E-Government Development in Comoros

The ICT sector in the Union of the Comoros is overseen by three key public institutions, each with a distinct but interrelated mandate: the National Digital Development Agency (Agence Nationale de Développement du Numérique, ANADEN), the National Regulatory Authority for Information and Communication Technologies (Autorité Nationale de Régulation des TIC, ANRTIC), and the Ministry of Posts, Telecommunications and Digital Economy (Ministère des Postes, Télécommunications et de l’Economie Numérique).

ANADEN, established by Decree No. 19-014/PR, is tasked with leading the country’s digital development efforts. It is responsible for implementing the national digital strategy, Digital Comoros 2028 (Comores Numérique 2028), adopted by the Council of Ministers in 2019. In addition to programme execution, ANADEN works on cybersecurity frameworks, promotes innovation and digital entrepreneurship, and advises the government on improving the digital sector’s business environment. It also supports skills development and ensures coordination across various public digital initiatives. 

The Ministry of Posts, Telecommunications and Digital Economy, as defined in Law No. 08-007/AU, is responsible for setting national ICT policy and strategic direction. It prepares and oversees the sector’s master plans and coordinates Comoros’ engagement in regional and international ICT initiatives. The ministry relies on the expertise of ANRTIC and ANADEN to carry out its functions and may commission ANRTIC to conduct sector studies or policy-relevant assessments. It also oversees the Universal Service Fund, which is managed by the Ministry of Finance and supports infrastructure expansion and digital inclusion. In cases involving the extension of services or network access, the ministry may direct ANRTIC to launch public tenders, based on consultations with the Ministry of Finance regarding subsidy use.

ANRTIC, created by Decree No. 09-065/PR, is the independent regulator for the ICT sector, with legal and financial autonomy. Its core responsibilities include enforcing ICT legislation, issuing licenses, allocating and supervising radio frequency spectrum, and ensuring compliance with service and technical standards. ANRTIC promotes fair competition, resolves disputes between operators, and safeguards consumer rights. It also provides legal and regulatory advice to the ministry, particularly in the context of Comoros’ participation in international or regional frameworks. Although not engaged in commercial or investment-heavy activities, ANRTIC conducts technical, legal, and economic studies to support evidence-based regulation and may be assigned specific mandates by the ministry.

Cybersecurity/Cybercrime Law

Decree No. 22-003/PR promulgating Law No. 21-012/AU on cybersecurity and the fight against cybercrime

The law defines the functions of the National Digital Development Agency (ANADEN), regulates the provision of trusted digital services, and introduces security requirements for networks, information systems, and critical digital infrastructure, including cryptographic tools and services. It also covers offences related to the misuse of ICTs, personal data violations, intellectual property infringements, and unlawful activities on electronic communication networks. Responsibilities of online service providers are specified, and existing criminal provisions are adapted to the digital context, including rules for prosecuting cybercrime.

Data Privacy Law

Law No. 14-029/AU on the Protection of Personal Data 

The law regulates the processing of personal data, defines individual rights, and sets obligations for data controllers. It establishes the National Commission on Information Technology and Civil Liberties (CNIL) as the supervisory authority and outlines applicable sanctions.

E-Government Standards

Some principles on electronic public services are included in Decree No. 14-197/PR and Decree No. 15-091/PR, but regulations defining E-Government Standards have not yet been adopted.

E-Government Interoperability Framework

Legal provisions defining the E-Government Interoperability Framework have not yet been established.

Electronic Signature Law

Although no dedicated legislation on electronic signatures has yet been adopted in the Union of the Comoros, Law No. 14-029/AU and Decree No. 22-003/PR recognize electronic signatures as a significant element of personal data and a mechanism for identity authentication that contributes to cybersecurity. Furthermore, Decree No. 20-D91/PR stipulates that, in the context of payment service agreements, electronic signatures and electronic documents possess the same legal validity as their handwritten equivalents.

AI Regulations

A regulatory framework for artificial intelligence has not yet been developed.

The Union of the Comoros adopted its first national digital strategy in 2019, titled Digital Comoros 2028 (Comores Numérique 2028), following approval by the Council of Ministers. Its implementation is led by the National Digital Development Agency (ANADEN), which was established to oversee the country’s digital transformation. The strategy is supported by the World Bank.

