines whether under domestic, 
foreign or joint ownership. 
- Road transport 
 
603.  Intra-island road transport for goods and passengers has always been a "liberal" activity performed by hundreds of Comorian traders. The principal urban centres are connected to villages by a network of private vehicles that transport bo th passengers and goods. There are taxi services 
for the urban centres on all the islands. A public service under the Ministry of National Education 
has a fleet of around ten minibuses that provides transport for schoolchildren aged five and up, a total of 5,000 children. 
604.  There are no constraints on foreign participation in the sector. 
- Financial services 
 
605.  The financial services sector plays an important role in Comoros' development, contributing 
up to 4.5% of gross domestic product in 2006. By  comparison, the figure for Cape Verde, which 
has a similar structure, is 5%. The Central Bank of Comoros regulates and supervises all insurance and banking activities in close cooperation with the Ministry of Finance to ensure the efficient 
operation of the country's financial system.  
- Insurance and insurance-related services 
 
606.  There are currently four private insurance companies providing services to the domestic 
market, all four financed by local and foreign investors: Al Amana , Assurances Générales des WT/ACC/COM/3 
- 83 - 
Comores , Générale Comorienne d'Assurance , and Comores Trade Insurance . All four are general 
agents of large foreign firms such as Prudence Créole-GFA  and Axa. 
607.  Strictly speaking, there are no local insurance companies established under Comorian law, 
including State-owned companies; there are only "insurance intermediaries" or general agents for 
foreign companies whose role is to give opinions and negotiate insurance contracts between 
consumers (individuals or enterprises) and the insurance companies. 
608.  Insurance is not widespread and is not part of the culture either in the private or economic 
domain. Most policies are taken out only when there is a legal or regulatory obligation to do so 
(vehicles, foreign travel) or a banking requirement (credit on collateralized goods, documented letter of credit). This area merits more in-depth study. 
609.  There are two categories of insurance inte rmediator – agents and brokers. Currently there 
are four intermediaries; they are general agents of foreign insurance companies but there are no 
insurance brokers. 
610.  The Ministry of Finance regulates and superv ises insurance companies in conformity with the 
laws and regulations in force in the Union of th e Comoros. Insurance enterprises are limited to 
providing insurance and related services (i.e. life assurance, and non-life insurance and re-insurance services). Moreover they must sa tisfy the criteria laid down in the Insurance 
Code of Comoros. 
611.  Individuals convicted of any major offence (e.g., robbery, abuse of trust, fraud, and 
fraudulent bankruptcy) are ineligible. Foreign nationals may become agents provided they meet all of the requirements for eligibility. Eligible foreign nationals will be allowed to work as agents under 
the same terms that apply to Comorian nationals working in the foreign national's country of 
origin.  
612.  General agents and insurance brokers must be registered with the Ministry of Finance and 
authorized pursuant to the provisions in force on engaging in insurance activities. 
613.  There are no other restrictions on foreign nationals seeking to become insurance brokers. - Banking and other financial services (excluding insurance) 
 
 - Banking services  614.  The banking system of Comoros has a three-tier structure: the first is banks as defined in 
Articles 4 and 5 of Law No. 80-87 on regulation of banks and financial establishments. In line with 
the category definition there are four  establishments providing services:  
- Bank of Industry and Commerce (BIC) with a capital of KMF 300 million, a subsidiary 
of the BNP Paribas Group; 
- Banque de Développement des Comores (BDC), in which the State is the majority 
owner through direct holdings and through the Central Bank, a State body. 
The European Investment Bank (EIB) and the French Development Agency (AFD) 
hold 49% of the subscribed capital of KMF 300 million; 
- Exim Bank (Comoros) operating as a branch of Exim Bank (Tanzania); - Banque Fédérale du Commerce (BFC) with a capital of €10 million, or around 
KMF 5 billion fully in the ownership of Kuwaiti private interests. 
 615.  Of the four commercial banks, the BIC and the BDC each have three agencies across the 
islands. Exim Bank launched its activities with a central agency based in the capital but plans 
to extend its supply of banking services to the other islands. The same is true for the BFC. 
616.  The second category referred to in the laws and regulations covers the Decentralized 
Financial Institutions (IFD) as defined in Decree No. 04069/PR of 22 June 2004 regulating the 
Decentralized Financial Institutions. WT/ACC/COM/3 
- 84 - 
617.  There are two institutions in operation providing services in this category: 
- the Union of MECKs with a network of 13 affiliated branches, the largest mutual network in 
the country, holds savings deposits of over KMF 10 billion, ranking it in second place in the country; 
- the Union of Sanduk with a ne twork of 32 affiliated branches. 
 618.  The third category within the meaning of the banking law covers Financial Intermediaries as 
defined in Article 2 of Law No. 80-07 regulating Banks and Financial Establishments: 
- The National Postal and Financial Services Company (SNPSF), which provides the following 
services: 
 
* savings account (National Savings Bank); 
* Postal current accounts; * Universal international money transfers (Western Union); 
* Currency exchange transactions, chiefly in euros. 
 
- Comores Express, a company established under  Comorian private law offering MoneyGram 
services; 
 
- Bank of Industry and Commerce,  representing Western Union. 
 
619.  A fourth category accounts for the remainder; potential off-shore banking, which is not 
currently available in Comoros with no one seeking to perform such activities, is not subject to any 
State regulation or any Central Bank regulatory instruction under the latter's statutes and the law. 
620.  The Central Bank of Comoros regulates and supervises all banking and parabanking 
activities. Law No. 80-07 regulating Banks and Financial Establishments establishes the regulatory framework for the sector, particularly in Articles 6 to 14 of Chapter II on the rules on granting 
authorization and prior authorization.  
621.  The Law, especially Article 6, provides that: 
- Financial establishments other than those governed by public law may not exercise 
their activity without the prior authorization of the Minister of Finance acting on a 
favourable opinion from the Bank. Authorization is declared through entry on the list 
of banks or the list of other financial establishments. 
- The entry is made public by the Bank. An y expense incurred is borne by the financial 
establishment. 
- The Bank may assign the banks and the other financial establishments to the 
categories determined by it in line with their activities. 
 
