Registering a VICOBA in Tanzania: GN 678/2019 and WEZESHA

This page is the VICOBA registration operating file: which instrument a savings group registers under, which desk holds the pen, and what must sit in the file before a council date-stamps it. It is not a constitution template.

• The tier a commercial lender sits in — the microfinance licence guide
• When the money is charitable, not member-owned — NGO, society or trust
• The account regulation 20 obliges — bank account KYC
• A member’s own trading name — business name registration
• The trustee route a community fund needs — incorporation of trustees

As at 21 September 2026. Confirm the live position on bot.go.tz and mof.go.tz; this file rests on the Microfinance Act, 2018 and the Microfinance (Community Microfinance Groups) Regulations, GN No. 678 of 2019.

Ten to fifty, sharing a common bond, and nobody else

Regulation 4(2) fixes the roll: ten to fifty persons who have a common bond in respect of the group’s activities. Nine cannot register. Fifty-one cannot register. A larger community forms a second group rather than stretching the first.

Regulation 4(1) has the group formed by individual persons, so a company cannot take a seat, a cooperative cannot, and neither can another savings group. The bar is on the kind of member, not the origin — the Regulations set no citizenship test. What they test is the common bond, which the ward or village authority attests to in the reference letter regulation 8(2) demands. The Ministry of Finance puts the practical version plainly: members drawn from one area, so the local government can identify them, behind one shared purpose. A roll assembled across three wards produces a letter nobody signs.

Tier 4 is registered; there is no licence to buy

Section 5 of the Microfinance Act, 2018 sorts providers into four tiers: Tier 1 deposit-taking institutions, Tier 2 non-deposit-taking providers including individual money lenders, Tier 3 SACCOS, and Tier 4 community microfinance groups. A VICOBA is Tier 4 and holds a certificate of registration. Anyone quoting a Bank of Tanzania licence number for a savings group is describing a document that does not exist.

The counter moved in 2019. Government Notice No. 888, published alongside GN No. 887 which sent Tier 3 to the Tanzania Cooperative Development Commission, placed the Bank’s Tier 4 powers with local government authorities — city, municipal, town and district councils. The Bank wrote the rules and hears the appeal; the council registers. Its Financial Sector Supervision Annual Report for 2024 records 58,926 groups on the register at 31 December 2024, of which councils registered 10,642 that year.

Two meetings, then the constitution the Schedule demands

Regulation 5 requires an initial meeting of the intending members, which elects an Interim Committee. Regulation 6 gives that committee its work — proposed name, draft constitution, member list, notice of the formation meeting — and regulation 7 is that meeting, where the name is adopted, the constitution approved and the leaders proposed. Regulation 8(2) then asks for two copies of the constitution and two of the formation minutes, each signed by all members. Signed by all members: anyone absent is brought back to sign, and the register does not take a chairperson signing for the roll.

The First Schedule sets thirteen heads the constitution must cover: name and contacts; place of business and area of operation; objectives; membership; governance; meetings; proceedings; operations, including fund mobilisation and loan procedure; distribution of surplus; reporting and records; complaints; dissolution; and amendment. Two cause almost every return — the share-out rule every group runs by custom and few write down, and the loan procedure, where three referees and a two-week wait vanish on paper.

Regulation 9 disposes of the trading name: unique, containing the words “Community Microfinance Group”, free of the word “bank”. Upendo VICOBA registers as Upendo Community Microfinance Group.

The file regulation 8 actually demands

Council counter, or the WEZESHA portal

Two doors, one file. The paper route runs through the local government authority holding delegated Tier 4 powers under GN No. 888 of 2019 — in practice the ward development officer upward to the council’s community development desk. The digital route is the WEZESHA portal, which the Ministry of Finance has directed community microfinance groups to register on and describes as carrying no charge whatsoever.

Either way, regulation 10 gives the authority fourteen days from receipt of the complete documents to determine the application. The word doing the work is complete: the fourteen days do not begin on the day a group arrives with most of the file.

The sequence the desks take

1. Test the roll first. Ten to fifty individual persons, with a common bond the ward will vouch for.
2. Hold the initial meeting under regulation 5 and minute the election of the Interim Committee.
3. Clear the name — unique, carrying “Community Microfinance Group”, free of the word “bank”.
4. Let the Interim Committee finish regulation 6: draft constitution, member list, notice of the meeting.
5. Hold the formation meeting, adopt the name and constitution, propose leaders, sign both copies in the room.
6. Evidence the subscriptions, because the member list must carry proof of payment, and obtain the ward or village reference letter, the one document nobody inside the group can produce.
7. Lodge Form No. 2 with the regulation 8(2) annexes at the council or on WEZESHA, and keep the receipt.
8. Take Form No. 3, meet within one month, open the account and begin operating within three months.