It focuses on six strategic areas: the digitalisation of public services, development of regulatory and institutional frameworks, cybersecurity, promotion of ICT, and human resources development, including improvements in IT education. The strategy also sets quantitative targets—raising the ICT sector’s contribution to GDP to 5% and attracting 30 billion Comorian Francs (approximately USD 67 million) in foreign direct investment by 2028.

Although limited infrastructure remains a key barrier, the strategy aims to increase this figure to 54%. In the area of e-administration, it provides for the development of 14 digital public platforms (referred to as “e-gouwshg”). The estimated budget for e-Government is 7.89 billion KMF (USD 17.5 million), or 15% of the total programme. Allocations also include 3.03 billion KMF (5.7%) for human capital, 2.28 billion KMF (4%) for regulatory frameworks, and 0.94 billion KMF (1.7%) for cybersecurity.

In 2022, in line with the objectives of the Digital Comoros Strategy, three public platforms were announced to be in their final stages of development and nearing launch. These include:

• Comoros Portal, designed as a one-stop platform for accessing digital public services;
• E-Registre platform, enabling online business registration and related procedures;
• Online Public Procurement Portal (Portail des Marchés Publics en Ligne), intended to manage the government procurement process. The initiative is supported by the World Bank.

Other platforms have also been introduced. The eRegulations Platform, developed in partnership with UNCTAD, provides step-by-step guidance on business registration, taxation, and investment opportunities. In addition, the country’s first digital agriculture platform, DIMAKOM, was launched by the Comorian government through ANADEN in collaboration with DIMAKOM-FERME.

The importance of digitalisation is also emphasised in the Emerging Comoros Plan 2020–2030 (Plan Comores Emergent, PCE), adopted in 2019. As part of a broader national agenda, the plan reinforces the goals of the Digital Comoros 2028 strategy, highlighting the need to strengthen legal and institutional frameworks, expand access to and use of ICTs, pool infrastructure, and diversify the digital sector beyond telecommunications. It envisions Comoros becoming an information society by 2030, with digitalisation contributing significantly to the national economy, supporting other sectors, and driving social transformation.

In 2024, the African Development Bank approved €9.51 million in financing for the Comorian Economic Digitalisation Support Project (Projet d’Appui à la Digitalisation de l’Économie Comorienne, PADEC), which has a total estimated cost of €22.53 million. The initiative is intended to support the country’s digital strategy by expanding infrastructure for digital public services. It includes the construction and operationalisation of a national data centre, the upgrade of a secondary facility, and the creation of a digital innovation incubator, to be operated through a public-private partnership. The project also foresees the development of a centralised digital administration platform, a range of e-services, a national public payment system, and a framework for interoperability and data exchange. It provides for the establishment of a National Authority for the Protection of Personal Data and Access to Information, as well as funding to improve digital skills training at the University of Comoros.

As one of the key outcomes of the Digital Comoros 2028 strategy and the Comorian Economic Digitalization Support Project, a new public administration data center was officially inaugurated in May 2025. The facility, co-managed by ANADEN and the state-owned operator Comores Cable, is a Tier 3 infrastructure designed to host government and private digital platforms securely. It plays a central role in improving data management, reducing reliance on foreign infrastructure, and enabling the rollout of digital services such as digital identity and e-government portals.

Currently, the Comoros does not have electronic identification (e-ID) technologies in place, and their introduction is not included in the Digital Comoros 2028 strategy. However, the development of such systems is part of the support components under the Comorian Economic Digitalization Support Project (PADEC). However, since 2010, biometric technologies have been partially integrated into the electoral process (see Section e-Elections for further details). 

One of the current initiatives related to digital identity, launched in March 2025, is the implementation of the MIX-ID system – a new platform for managing public sector personnel. The system replaces the outdated GISE (Gestion Informatisée des Structures et des Effectifs, or Computerised Management of Structures and Staffing) with a secure, reliable registry designed to eliminate duplicate and fictitious records. Led by the Ministry of Public Administration and the Directorate of Information Systems, the project also includes the issuance of biometric professional ID cards for civil servants and represents a significant step toward improving transparency and administrative efficiency in the public sector.