622.  Before a commercial bank or a banking or parabanking establishment can become established, an authorization or prior authorization must be obtained from the Central Bank of Comoros. The procedure is initiated by the Government of the Union of the Comoros at a central 
bank board meeting, a body empowered to take a de cision pursuant to the statutes of the issuing 
establishment, subject to a number of prerequisites.  
623.  In fact, authorization is conferred by the Mini ster of Finance in the light of the opinion of the 
board of the central bank. Authorization is then declared through entry on the list of banks or the 
list of other financial establishments. The entry is made public by the Bank. Any expense incurred 
is borne by the financial establishment. 
624.  Articles 8 to 15 lay down the terms and conditions as follows: 
(1) The application for authorization as a financial establishment shall state the activities 
that the financial establishment intends to pursue, the location of its registered company office, the locations where it proposes to open branches, agencies or 
windows, the names of the people responsible for administering, directing or 
managing it, its legal status and its company capital. WT/ACC/COM/3 
- 85 - 
(2) If the company office of the financial establishment is abroad, the application for 
authorization shall state the location of the principal establishment on the territory of the Republic and the source of equity funding of the financial establishment on the territory of the Republic. 
(3) The Bank may require the financial establishment to provide to it any other 
information it may require and to produce all documents it deems necessary. 
(4) When examining an application for authorization the Bank shall take into consideration 
inter alia  the legal status and financial situation of the financial establishment, the 
experience it has been able to acquire, the competence of the staff charged with its administration, direction or management, the existing or foreseeable needs of the region where it intends to pursue that activity, including the effects that that activity 
may have on existing financial establishments. Where authorization is refused on 
grounds of the national interest, there is no requirement to notify the applicant of the reason therefor. 
(5) The authorization may be subject to special terms. It may state the location of the 
company headquarters or the principal office of the financial establishment on the territory of the Republic, the locations wher e the financial establishment may or must 
open branches, agencies or windows and the activities that it can or must pursue. 
The terms governing the authorization may be amended subsequently at the request 
of or with the consent of the financial establishment. The Bank shall examine the 
request for amendment and make a decision  as in the matter of application for 
authorization. 
(6) Authorization of the financial establishments referred to in Article 2(2) shall stipulate 
the extent to which the present law applies to them and all rules appropriate to its 
application. 
(7) The authorized financial establishments are required to notify the Bank of any 
amendment to aspects brought to the Bank's attention by virtue of the present Article 
when examining their application for authorization. Any expense incurred shall be 
borne by the financial establishment. 
(8) Any financial establishment in receipt of public funds which has its registered office on 
the territory of the Republic must at all times hold a minimum level of capital as 
determined by the Minister of Finance acting on proposals from the Central Bank. 
For a bank, the share capital may not be less than KMF 100 million. 
(9) The minimum capital must be the same for each financial establishment in the same 
category. 
(10) The capital of a financial establishment as referred to in paragraph 1 must be fully 
paid up within six months of the date of au thorization or of any subsequent decision to 
increase the capital. 
(11) All official instruments, letters and documents of a financial establishment must make 
reference to its capital. 
(12) The provisions of Article 15(1), (2) and (3) shall apply to the capital endowment of 
financial establishments governed by public law. 
(13) The financial services sector as a whole is governed by the body of legislative and 
regulatory texts listed below: 
 
- Law No. 80-87 of 26 June 1980, "the Banking Law", regulating banks and financial 
establishments; 
- Law No. 95 6 016 AF of 7 July 1995 establishing a National Guarantee Fund; 
- BCC Instruction No. 12/1999 on periodic accounts to be submitted by the banks and 
financial establishments; WT/ACC/COM/3 
- 86 - 
- BCC Instruction No. 13/2000/COB on the definition of capital requirements for banks and 
financial establishments;  
- BCC Instruction No. 14/2000/COB on the solvency ratio of banks and financial 
establishments; 
- Recognition of Savings and Credit Mutuals by  the Minister of Finance, the Budget and the 
Plan, ref.: 97-348/MFBP CAB; 
- Extracts from Ordinance No. 92-004 establishing the statute of the SNPT; 
- Instruction on foreign exchange transactions involving the euro conducted by the SNPT; 
- Decree 87-005/PR of 16 January 1987 regulating financial relations between the Islamic 
Federal Republic of the Comoros and other countries; 
- BCC Instruction No. 1/RDC of 17 February  1987 on the appointment of authorized 
intermediaries for financial relations with other countries; 
- BCC Instruction No. 2/RDC of 17 February 1987 on authorized intermediaries: 
general provisions; 
- BCC Instruction No. 5 of 17 February 1987 on the regulation of foreign exchange: 
provisions on accounts open to non-residents; 
- BCC Instruction No. 6/RDC of 17 February 1987 on foreign travel costs: provisions 
on travellers; 
- BCC Instruction No. 7/RDC of 17 February 1987  on the regulation of foreign exchange: 
statistical obligations incumbent upon authorized intermediaries; 
- BCC Instruction No. 8/RDC of 26 July 1988 on travellers' cheques: notices and instructions; 
- BCC Instruction No. 9/RDC of 26 July 1988 on travellers' cheques denominated in the units 
of account of the preferential trade area: transactions and operational procedures;  
- BCC Instruction No. 10/RDC of 16 December 1991 on provisions concerning exports; 
- BCC Instruction No. 11/RDC of 16 December 1991 on provisions concerning imports; 
- Circular No. 91-01 of 16 December 1991 on co ntrols on the external position of banks 
and financial establishments; 
- Circular No. 91-02 of 16 December 1991 on enumeration by nature of movements 
registered on the external contra accounts of banks and financial establishments; 
- Circular No. 91-03 of 16 December 1991 on the enumeration of transactions on foreign 
notes and traveller's cheques by banks and financial establishments; 
- Order No. 99-001/MECIA/CAB of 4 January 2000 eliminating import and export licences; 
- Circular No. 304/CD of 7 February 2000 to importers and exporters on domiciliation 
of foreign trade transactions; 
- Law on leasing, 2012. 
 WT/ACC/COM/3 
- 87 - 
Figure 2 
Commercial banks in the Union of the Comoros 
 
