Cameroon enters the era of zero-tolerance for e-Procurement enforcement

Circular No. 000002 of 19 February 2026 Imposes Full Dematerialisation and Financial Gatekeeping for e-Procurement

In a decisive regulatory shift, the Minister Delegate at the Presidency in charge of Public Contracts has issued Circular No. 000002 of 19 February 2026 (the Circular), marking the formal transition from facilitative implementation to strict enforcement of Cameroon’s electronic procurement regime.

Nearly seven years after the adoption of Decree No. 2018/0001/PM and Decree No. 2018/0002/PM, the Circular removes residual ambiguities surrounding dematerialisation and establishes a zero-tolerance compliance framework.

The circular introduces systemic financial controls, strengthens procedural invalidity rules, and elevates operational requirements for contracting authorities and project stakeholders.

The message is unambiguous: offline procurement is no longer merely irregular — it is commercially unsustainable.

1.     Exclusive and Mandatory Use of the COLEPS Platform

The Circular confirms that the Cameroon Online E-Procurement System (COLEPS) constitutes the sole legally permissible channel for public procurement procedures.

All Contracting Authorities, including Project Owners, Delegated Project Owners, and Tenders Boards must:

• Publish all calls for tenders, addenda, and contract awards exclusively on COLEPS;
• Ensure simultaneous publication with the Public Procurement Journal (JDM) on the same date;
• Conduct the entirety of procurement procedures online, including restricted tenders and pre-qualification processes.

Critical consequence:

The Circular effectively eliminates parallel or hybrid processes. Any pre-qualification conducted outside COLEPS is automatically null and void.

2.     Closure of the “Mutual Agreement” Compliance Gap

The Circular definitively clarifies that contracts awarded by mutual agreement are not exempt from dematerialisation requirements.

Processing through COLEPS is now mandatory, subject only to a narrowly circumscribed derogation applicable to certain Project Owners statutorily excluded from electronic procurement and strictly limited to the 2026 fiscal year.

This measure substantially restricts the historical use of offline negotiated contracting.

3. Operational Validity: The Electronic Certificate Requirement

Access to and transaction capability on COLEPS requires a valid, annually renewed electronic certificate. The Circular imposes a valid certification for:

• The Project Owner / Delegated Project Owner / Contracting Authority;
• The Head of the Internal Procurement Unit;
• The Chairperson and Secretary of the Tenders Board (where applicable).

Compliance risk:

Failure to secure or renew these certificates may compromise the legal validity of procurement procedures and delay or invalidate contract awards.

Electronic certification is no longer an administrative formality; it is a precondition for procedural existence.

4.     Strict Enforcement of Procurement Programming

All procurement operations must be pre-programmed and validated online before launch. Where established timelines cannot be respected:

• The procurement plan must be formally updated on COLEPS, and
• A fully reasoned justification must be submitted before tender launch or publication of award results.

This introduces a heightened planning discipline and reduces discretionary deviations.

5.     Backup Copies: Exceptional and Regulated Use Only

The Circular sharply restricts the use of backup copies in electronic tenders to prevent procedural manipulation.

Key principles:

• A bid validly submitted online cannot be rejected solely for the absence of a backup copy.
• Backup copies may only be opened in strictly defined circumstances:

• Backup copies cannot be accepted after the submission deadline.

The regime aims to preserve the primacy and integrity of the digital submission system.

6.     Financial Controllers as Compliance Gatekeepers

The most consequential innovation of the Circular lies in its systemic financial enforcement mechanism.

Financial Controllers and Public Accountants are expressly instructed to reject any financial commitment relating to procurement procedures that were:

• Launched offline, or
• Awarded offline (outside statutory exceptions).

This effectively renders non-compliant contracts financially unenforceable.

The Circular transforms financial authorities into frontline enforcement actors, aligning payment validation with procedural legality.

7.     Exposure to Annulment and Sanctions

Non-compliance may result in:

• Annulment of the entire procurement procedure;
• Regulatory and disciplinary sanctions against responsible officials;
• Exclusion from participation in future public contracts.

Independent observers are expressly mandated to report irregularities directly to competent authorities, reinforcing oversight intensity.

Strategic Implications

Key implications include:

1.     End of transitional tolerance: The grace period for partial or hybrid implementation has closed.

2. Strict liability environment: Procedural defects now carry automatic financial and legal consequences.

3. Governance accountability: Senior procurement officials face heightened exposure to regulatory scrutiny.

4. Commercial risk realignment: Contractors must independently verify procedural compliance before mobilising resources.

For private operators, the risk is no longer merely administrative; it is economic.

Recommended Immediate Actions

We recommend that contracting authorities and private sector participants:

1. Conduct a comprehensive compliance audit of ongoing and recently concluded procurement procedures.

2. Verify the validity of all electronic certificates and initiate immediate renewal where necessary.

3. Reassess internal protocols governing tender handling and backup copies.

4. Confirm proper programming and validation of all procurement plans on COLEPS.

5. Implement targeted compliance training for Tenders Boards and procurement units focused on financial and sanction risks.

How We Can Assist

Our Projects and Public Procurement team advises public entities, EPC contractors, infrastructure sponsors, and financial institutions on procurement compliance, regulatory exposure, and risk mitigation.

We provide:

• Independent compliance audits;
• Pre-award procedural risk reviews;
• Training for procurement authorities and Tenders Boards;
• Advisory support in the event of annulment or sanction exposure;
• Strategic engagement with supervisory authorities.

Contacts

For further information or assistance, please contact us.

This publication is provided for general information purposes only and does not constitute legal advice. Specific advice should be sought in relation to particular circumstances.