The Comoros is seeking to digitalise its tax payment procedures. At present, the eRegulations platform provides an overview of the main taxes applicable to businesses; however, the website of the General Directorate of Taxation and State Property (Administration Générale des Impôts et Domaines, AGID), the authority responsible for tax collection, remains inaccessible.

Source: eRegulations platform

Use of ICT in the education sector in the Comoros remains limited. Although the website of the Ministry of National Education (Ministère de l’Education Nationale, MEN) was launched in 2016, it does not offer access to any online services. However, the importance of digitalising education is acknowledged in both the Digital Comoros 2028 strategy and the Comorian Economic Digitalization Support Project (PADEC).

Digital Comoros 2028 recognises education as one of the key sectors expected to undergo a gradual digital transition through the development of local digital content and support for innovative start-ups in priority areas.

As part of its education component, PADEC focuses on strengthening digital capacity in higher education. It includes plans to renovate facilities at the University of Comoros and its technical institutes across the three islands, install campus-wide Wi-Fi, and introduce a digital information system to improve administrative and academic processes. The project also supports the development of new training programmes in artificial intelligence and cybersecurity, along with the creation of an AI laboratory, linking education reform to broader goals of economic diversification and resilience.

Comoros has an official Stratégie Nationale de Santé Numérique 2022–2026, though the document is currently not publicly accessible. Nonetheless, the country has taken concrete steps toward digital health, including the deployment of CI_MEDECIN, a clinical information system that supports physicians in managing consultations and maintaining comprehensive digital medical records. The system enables real-time data entry, prescription tracking, and integration of various clinical tools and administrative functions.

Source: CI_MEDECIN

In July 2024, an additional initiative was proposed by clinical research engineer Djamila Mohamed Saïd to digitise patient records using a cloud-based platform. The project, presented in the presence of the Minister of Health and WHO representatives, aims to improve data accessibility and care continuity. While welcomed by stakeholders, its implementation faces challenges such as limited IT infrastructure and low digital readiness among staff. The Ministry of Health reaffirmed its support for digital transformation.

ICT has not yet been integrated into the justice sector in the Comoros.

In 2010, the Comorian government launched the Project to Support the Modernisation of the Electoral Register, with technical and financial assistance from the UNDP. The initiative aimed to build a more reliable and transparent electoral system by introducing a biometric electoral register and issuing secure biometric voter cards. The project involved the creation of a centralized National Electoral Data Processing Center (CNTDE) and the rollout of biometric registration nationwide. Fingerprint and facial recognition data were used to uniquely identify voters and prevent duplication and electoral fraud.

By 2015, the biometric register had been completed, the CNTDE became operational, and approximately 70% of eligible voters had been registered. The electoral list used in that year’s elections was drawn from this new biometric database.

Public information on the continued integration of biometric technologies into the electoral process remains limited. However, in May 2023, the Independent National Electoral Commission (CENI) launched a revision of the electoral register across the Union of the Comoros. The process involved biometric registration of new voters, updates to civil registry data, and removal of ineligible entries. Final voter lists were to be prepared by the National Electoral Data Processing Center (CNTDE), suggesting that elements of the biometric infrastructure continue to be in use. Despite this, according to the 2024 UN E-Government Knowledge Database, Comoros currently registers no measurable level of e-participation (2024 EPART: 0.0000).

In May 2025, the Union of the Comoros launched its first Government Service Bus (GSB) as part of the operationalisation of the Tier 3 public administration data center, inaugurated on 19 May and co-managed by the National Agency for Digital Development (ANADEN) and Comores Câble. This infrastructure, with a hosting capacity of 44.4 terabits, is designed to securely host digital platforms for both the public and private sectors, and to centralise public data in line with international standards.

This initiative forms part of the national Digital Comoros 2028 strategy, which aims to increase the digital sector’s contribution to GDP to 5% and reduce the country’s dependence on foreign infrastructure.

Information and communication technologies (ICTs), including the Internet, are not currently utilised in the Comoros for environmental protection or related monitoring and management purposes.

e-Procurement

The Online Public Procurement portal (Portail “Marchés Publics en Ligne”) is intended to manage public procurement in Comoros at all stages of the process, from the preparation of tender documents to the awarding of contracts. The project is also supported by the World Bank. The platform has been announced but is not yet operational.