 
Bank of 
Industry and 
Commerce 
(BIC) 
Central Bank 
of Comoros 
(BCC)  
Supervision, 
control and 
disciplinary 
oversight 
Comoros 
Development 
Bank 
(BDC) Federal Bank 
of Commerce 
(BFC) WT/ACC/COM/3 
- 88 - 
Figure 3 
Decentralized financial institutions 
 
 
 
 National Union 
of "SANDUK " 
(32 affiliated 
branches)  
Central Bank 
of Comoros  
BCC 
Supervision, 
control and 
disciplinary 
oversight  
Union of Mutual 
Comoros Savings 
and Credit 
Associations 
 MECKs  
(13 affiliated 
branches)  WT/ACC/COM/3 
- 89 - 
Table 18: Financial Intermediaries  
Entity Activity 
National Guarantee Fund Administered by th e BCC and presided over by its Governor, 
the Fund is financed by the following resources: - proceeds of fund-raising from donors; - interest paid on the fund, including annual guarantee fees 
and financial products; 
- capital from the alienation of moveable and immoveable 
property; 
- subsidies; - grants and bequests; - incidental revenue. The fund is administered by a board comprising five members 
representing the banking system, the private sector and the donor community.  The target beneficiaries are: - micro-enterprises, small and medium-sized companies 
(SMEs) under Comorian law where the investment (capital assets or capital cost) is between KMF 0.5 million and KMF 50 million; 
- Fledgling or expanding enterpri ses must submit a feasibility 
study case-file providing evidence of their profitability. 
 The banks are entitled to demand full security for any bankable case-file. 
Savings Bank Limited to collecting savings deposits remunerated at the guide 
rate determined by the BCC. This activity is the exclusive responsibility of the National Postal and Financial Services Company. However other establ ishments may offer their own 
savings products to their customers under specific plans. 
Postal Cheque Accounts Restricted to dema nd deposits by savers  and other economic 
and social operators; this activity is exclusively the domain of public-law entities and is perfor med by the National Postal and 
Financial Services Company. 
International transfers Restricted to tran sfers-remittances of funds from a foreign 
country to Comoros and vice-versa. 
Foreign exchange offices Restricted to the pu rchase and sale of fo reign currencies. Staff 
at the offices must obtain prior authorization from the BCC and satisfy certain conditions: (1) ad opt the form of a capital stock 
enterprise or partnership; (2) co ntrol capital stock of at least 
100 million; and (3) use the expression "Bureau de change" in the name of the establishment. 
Credit card issuers Limited to issuing credit  cards, an activity undertaken mainly by 
the BIC and Exim Bank (Visa and MasterCard), and providing related services (cards specific to issuing establishments can be used only at dedicated ATMs). 
 
- Other financial services  
625.  In view of its level of development, in particular the low levels of local capital, the amount of 
which is a determining factor in stock market capitalization, the Union of the Comoros does not have a stock market. The outlook in this regard is that this type of service may be supplied at 
subregional level within the framework of the Indian Ocean Commission (Stock Exchange in 
Mauritius, for example) or at regional level within the COMESA framework. 
2.  Policies affecting trade in services 
626.  In this respect, general reference should be made to the body of laws, regulations, rules, 
procedures, decisions, administrative measures and other essential legal instruments and to the description of specific measures affecting trade in services. Distinctions could be made, where relevant, according to the mode of supply or sector concerned.  WT/ACC/COM/3 
- 90 - 
(a)  Government departments, agencies, prof essional associations or other bodies with 
authority or a role relevant to the conduct of service activities 
627.  There are a number of ministries, agencies and professional associations that play a role in 
the conduct of service activities. Th e principal government bodies are: 
– Ministry of the Economy and Foreign Trade; 
– Ministry of Transport and Tourism; – ANPI; 
– National Office for Health Control of Foodstuffs (ONACSA); 
– UCCIA; – Tourism General Directorate; – Ministry of Infrastructure; 
– Ministry of Finance and the Budget; 
– Office of the Commissio ner General for Planning; 
– Ministry of Health; 
– Ministry of Education and Culture; 
– Ministry of Agriculture, the Environment and Fisheries; – Central Bank of Comoros; 
– many socioprofessional associations also play a role in this sector, including the 
Bar Association, the Association of Businesswomen, Comoros Employers' Organization, the Comoros Private Sector Federation, the Order of Physicians and Pharmacists, the National Union of Farmers of Comoros, the National Union of Craftspeople, etc. 
 
