An assessment of digital trade regulations in Rwanda and Uganda

Rwanda and Uganda have placed digital trade at the centre of their national development strategies and regional integration efforts, including within the framework of the recently concluded African Continental Free Trade Area (AfCFTA) Digital Protocol negotiations. 

In both countries, long-term development plans – such as Rwanda’s  Vision 2050 and Uganda’s Vision 2040 and Digital Uganda Vision, as well as more operational strategies like Rwanda’s National Strategies for Transformation (NST1: 2017-2024 and NST2: 2024-2029) and Uganda’s Digital Transformation Roadmap – recognise digital transformation as a key driver of economic growth, improved service delivery, and institutional efficiency.

While digital trade is seen as a pathway to greater competitiveness and inclusive growth, a key question remains: are national policy aspirations reflected in the actual regulatory environment? Recent research funded by the International Growth Centre addresses this question by examining the legal and institutional frameworks in Rwanda and Uganda. 

The analysis combines desk research on primary and secondary sources with qualitative data collected in 2024 and 2025 through interviews, surveys, and focus group discussions with over 80 stakeholders, including startups, established firms, regulators, and business support organisations.

Untapped potential of digital trade in Rwanda and Uganda

Despite strong policy interest and growing regional integration efforts, both Rwanda and Uganda continue to record relatively low volumes of digital trade. As summarised in Figure 1 below, exports of information and communications technology (ICT) goods remain modest – at USD 18 million for Rwanda in 2022 and USD 9 million for Uganda in 2023, representing just 0.9% and 0.15% of their total exports, respectively. 

These shares fall below the African regional average of 1% and are far behind the global average of 11.5%. While both countries have invested in initiatives to develop ICT manufacturing, such as Rwanda’s Mara Phones and Uganda’s SIMI Mobile, these have yet to translate into significant export growth.

Figure 1: Total export volumes and share in goods exports of ICT goods in 2023

Digital services exports also show a weak performance (Figure 2). In 2023, Uganda exported USD 285 million in digital services (13.9% of total services exports), compared to Rwanda’s USD 60 million (5.7%). Still, both countries remain below Africa’s average of 26.5%, and well below the global benchmark of 56.4%. These figures highlight the untapped potential of digital trade as a driver of export diversification and competitiveness.

Figure 2: Total export volumes and share in total goods exports of digital services in 2023

Regulatory framework of digital trade in Rwanda

Building on the Digital Trade Integration (DTI) methodology, Figure 3 compares Rwanda’s regulatory framework with the regional average across the 12 policy pillars of the DTI database, which cover policies and practices in 12 policy areas.

Figure 3: Comparing restrictions and enabling policies in Rwanda with the African average in 2023

Rwanda’s regulatory framework is more restrictive than the regional average in cross-border data policies, domestic data policies, and content access (pillars 6, 7, and 9), with roughly twice as many measures. Restrictions in telecom, quantitative trade (pillars 5 and 10), and technical standards (pillar 11) broadly align with the regional trend. In contrast, Rwanda applies fewer restrictions in areas such as tariffs, procurement, investment, IPRs, intermediary liability, and online transactions (pillars 1, 2, 3, 4, 8, and 12). It shows higher overall activity in enabling measures, especially in pillars 4, 8, and 12.

Stakeholders expressed concerns about data transfer requirements and compliance burdens that can disproportionately affect startups. Some of the recommendations – listed in a forthcoming policy report presenting a detailed analysis of the regulatory environment for digital trade in Rwanda and Uganda – include:

• Lower tariffs on ICT goods and consider joining the World Trade Organization’s Information Technology Agreement (ITA)
• Clarify data transfer regulations and avoid overlapping requirements
• Streamline registration of data controllers and offer fully online procedures for registration
• Strengthen inter-agency coordination in data governance
• Enforce IPRs and consider ratifying the World Intellectual Property Organization (WIPO) Internet Treaties
• Promote regional regulatory harmonisation through the East African Community (EAC) and AfCFTA

Digital trade policies and practices in Uganda

Turning to regulatory policies in Uganda, the country demonstrates comparatively higher numbers of restrictive regulations in public procurement, telecom infrastructure and competition, cross-border data policies, domestic data policies, content access, and quantitative trade restrictions related to ICT goods and online services (pillars 2, 5, 6, 7, 9, and 10) (Figure 4).

Figure 4: Comparing restrictions and enabling policies in Uganda with the African average in 2023

Conversely, Uganda imposes fewer restrictions than the regional average in tariffs, foreign investment, IPRs, intermediary liability, and online sales and transactions (pillars 1, 3, 4, 8, and 12). It also outperforms the regional average in enabling measures across most pillars, with particularly strong activity in pillars 4, 8, and 12, where it has adopted more than twice the number of enabling policies. 

The interviewed stakeholders pointed to limited institutional coordination, a lack of transparency, and blocking online content and internet connections as key restrictions for conducting business online. Some of the recommendations listed in the report include:

• Improve transparency and address bribery concerns in customs procedures and public procurement
• Limit internet shutdowns and content blocking
• Increase regulatory independence in the telecom sector
• Strengthen data governance coordination across agencies and streamline approvals for registration and data transfers
• Modernise the Electronic Transactions Act and licensing processes
• Support startups via tax incentives, sandboxes, and ad hoc mechanisms

Making digital trade reforms work in low-income economies

The report confirms that Rwanda and Uganda see digital trade as a key component of their economic transformation strategies. Rwanda has prioritised regulatory innovation, introducing streamlined procedures, sandbox initiatives, and incentives for digital entrepreneurs, while Uganda has focused on aligning its regulations with international standards and expanding enabling policies. Yet, persistent challenges remain in both countries, including regulatory uncertainty and broader structural barriers such as limited market size, skills gaps, and weak regional integration.

Our analysis underscores that regulatory reform must go beyond new rules, prioritising coherence between policy objectives and implementation, improved institutional coordination, and continuous engagement with the private sector. Advancing regional convergence – particularly within the EAC and AfCFTA – is also essential, especially in data governance, licensing, and customs. Development partners can support these goals by strengthening institutional capacity and promoting regional policy harmonisation to unlock the full potential of digital trade.

Our findings complement global lessons highlighted in recent international research. A 2023 study by the United Nations Economic and Social Commission for Asia and the Pacific and IGC on digital trade in least developed countries (LDCs) emphasises that weak regulatory coherence, limited institutional capacity, and fragmented cross-border digital frameworks remain common barriers in digitally transforming low-income economies. 

Beyond regulations: Unlocking the full potential of the digital economy

While regulatory policies and practices significantly affect digital trade, it is important to note that a conducive regulatory environment for digital trade is only one of the factors needed to unlock the full potential of the digital economy.

Other important factors include sustained investments in ICT infrastructure, targeted support for research and development, accessible capital markets, an efficient ecosystem for online payments, and a robust system for developing digital and entrepreneurial skills. Only by integrating regulatory reform with broader structural measures can Rwanda and Uganda fully harness digital trade as a driver of inclusive, long-term economic transformation.