One base, many markets: building software for the whole continent

The AfCFTA promises a single market of 1.3 billion people, but digital trade rules and data protection laws still differ country by country. What software builders need to know.

Africa has 54 countries, dozens of currencies and hundreds of languages. For a software company based in one of them, the rest of the continent is both the biggest opportunity and the biggest headache. The African Continental Free Trade Area (AfCFTA) is meant to make that easier. For software in particular, the rules are still being written.

This article sets out what the AfCFTA means for software builders today, what is still to come, and the data protection laws you need to respect in the meantime.

The size of the prize

The AfCFTA brings together 55 countries with about 1.3 billion people and a combined GDP of around US$3.4 trillion, according to the US International Trade Administration. Almost every African Union member state has now ratified the agreement; recent counts put the number at around 49 or 50, although sources differ slightly on the exact figure.

Trade in goods under the agreement started through a pilot called the Guided Trade Initiative, which has since grown to dozens of participating countries. For physical goods, tariff schedules and rules of origin are gradually coming into effect.

Digital trade: agreed, but not yet in force

Software, online services and data flows are covered by a separate Digital Trade Protocol. The African Union adopted the protocol in February 2024, and eight annexes covering topics such as cross-border data transfers were adopted in February 2025.

The protocol is not yet in force. It needs 22 ratifications and takes effect 30 days after the last one. Nigeria's Federal Executive Council approved ratification in November 2025, and others are moving, but until the threshold is reached, digital trade across African borders is governed by each country's own laws.

The cross-border data annex is worth watching closely. It sets up an adequacy-based system, in which data can flow freely between countries whose own laws meet a common standard. For SaaS companies that store customer data in one place and serve customers in many, that could eventually simplify a great deal.

Data protection laws, country by country

Most of the larger African markets now have data protection laws. A few that matter for builders based in Southern and East Africa:

CountryLawRegulator
ZimbabweCyber and Data Protection Act, 2021POTRAZ, acting as the Data Protection Authority
South AfricaProtection of Personal Information Act (POPIA), 2013Information Regulator
KenyaData Protection Act, 2019Office of the Data Protection Commissioner
NigeriaNigeria Data Protection Act, 2023Nigeria Data Protection Commission

The details differ, but the principles are broadly similar to Europe's GDPR: collect only what you need, tell people what you do with it, keep it secure, report serious breaches, respect people's right to see and correct their data, and be careful about sending it to countries without adequate protection. Zimbabwe's Act, for example, restricts transfers of personal data outside the country unless adequate protection exists, with specific exceptions.

This is general information, not legal advice. Before you launch in a new country, check its current rules with a local lawyer.

A practical playbook for multi-country software

Build once, configure per country

Currencies, taxes, languages, phone number formats, date formats and payment methods should all be settings, not code. Adding a country should mean filling in a profile, not rebuilding the product.

Localise more than the language

Demo data, names, street addresses and examples should feel local to each market. A sales team in Lusaka will trust a product more if the examples look like Lusaka.

Design for data protection from the start

Keep a record of what personal data you hold and why. Make it easy to export or delete a customer's data. Encrypt data in transit and at rest, and keep audit trails of who changed what. These are good engineering habits, and they satisfy most of what regulators ask.

Choose your contracting entity carefully

Customers in other countries want to know who they are signing with and under which law. Many studios hold contracts in one parent company and add regional entities where payments or tax require them.

Expand in a deliberate order

Neighbouring markets with similar languages, currencies and business habits are usually the easiest next step. A Zimbabwean product might look first at Zambia, Botswana and South Africa before moving further afield.

Do not stop at Africa

Software built to handle many African markets is already built for complexity. The same features, multiple currencies, multiple languages, mobile-first design and flexible payments, make it a strong product anywhere in the world.

The opportunity

The AfCFTA will not remove every barrier overnight, and the digital protocol is not yet law. But the direction is clear: towards a larger, more connected African market with common rules for data. Companies that build for many markets now, while respecting each country's laws, will be ready when the doors open fully.

Written by the Next Foundry team. We build software companies for businesses around the world. Spotted an error? Tell us and we will correct it.