(b)  Judicial, arbitral or administrative trib unals or procedures providing for the review 
of, or remedies in relation to, administra tive decisions affecting trade in services 
628.  Under the Law on the Investment Code (Law  No. 07-010/AU of 31 August 2007), all disputes 
between foreign service providers and the State are subject to mediation or arbitration unless otherwise provided for in an agreement or international treaty to which the Union of the Comoros 
is a signatory. 
629.  Additionally, the Comoros Chamber of Commerce envisages the establishment 
of a mediation and arbitration centre in conjunction with the Bar Association and the State through public prosecutors and independent persons recogniz ed for their qualifications and/or experience. 
(c)  Provisions, including those in internat ional agreements, concerning qualification 
requirements and procedures, technical stan dards and licensing and/or registration 
requirements for the supply of services 
630.  There are a number of provisions concerni ng eligibility requirements for the provision 
of services; they have been fully detailed in the relevant sections of this Memorandum. 
(d)  Provisions governing the existence and operation of monopolies or exclusive service 
suppliers 
631.  While much of the services market has und ergone significant liberalization, a number of 
monopolies do exist in the provision of certain basic services, notably in telecommunications, electricity and water, and the importation and marketing of ordinary rice (i.e. between 5% 
and 25% in the husk). 
632.  These monopolies operate in conformity with the procedures laid down in the laws regulating 
them. The trend would appear to be towards signature of specific service contracts with precise 
terms on attainable and measurable objectives , results and performance, accompanied by the 
terms and conditions governing a monopoly concession within a framework justified on the grounds of providing a public service. 
(e)  Provisions relating to safeguard meas ures as they apply to trade in services 
633.  There are no provisions relating to safeguard measures in the services sector. WT/ACC/COM/3 
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(f)  Provisions relating to international tr ansfers and payments for current transactions 
involving services 
634.  Pursuant to the relevant legislation and regulations, transfers and payments for current 
transactions involving services can be made freely (Article 1 of Decree No. 87-005/PR) except in 
the following cases in which they are either prohibited (Ordinance No. 03-002/PR on money 
laundering, confiscation, and international cooperation in relation to proceeds of crime) or are subject to prior authorization by the Central Bank of Comoros: 
- Articles 2 to 12 of Decree No. 87-005/PR implementing the Banking Law and 
Instructions Nos. 1 to 11 of the Central Bank of Comoros implementing the decree, 
set out provisions on financial relations with foreign countries within the framework of the foreign exchange system; 
 
– Article 4 of Decree No. 87-005/PR prohibits,  unless authorized by the Central Bank, all 
foreign exchange transactions or transfers in the Republic of Comoros whereby a 
resident builds assets abroad or holds in the Republic of Comoros the means to make 
payments abroad; 
 
– Any payment in cash or by bearer security of a sum greater than KMF 5 million is 
prohibited (Ordinance No. 03-002/PR); 
 
– Any transfer abroad or originating abroad of funds or securities for a sum greater than 
KMF 1.5 million must be made by an authorized lending institution or financial 
institution or by its intermediary (Ordinance No. 03-002/PR). 
 
(g)  Provisions relating to capital tran sactions affecting the supply of services 
635.  Under the Banking Law of the Union of the Comoros and its implementing decrees, capital 
transactions are subject to prior authorization by  the Central Bank of Comoros (stock exchange 
transactions will be exempt from this provision). 
(h)  Provisions governing services procurement by government bodies 636.  Provisions on services procurement by gove rnment bodies are set out in the Decree on the 
Government Procurement Code and other specific provisions enacted by the Government whether 
under the Finance Law or any other legal instrument such as a financing agreement with a donor 
or funding body. The Ministries of Finance, the Economy, Infrastructure, Energy, Posts and Telecommunications, each acting in the field under its responsibility or through the 
Government Procurement Regulatory Authority, ov ersee the procurement of services, put out calls 
for tender and sign and renew contracts directly or through their agencies. 
637.  The Ministry of Finance is the only Ministry  authorized to procure certain services, including 
services for the supply of electricity and water, an d telecommunications, insurance, rental, security 
and security guard services for the State and its agencies. 
638.  The various Ministries may procure certain other services provided that the cost does not 
exceed a set maximum amount determined under the relevant provisions of the 
Government Procurement Code. 
(i)  Provisions concerning any form of aid,  grant, domestic subsidy, tax incentive or 
promotion scheme affecting trade in services 
639.  To the extent that such aid, subsidy, incentive or promotion schemes exist, they are 
described in detail in the appropriate sections of this Memorandum. Generally, the Law on the Investment Code provides for certain tax and financial incentives for investors and authorizes 
customs exemptions and other concessions for eligible enterprises in line with the authorization 
issued to them. 
640.  Additionally, the Government may provide assistance to public enterprises (e.g., for the 
purposes of a restructuring programme or an investment deemed strategic for the country). WT/ACC/COM/3 
- 92 - 
All such measures are the subject of ministeria l orders following consultation with the Council 
of Ministers. 
3.  Market access and national treatment (a)  Limitations on the number of service suppliers 
641.  There are no limitations of this kind. 
(b)  Limitations on the total value of services transactions or assets  642.  There are no limitations of this kind. 
(c)  Limitations on the total number of service operations or on the total quantity of 
service output 
643.  There are no limitations of this kind. (d)  Limitations on the total number of na tural persons that may be employed in 
a particular service sector 
644.  There are no limitations of this kind. (e)  Restrictions on, or requirements of sp ecific types of legal entity through which 
a service may be supplied 
645.  Insurance enterprises and commercial banks must be established in the form of joint-stock 
companies and foreign exchange offices ( bureaux de change ) in the form of joint-stock companies 
or partnerships (see section VI.1(e)). In the construction and public works sector, foreign 
enterprises must establish an office in-country (see section VI.1(b)). 
(f)  Limitations on foreign capital participation 646.  There are no limitations of this kind. 
(g)  Measures providing for less than the tr eatment accorded to national services or 
service suppliers 
647.  Foreign service suppliers generally receive the same treatment as that afforded to domestic 
suppliers. The Law on the Investment Code enshrines the principle of non-discrimination. 
648.  The Government Procurement Code provides for a minimum level of resort (30%) to national 
service providers in the execution of specific pu blic contracts. This measure concerns national 
treatment to support fledgling industries. The me asure does not discriminate on grounds of the 
provider's nationality; the important factor is that the provider's offer is for services originating in the Comoros. 
649.  The universal exclusivity rule reserves the pr ovision of attorneys' services to members of the 
Comorian Bar Association. However, exceptions to the rule may be made by a decision of the Bar 
Association in individual cases, based essentially on the existence of reciprocal arrangements with the country concerned. 
650.  Additionally the previous Commercial Code of  1984, repealed in 1995, reserved the exercise 
of certain retail activities to Comorian nationals. A future replacement text will re-introduce that provision in response to claims by Comorian socioprofessional organizations that a foreigner should 
bring something extra, adding value to an investment. 
4.  Most-favoured-nation treatment 651.  There are no existing measures inconsistent with MFN treatment. WT/ACC/COM/3 
- 93 - 
VII.  INSTITUTIONAL BASE FOR TRADE AND ECONOMIC RELATIONS WITH THIRD 
COUNTRIES 
1.  Bilateral or plurilateral agreements rela ting to foreign trade in goods and trade in 
services 
652.  The Union of the Comoros will submit the li st of agreements relating to foreign trade in 
goods and trade in services to the Working Party. 
2.  Economic integration, custom s union and free trade agreements 
653.  As noted in section IV.1(b), the Union of the Comoros is a member of COMESA, the Indian 
Ocean Commission and the trading frameworks specific to the League of Arab States and the Islamic Conference. Under the Treaties establishing COMESA and the IOC, the member States of the two organizations agreed to apply a common external tariff (CET) and to establish a customs 
union (COMESA) and a free trade area (IOC). In conformity with its COMESA commitments, the 
Union of the Comoros notified the IOC of an 80% tariff reduction on products originating in other member States. 
654.  The Union of the Comoros took the final step to join the COMESA free trade area in 2006 in 
accordance with the Treaty and notified a 100% tariff reduction on originating products. It is preparing to join the Customs Union pursuant to Article 45 of the COMESA Treaty at the end of the 
ten-year transitional period. The Customs Union was launched in December 2008 on the basis of 
the Cairo Road Map adopted by the 11
th Council of Ministers. 
655.  The Union of the Comoros has not yet notified membership of the Customs Union. 
However, it intends to do so in the near future in conformity with its commitments. 
656.  The COMESA Customs Union comprises the follo wing elements, as outlined in the Road Map 
adopted by the member States: 
- A common external tariff (CET) 
 
