Regulatory Disclosures
Preamble
This page discloses Ustawi's ("Ustawi") corporate and regulatory status as a technology vendor, and clarifies the distinction between Ustawi's role and the regulatory status of the institutions that license our software.
1. Corporate Information
| Fact | Status |
|---|---|
| Legal entity name | Click Up Company Limited |
| Company registration number | 163520974 (the Business Registrations and Licensing Agency (BRELA)) |
| Registered address | Block 45C, Kijitonyama, Cameroon Road, Dar es Salaam, Tanzania |
| Country of incorporation | the United Republic of Tanzania |
2. Ustawi's Role
Ustawi is a software technology vendor. Ustawi provides a multi-tenant SaaS platform that microfinance institutions, SACCOs, VICOBA/VSLA networks, employers, and digital lenders use to operate their own lending, savings, and collections business. Ustawi is not itself a bank, deposit-taking microfinance institution, SACCO, or licensed lender, and does not itself extend credit, accept deposits, or hold client loan funds.
3. Licensing Status
Ustawi is a pure technology vendor and does not itself hold, or require, a Bank of Tanzania (BOT) microfinance license, deposit-taking authorization, or Tanzania Insurance Regulatory Authority (TIRA) license — Ustawi does not extend credit, accept deposits, or act as an insurer in its own right (see Section 2). Tenant institutions (MFIs, SACCOs, VICOBA/community groups, employers, digital lenders) hold their own Bank of Tanzania licenses under the Microfinance Act 2018's four-tier system: Tier 1 deposit-taking MFIs, Tier 2 non-deposit-taking MFIs/digital lenders, Tier 3 SACCOs, and Tier 4 community microfinance groups (including many VICOBAs). Ustawi provides the software tooling — PAR/classification reports, STR export formats — that supports each tenant's own regulatory reporting, but does not itself hold a license and does not file on a tenant's behalf unless separately contracted. This reflects Ustawi's own assessment of its status as a pure software vendor, is subject to final confirmation by legal counsel, and is not a determination by the Bank of Tanzania.
4. Tenant Institutions' Own Licensing
Each tenant institution using Ustawi is independently responsible for holding whatever license or registration its own business model requires under Tanzanian law (e.g. a BOT microfinance license, SACCO registration, or other applicable authorization). Using the Ustawi platform does not confer, imply, or substitute for any such license. Ustawi may support onboarding checks (e.g. verifying a tenant's registration status as part of commercial due diligence) but does not warrant or certify a tenant's regulatory compliance.
5. Regulatory-Alignment Design Intent
Ustawi's compliance and reporting tooling — PAR/classification/provisioning reports, recovery-notice-gated repossession workflows, statutory-clock complaints handling, AML screening and goAML export — is built with Bank of Tanzania microfinance regulatory alignment as an explicit product-design goal. This is a statement of design intent and tooling capability, not a claim that Ustawi itself is licensed, audited, or approved by BOT. See /legal/aml-kyc-compliance-statement for the AML-specific detail.
6. Data Protection Registration
Ustawi registers as a data controller/processor with the Personal Data Protection Commission (PDPC) as required under the Personal Data Protection Act, 2022. Registration particulars are indicative demo details to be finalised before launch.
7. Insurance App Disclosure
Where a tenant enables the credit-life/asset insurance app, Ustawi provides software tooling for policy issuance, premium posting, and claims tracking on behalf of the tenant's own arrangement with a licensed insurer or as an appointed agent thereof; Ustawi is not itself an insurer. Any insurance product is underwritten by a licensed insurer regulated by the Tanzania Insurance Regulatory Authority (TIRA); Ustawi's role is limited to software tooling and it does not underwrite, price, or bear insurance risk in its own right.
8. Complaints About Regulatory Status
Questions about this disclosure, or about a specific tenant's licensing status, should be directed to /contact (for Ustawi's own status) or to the tenant institution directly (for that institution's licensing) — see /legal/complaints-and-dispute-resolution for the general complaints process.
9. Changes to This Disclosure
This page will be updated promptly whenever Ustawi's corporate or regulatory status changes materially.
Frequently asked questions
Is Ustawi a bank or licensed lender?
No — see Section 2. Ustawi is a software vendor; it does not extend credit, accept deposits, or hold client loan funds.
Does Ustawi hold a Bank of Tanzania license?
No — as a software-only vendor Ustawi does not itself require a BOT license (Section 3); each tenant institution holds its own license under the Microfinance Act 2018.
Who is responsible for my lender's regulatory compliance — Ustawi or my lender?
The lender (tenant institution) — see Section 4.