What registration costs, and what the fee buys

GN 678 prescribes no registration fee — no application fee, no certificate fee, nothing in its schedules. The contrast is deliberate: other tiers carry stated licence fees and Tier 4 carries none. The Ministry of Finance describes the portal route the same way, as carrying no charge at all.

So the only cash is drafting and lodging. Zatra’s published fee is TZS 500,000 per group, covering the constitution drafted to the First Schedule, the formation minutes, the Form No. 1 resolution, the member list and the lodging, in five to ten working days. The council’s fourteen days run after that, not alongside it. Across ten members the fee is TZS 50,000 each; across thirty, TZS 16,667; at the fifty-member ceiling, TZS 10,000. Statutory registration adds TZS 0 to every line.

Set it against regulation 31: a fine of not less than TZS 1,000,000 and not exceeding TZS 10,000,000, or imprisonment of three months to two years, or both. The floor is twice the whole registration cost of a group and the ceiling twenty times it, and it attaches to the person, because no company stands between the leaders and the penalty.

What the group may do, and what it may never do

Regulation 19(1) is short: mobilise contributions from members, grant loans to members, mobilise funds for their social and economic welfare. Regulation 19(2) is shorter and harder — no savings from non-members, and no branch, agency or outlet. The moment a VICOBA takes money from a neighbour who is not on the member list it is outside the provision it registered under, and it cannot repair that by opening a circle in the next street. The lawful answer is a second registered group.

Regulation 24 runs the other way. A group may link with banks, non-financial organisations and training bodies and borrow to on-lend, but the loan shall not exceed the total assets of the group unless guaranteed by collateral fully covering it. That is the ceiling on every facility a bank offers a savings group.

The clock that starts at the certificate

The certificate issues in Form No. 3 under regulation 11 and stays valid unless cancelled, so there is nothing to renew. Regulation 12 gives the Interim Committee one month from receipt to hold the first meeting. Regulation 18 gives the group three months from registration to begin operating, and one that does not receives a fourteen-day notice before cancellation — the most avoidable way to lose a certificate that cost nothing.

Regulation 20 sets the standing duties: a physical address, an account with a bank or financial institution, minutes, a membership register and copies of the constitution kept, accounts monitored or audited, and a person appointed for internal control. That appointee is a real constraint in a village group, because regulation 26 requires a person of integrity holding at least an ordinary certificate of secondary education. Regulation 21 adds a quarterly report in the Third Schedule format, and regulation 27 sends member credit information to credit reference bureaus on written consent.

Refusal, appeal and cancellation

Regulation 13 allows refusal in writing where the application does not meet the requirements or the information is inaccurate; regulation 14 lets the group reapply once the deficiency is corrected. Regulation 15 sets thirty days from that notice to appeal, and the forum follows the decider — to the Bank where a Delegated Authority refused, to the Minister where the Bank refused. Appealing to the wrong one burns the thirty days.

Afterwards, regulation 25 gives the authority reports, complaints and official visits, and the power to direct that anomalies be rectified within twenty-one days. Regulation 17 covers cancellation for breach, and regulation 32(2) allows measures short of prosecution — suspension of profit distribution, suspension of leaders, a rectification order, cancellation of the registration. Regulation 30 points the other way, letting a group meeting a higher tier’s criteria apply to transform into it.

Where this file stalls

• A roll of fifty-two, where two members must be minuted out or a second group formed.
• A constitution copied from a neighbouring group, still carrying its name in the dissolution clause.
• Minutes signed by the committee rather than by all members, which regulation 8(2) refuses.
• Subscriptions collected in cash with no receipt book, so the member list cannot evidence payment.
• Quarterly returns never filed, found on a monitoring visit rather than a calendar.

Mandate-holders this file does not replace

The local government authority holds the register, the fourteen days and the certificate under GN No. 888 of 2019. The Bank of Tanzania owns the Tier 4 framework, the Regulations and the appeal against a council’s refusal. The Ministry of Finance owns the policy and the WEZESHA route, and the Tanzania Cooperative Development Commission holds Tier 3. The bank applies its own due diligence to the account regulation 20 obliges. Zatra drafts, structures and lodges; it does not register the group, issue any certificate, or practise law or audit.