657.  The CET is applied to imports from third countries (extra-COMESA imports) subject to the 
most-favoured-nation (MFN) rates. At their meeting in Nairobi, Kenya, in May 2008, the Council of 
Ministers adopted a four-band CET as follows: 
(a) Capital goods; 
(b) Raw materials; (c) Intermediate products; 
(d) Finished products. 
 
- Common tariff nomenclature (CTN) 
 
658.  A common tariff nomenclature, based on the HS 2003, has been developed and adopted. Some member States, including Co moros, harmonized their national nomenclatures with the CTN 
as part of the ASYCUDA++ implementation process conducted in 2008. 
- Common customs valuation system 
 659.  Fifteen member States have adopted the WTO Customs Valuation Agreement as their 
valuation system, whilst an additional four, including Comoros, are making preparations to 
implement the system. 
- Customs Management Act 
 
660.  The COMESA Customs Management Act sets the customs rules and procedures to be implemented by customs administrations and adopted by Directors of Customs. WT/ACC/COM/3 
- 94 - 
- List of sensitive products and tariff harmonization timetables 
 661.  Pursuant to the principle of flexibility and policy space, products that will in the medium to long term need exemptions, exclusions and derogations from the agreed CET rates listed above 
will be accorded differential tariff treatment and will be deemed to be sensitive products. 
662.  The allocation of CET rates to be applied in the Customs Union to all 97 chapters and the 
identification of sensitive products are scheduled to be finalized in the near future. Member States 
will be required to indicate the time-frames within which those of their tariffs that are not aligned 
with the CET will be harmonized with the CET as agreed and adopted, according to tariff 
harmonization timetables. Thus, some products requiring exemption from harmonization will be taken into account. 
663.  The Union of the Comoros has signed a number of bilateral economic cooperation 
agreements incorporating trade-related provisions th at do not envisage a preferential or free trade 
regime in the strict sense. The principal agreements in question are with Madagascar, Kuwait, 
Turkey and Tanzania.  
3.  Labour markets integration agreements 664.  A protocol on the free movement of person s forms an integral part of the COMESA Treaty. 
States sign at a date appropriate for them but in any event prior to the entry into force of the 
Customs Union, the final step in providing for fr ee movement of goods and persons. The Union of 
the Comoros has not yet notified implementation of the Protocol but intends to do so very shortly, in conformity with its commitments. 
4.  Multilateral economic cooperation, membership in the multilateral economic 
organizations, trade-related programme s of other multilateral organizations 
665.  Associations and organizations: 
- International Air Transport Association (IATA); 
- International Civil Aviation Organization (ICAO); - World Customs Organization (WCO); 
- World Intellectual Property Organization (WIPO); 
- World Tourism Organization (UNWTO); - International Maritime Organization (IMO). 
 