Business and Company Registration System

The eRegulations Platform allows for establishing a business, registering as a merchant and provides reference information on taxes to be paid, possibilities for investment, etc.

Source: eRegulations

The e-Registre platform, announced as part of efforts to digitize business registration procedures, is intended to allow for declaring business and carrying out the necessary procedures online. The project is led by the Ministry of Economy, Industry, Investments through the National Agency for the Promotion of Investments (ANPI) and supported by the World Bank through the Fourth Phase of the Regional Communication Infrastructure Programme (RCIP-4). As for now, the platform has not yet been launched.

Guichet Unique for Foreign Trade

The Guichet Unique for Foreign Trade, based on the SYDONIA platform (SYstème DOuANier Automatisé, or Automated System for Customs Data – ASYCUDA), was launched in 2018. However, as of now, SYDONIA World is operational primarily within the Customs Administration (Administration des douanes).

The Customs Administration, under the Ministry of Finance and Budget, is responsible for formulating and implementing customs policy, regulating international trade in goods, and overseeing revenue collection and enforcement activities. It operates through central and regional services, ensuring compliance across the national territory. Each autonomous island has its own regional customs office reporting to the central authority. 

Source: Sydonia World

In March 2022, DIMAKOM, the first digital agriculture platform in the Union of the Comoros, was launched. Initiated and funded by the Comorian Government through ANADEN, the platform is intended to support digital innovation in the agricultural sector. It facilitates the purchase of agricultural products by bringing together producers from all three islands – Anjouan, Mohéli, and Ngazidja – into a single online marketplace. The platform also offers reference information and contact details for registered farmers. As of April 2023, 16 farmers had registered on the platform. However, the platform is currently unavailable.

The Union of the Comoros has no AI solutions in use and no national strategy or policy framework dedicated to artificial intelligence.

National Best Practices

Medical Software – CI_MEDECIN platform

CI_MEDECIN is a digital tool designed to support physicians during medical consultations. It enables the creation and ongoing management of a complete patient record, including both personal and clinical data. The system provides access to all previous prescriptions when issuing a new one, supports real-time data entry, assists in selecting medications, lab tests, imaging, and vaccines, allows scanning and consultation of patient documents, manages appointments, and helps draft referral letters to other healthcare professionals.

Biometric Voter Registration – National Electoral Data Processing Center (CNTDE)

The introduction of biometric voter registration in Comoros represents a key digital solution to enhance electoral reliability and transparency. Launched in 2010 with UNDP support, the initiative led to the creation of a biometric electoral register and the establishment of the National Electoral Data Processing Center (CNTDE). This system, based on fingerprint and facial recognition, enabled the secure and unique identification of voters, significantly reducing duplication and fraud. By 2015, 70% of eligible voters were registered biometrically, and the new system was used in national elections. A follow-up biometric update of the voter registry in 2023 confirms the continued use of this infrastructure. While broader digital participation remains limited, the biometric system provides a tested foundation for future electoral digitalisation in the country.

Regional Inspirations

National E-Learning Platform – TelmidTICE (Morocco)

Launched in 2020 by Morocco’s Ministry of National Education, TelmidTICE is a bilingual (Arabic and French) digital education platform that provides nationwide access to interactive lessons, videos, and exercises. It supports virtual classroom management, allowing teachers to assign tasks and track student progress. Accessible on various devices, TelmidTICE has become a key tool for ensuring continuity in education, particularly during COVID-19-related school closures.

Digital Justice Platform – ECCMIS (Uganda)

Launched in 2022, ECCMIS (Electronic Court Case Management Information System) is Uganda’s comprehensive digital platform for managing the entire lifecycle of court cases—from filing to resolution. One of its core features is e-Filing, which allows users to submit case documents online through a public portal covering all case types and jurisdictions. The system also enables real-time access to case status via mobile phone and SMS, and provides automated notifications via SMS, email, and internal alerts to all involved parties.

Authors:
Pavel Bianki
Olesya Kalashnik

Reviewed by Abdoulfatah Ousseine, SG, Ministry of Energy, Water and Hydrocarbons of the Union of the Comoros