VIII.  OTHER PROCEDURAL REQUIREMENTS  
666.  There are no procedural requirements in the Union of the Comoros, other than those 
described in sections I through VII of the Memorandum on the Foreign Trade Regime. 
_______________ WT/ACC/COM/3 
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ANNEX 1 
 
STATISTICS AND PUBLICATIONS 
 2009 2010 2011  2012 2013 2014 2015  2016
Prel.             Projections
Current account  -14,736 -14,113 -20,575 -23,693 -23,349  -23,533 -22,562 -23,478
Goods and services  -62,898 -70,272 -78,787 -81,997 -81,389  -81,064 -80,533 -83,948
Trade balance  -53,386 -59,359  -64,418 -68,184 -68,866  -69,785 -70,782 -75,050
     Exports (f.o.b.) 6,659  7,656 8,908  9,428 10,035 10,868 11,775 12,755 
  Of which :  Vanilla 645 309 350 359 372 394  418 435
                     Cloves  3,221 5,410 6,361 6,712 7,155 7,813 8,529  9,311
                     Ylang-ylang 762 881 745 786 830 881  934 991
                     Othe r 2,031 1,056 1,451  1,571 1,677 1,780 1,893  2,019
Imports (f.o.b.) -60,045  -67,015 -73,326 -77,612 -78,901  -80,652 -82,556 -87,805
  Of which : Petroleum products -12,356 -17,327 -22,190 -24,643 -24,167  -23,480 -23,105 -22,970
Services (net) -9,512  -10,912 -14,369 -13,813 -12,523  -11,279 -9,751 -8,898
      Receipts 20,806  23,897 24,175 26,407  28,974 31,811 34,938 38,448 
      Payments  -30,318 -34,810 -38,544 -40,220 -41,498  -43,090 -44,688 -47,346
Income (net) -168  -851 -162 -527  -507 -487 -401 -68  
   Credit 547 20  581 255 236 247  282 562
    Debit -715  -871 -743 -782  -743 -734 -683 -630  
  Of which : Interest on rescheduled obligations -145 -91 -148  -135 -144 -116 -87  
Current transfers (net)  48,331 57,010 58,374 58,831  58,547 58,018 58,372 60,538 
      Government  10,649 22,535 17,998 14,217  11,858 10,543 10,100 10,178 
  Of which :  HIPC interim assistance 103 198 207 0 0  00
   Private sector 37,682  34,475 40,375 44,614 46,690 47,475  48,272 50,360 
Capital and financial account 14,298  15,569 19,350  22,434 18,969 16,849 16,558 17,759 
Capital account 10,771  8,859 10,989 14,184 14,599 16,035 17,222 18,493 
  Capital transfers  10,771 8,859 10,989 14,184 14,599 16,035 17,222 18,493 
       Transfer of fixed assets 7,206 8,525  10,260 13,411 14,599 16,035 17,222 18,493 
         Of which:  HIPC interim assistance 334 729 773 0 0 0
   Liabilities cancellation 0 0  000000
Financial account 3,527 6,710 8,361  8,251 4,370 813 -664 -734  
    Direct investment 4,882 1,463  4,926 6,562 6,581 6,619  6,664 6,712
    Net portfolio and other investment -1,355  5,247 9,243 1,904 2,456 1,724  366 -390  
       Government -6,318  -2,225 -2,742 -2,725 -2,087 -2,450 -2,813 -3,011  
          Drawin gs 60 548 31  31 537 551  592 635
          SDR allocations 4,139
           Amortization -2,239  -2,773 -2,772 -2,755 -2,625 -3,001 -3,405 -3,647  
              Before reschedulin g -2,503 -2,443 -2,424 -2,193 -2,318 -2,388 -2,329  
              On restructured obli gations -271 -330 -332  -432 -683 -1,016 -1,318  
Private sector (net) 4,963 7,472  6,177 4,414 -124 -3,355  -4,515 -4,435  
    Banks, net 2,101 -1,019  -3,111 -218 -358 -313 -352 -341  
    Other 2,862 8,491  9,287 4,632 234 -3,042  -4,163 -4,093  
Errors and omissions  2,789 -1,743  8,752 00000
Overall balance -2,664  -288 12,379  -1,258 -4,380 -6,684 -6,004 -5,719  
Financing 2,664 288 -3,627  1,258 -288 -845 -1,690  -1,338 
   NFA of central bank (increase = -) -1,873  -841 -4,303  1,044 -288 -845 -1,690  -1,338 
   Foreign assets 11,741  -2,208 -5,560 -785 -2,119 -580 -926 -291 
    Foreign liabilities 9,868  1,367 1,257  1,829 1,831 -265 -764 -1,047
  Of which : Use of IMF credit  1,697 920 891 1,829  1,831 -265 -764 -1,047
Net change in arrears -1,427  -14,343 -5,132 000  00
Clearance of deferred arrears and debt service1 -5,016 
Exceptional financin g 5,964 15,472 5,808 215 0 0  00
    Arrears restructurin g and deferral 14,415  5,014 000  00
    Current maturities restructurin g and deferral 1,057 795 215 0 0  00
Financing gap² 0 0 0  0 4,668 7,529 7,694  7,057
Memorandum items:  
Current account (percenta ge of GDP)  -7.8 -7 -9.5 -10.4  -9.6 -9 -8 -7.8  
Excludin g transfers  -33.3 -35.2 -36.6 -36.1  -33.5 -31.1 -28.7 -27.8  
Exports of goods and services (percenta ge of GDP)  -14.5 -15.6 -15.3 -15.7  -16 -16.3 -16.6 -16.9  
Imports of goods and services (percenta ge of GDP)  47.7 50.5 51.8 51.6 49.3 47.2 45.2 44.7 
Gross international reserves (US$ millions) 146.0  144.2 168.7  156.7 162 162.8 164.3  164.3
   In months of imports of goods and services  6.8 6.3 6.4 6.1 6.2 6.1  65 . 7  
 Source: Comorian authorities, and IMF staff estimates and projections.
1 Includes further deferral of arrears to the HIPC decision point, following which these arrears are assumed to be cleared throu gh restructuring or further deferral.  
2 The financing gap for 2012-2013 can be covered by additional grants and ECF financing.  Table 6. Comoros-Balance of payments, 2009-2016  
In millions of Comorian francs, unless otherwise indicated  WT/ACC/COM/3 
- 96 - 
 2009 2010 2011 2012 2013  2014 2015 2016
            Projections
Net forei gn assets  44,114 45,974 53,388 52,563 53,208 54,366  56,408 58,088 
  Central Bank Assets 51,601  53,810 59,370  60,155 62,274 62,854  63,780 64,071 
  Central Bank Liabilities  -8,108 -9,475 -10,732 -12,561 -14,392 -14,126 -13,362  -12,315 
  Commercial Banks Assets  2,089 5,023 8,655 8,951 9,409  9,885 10,407 10,925 
  Commercial Banks Liabilities  -1,468 -3,384 -3,905 -3,983 -4,083 -4,246 -4,416 -4,592  
Net domestic assets  13,457 22,772 21,953 23,535 28,496 33,679  38,472 43,796 
Domestic credit  37,095 43,680 45,516 51,495 57,504 62,759  68,103 73,978 
          Net credit to government1 7,266 5,743 5,707 7,921 9,260 9,329 8,913 8,391
  Of which : Treasury  9,604 8,885 9,665 11,879  13,218 13,287  12,871 12,349 
               Claims on public enterprises  1,303 2,232 1,341 1,341 1,341 1,341  1,341 1,341
               Claims on other financial institutions 476 86  -21 -21 -21 -21 -21 -21
               Claims on private sector  28,048 35,304 38,27 42,254  46,924 52,111  57,871 64,267 
Other items net  -23,638 -20,908 -23,563  -27,959 -29,008 -29,081 -29,632  -30,182 
Broad money  57,571 68,747 75,341 76,098 81,704 88,045  94,880 101,883
    Money 35,754  42,650 48,820 49,323 53,052 57,273  61,831 66,394 
    Currency in circulation  14,291 18,115 19,985 22,358 24,005 25,868  27,876 29,934 
    Demand deposits 21,464  24,534 28,835 26,965 29,047 31,405  33,954 36,460
Quasi-money 21,817  26,097 26,521 26,775 28,651 30,772  33,049 35,489 
Memorandum items (in percent of beginning period broad money):Net foreign assets 7.7 3.2 10.8 -1.1 0.8  1.4 2.3 1.8
Net domestic assets  5.6 16.2 -1.2 2.1 6.5  6.3 5.4 5.6
Domestic credit  19.1 11.4 2.7 7.9 7.9  6.4 6.1 6.2
       Net credit to government  4.0 -2.6 -0.1 2.9  1.8 0.1 -0.5 -0.6
       Credit to public enterprises  -2.8 1.6  -1.3 0.0  0.0 0.0 0.0 0.0  
       Credit to private sector  16.9 12.6 4.3 5.3 6.1 6.5 6.5 6.7
Other items (net)  -13.4 4.7  -3.9 -5.8 -1.4 -0.1 -0.6  -0.6
Other items (net)  13.3 19.4 9.6 1.0 7.4 7.8 7.8 7.4
       Money 1.9  12 9.0 0.7 4.9 5.2 5.2 4.8
       Quasi-money 11.4  7.4 0.6 0.3 2.5 2.6 2.6 2.6
Velocity 3.3 2.9 2.9 3.0 3.0 3.0 3.0 3.0  
Credit to private sector (percent chan ge) 44.1 25.9 8.4 10.4 11.1 11.1 11.1 11.1 
Source: Central Bank of Comoros; and IMF staff estimates and projections
1Includes net credit to government entities other than public treasury.                   Table 5. Comoros: Monetary Survey, 2009-2016  
                             (in millions of Comorian francs)WT/ACC/COM/3 
- 97 - 
 
 
__________  2009 2010  2011 2012 2013 2014 2015  2016
Prog. Prel. Prog. Prel. Prog. Proj.  Projections
2nd review 2  nd review 2  nd  review
Total revenue and grants  44,776 57,912 58,869  45,349 50,907 49,210 57,760 59,177 63,004 68,159 74,407  
    Revenues126,401 28,848 28,875  30,175 34,793 32,939 31,847 35,148 38,775 42,756 47,129  
    Tax revenues  20,515 22,479 22,449  26,337 23,520 28,826 26,871 29,753 32,901 36,361 40,167  
       Direct and indirect taxes  10,867 11,998 11,514  16 12,412 17,371 14,690 16,405 18,459 20,806 23,330  
        Taxes on international trade and transactions 9,648  10,481 10,935  10,609 11,108 11,208 12,181 13,348 14,443 15,554 16,838
     Nontax revenues  5,887 6,368 6,426 3,838 11,273  4,113 4,976 5,394  5,874 6,395 6,962  
External grants  18,374 29,064 29,994  15,174 16,114 16,271 25,913 24,029 24,229 25,403 27,279  
      Budgetary assistance² 7,743  15,177 18,584  05 3  0 5,151 2,495  576 0  0
     Pro jects (incl. techn.assist.)  10,631 13,444 10,973  14,205 15,135 15,259 19,781 21,534 23,653 25,403 27,279  
     HIPC interim assistance  444 437 969 926 1,012  980 0  0 0 0
Total expenditure and net lending 43,627  48,300 44,703 49,269 47,793 51,464 56,312 60,971 66,052 70,511 75,812  
  Current expenditure  34,240 33,155 33,116  32,914 35,785 33,428 37,939 40,130 42,500  44,875 47,553  
    Primary current expenditures  29,806 29,391 29,631  30,107 29,959 30,436 30,558 32,281 33,965 35,813 37,926  
      Wages and salaries  17,034 17,864 18,500  18,350 18,409 17,875 18,307 18,416 19,070 19,705 20,430
      Goods and services 7,447  7,692 7,553 7,743 7,662 8,307  8,154 9,136  9,813 10,611 11,551  
      Transfers 5,325  3,835 3,578 4,015 3,889 4,254  4,116 4,729  5,082 5,496 5,942  
  Interest payments 1,069  1,425 1,036 987 952 1,008  1,010 914 917 880 842
    External debt  715 1,197 831 781 743 793  782 743 734 683 630
       Before rescheduling 686 686 674 652 649  633 608 589 567 543
       On restructured obli gations  511 145 107 91  144 148 135 144 116 87  
   Domestic debt 355 228 205 206 209 215  229 171 184 197 212
 Foreign financed project assistance 1,585  1,412 677 1,094 2,636 1,175  1,129 1,229  1,350 1,450 1,557 
 Foreign financed technical assistance  1,780 928 1,771 753 2,238 809  5,242 5,706  6,268 6,731 7,228  
Capital expenditure28,939 15,145 11,588  16,328 11,708 18,036 18,022 20,840 23,552 25,637 28,259  
   Domestically financed investment  1,563 2,598 2,515 2,900  1,417 3,611  3,909 4,974  6,173 6,961 8,194  
   Forei gn financed investment  7,326 11.97 9,073 12,807  10,291 13,754 13,441 15,136 16,586 17,814 19,129  
   Counterpart funds financed  50 577 0 621 0 672  672 730 793 862 937
Net lendin g 448 0 0 0 300 0 350 0  0 0 0
Domestic primary balance  -4,967 -3,141  -3,271 -2,832 3,417 -1,108  -2,621 -2,107  -1.363 -18 1,009  
Overall balance (commitment basis)  1,148 9,611 14,165  -3,920 3,114 -2,253  1,448 -1,794  -3,049 -2,352 -1,405 
       Excludin g grants -17,226 -19,453 -15,829  -19,094 -13 -18,525 -24,465 -25,823 -27,277 -27,755 -28,684
Change in net arrears and reschedulin g 430 -15,593 -12,430  -851 -7,281  -1,134 -1,152 -2,125  -2,099 -2,113 -2,118 
  Interest on external debt  -271 -4,809 -4,007 0 -1,662  00  0 0 0 0
    Domestic arrears  3 702 -10,784 -8,423  -851 -5,619  -1,134 -1,152 -2,125  -2,099 -2,113 -2,118 
        Repayment  -9,391 -10,784 -13,629  -851 7,985 -1,134  -1,152 -2,125  -2,099 -2,113 -2,118 
          Accumulation  10,093 0 5,206 0 2,366 0 0  0 0 0 0
  Of which : float  2,849 2,761 2,071
Overall balance (cash basis)11,579 -5,982 1,736 -4,771  -4,167 -3,388 296 -3,919  -5,148 -4,465 3,523 
      Excludin g grants -16,795 -35,046 -28,258  -19,945 -20,280 -19,659 -25,616 -27,948 -29,376 -29,869 -30,802
Special adjustment4 -3,900 3,900
  Errors and omissions  -324 0 -28 0 -109 0 0  0 0 0 0
Financin g -1,255 1,859 2,192 83  376 -1,571  -296 -748 -2,381  -3,229 -3,533 
   Forei gn (net)  -2,387 2,605 2,911 -1,466  -404 -2,021  -2,510 -2,087 -2,450 -2,813 -3,011 
      Drawin gs, PIP (identified) 60 866 548 448 31  478 31 537 551 592 635
   Amortization  -2,239 -4,132  -2,773 -2,722 -2,772 -2,721 -2,755 -2,625  -3,001 -3,405 -3,647 
     Before reschedulin g -2,560 -2,503  2,514 -2,443  -2,461 -2,424 -2,193  -2,318 -2,388 -2,329 
      On restructured obligations -1,572  -271 -208 -330 -259 -332 -432 -683  -1,016 -1,318 
  Clearance of deferred arrears and debt service5-5,016
  Chan ge in net arrears (principal)  -1,155 -13,937 -10,337  0 -3,470  00  0 0 0 0
  Exceptional financin g 5,964 19,808 15,472  807 5,808 221  215 0  0 0 0
      Arrears restructurin g and deferral  18,700 14,415 0 5,014 0 0  0 0 0 0
      Current maturities restructurin g and deferral 1,108 1,057 807 795 221  215 0  0 0 0
Domestic (net)  1,131 -746 -719 1,549 780 450  2,214 1,339  69 -416 -522 
    Bank financin g 1,131 -746 -719 1,549 780 450  2,214 1,339  69 -416 -522 
    Central Bank  1,357 -333 -770 1,756 1,951 761  2,214 1,516  296 -303  -422 
  Of which : IMF 21,697 920 920 0 891 0 1,829 1,831  -265 -764 -1,047 
     Commercial banks  -226 -413 51 -207 -1,171  -310 0  -177 -227  -113 -100 
Financing gap  2  (+ = underfinancin g) 0 4,123 0 4,689 0 4,958  0 4,668 7,529 7,694 7,057  
Memorandum items : 
     GDP (nominal)  189,531 201,028 201,833 212,732 215,919  226,823 228,294  244,294 262,375 281,794 302,593
Debt service to be paid in cash6 2,343 2,038 1,727 1,913 2,280 2,343 3,368  3,735 4,088 4,277  
Wages in percentage of revenues  64.5 61.9 64.1 60.8  52.9 54.3 57.4 52.4 49.2 46.1 43.4 
Sources : Mainistére des finances;estimations des services du FMI.
1 Revenue for 2011 includes exceptional "economic citizenship programme" receipts.
2 Starting with the third ECF review, programme projections incorporate all identified grants and IMF support.  
3 Performance criteria and benchmarks on accumulation of arrears exclude float.  
4 2010 revenues recevied in early 2011.  
5 Includes deferral of arrears to the HIPC decision point, following which these arrears are assumed to be cleared through restr ucturing or further deferral.  
6 Net of HIPC interim assistance from mid 2010 to 2012.Table 4.A Comoros – Consolidated Government Financial Operations,2009–2016
(In millions of Comorian francs, cumulative since end of previous year, unless otherwise specified)