Nikolai Timofejev
15 years in FinTech and payments. Maps your business model to the right licence scope and leads the file all the way to the National Bank's licence, including banking and payment rails.
Get a payment license in Ethiopia.
Ethiopia licenses payments through the National Bank of Ethiopia under the National Payment System Proclamation No. 718/2011, as amended by Proclamation No. 1282/2023 of 3 February 2023. A payment instrument issuer is licensed under Directive ONPS/09/2023, in force since 6 October 2023 and amended by ONPS/10/2025 on 12 May 2025, on paid-up capital of Birr 100,000,000 - roughly USD 738,700 at the National Bank's 2024/25 weighted average of 135.37 birr to the dollar. A payment system operator is licensed under ONPS/02/2020, from Birr 3 million for a payment gateway up to Birr 300 million for the national switch. Both directives give the National Bank 60 calendar days to answer. The sector is open to foreign investors, but a single shareholder is capped at 40% of an issuer unless it is a government, a telecom operator, a licensed issuer or a licensed operator.
27 yrs
on the international marketon the market
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in-house specialistsspecialists
400+
Licenses obtainedlicenses obtained
Updated
Ethiopia in brief
Two directives, one hundred million birr, and a forty percent ceiling.
The statute is the National Payment System Proclamation No. 718/2011, published in Federal Negarit Gazeta No. 84 on 18 July 2011 and amended by Proclamation No. 1282/2023 of 3 February 2023. The amendment did the definitional work: it inserted payment instrument issuer, electronic money, company, subsidiary and foreign national into Article 2, and it put issuers and operators inside the definition of a financial institution. Everything else lives in directives, and the chain is worth getting right because most secondary sources still quote repealed text. Directive ONPS/09/2023, in force 6 October 2023, repealed ONPS/01/2020, ONPS/03/2021 and ONPS/06/2022 by its Article 19(1). Directive ONPS/10/2025, in force 12 May 2025, then amended ONPS/09/2023 and lifted the paid-up capital of a payment instrument issuer from Birr 50 million to Birr 100 million, payable in cash into a blocked bank account in the name of the issuer under formation. An issuer already licensed below that figure has until the end of June 2027 to reach it, under the new Article 17(1). The operator directive, ONPS/02/2020, survives; only its fee articles 4.8 and 4.24 were repealed, by ONPS/07/2022. Article 4.7 prices operators by system: Birr 300 million for the national switch, 40 million for a switch, 20 million for an ATM operator, 10 million for point of sale and 3 million for a payment gateway.
Foreign money is admitted and foreign control is not. ONPS/10/2025 inserted Article 4(b)(vii): no person other than a government, a telecom operator, a licensed payment instrument issuer or a licensed payment system operator may hold more than 40% of an issuer's subscribed shares, and sub-article (viii) caps direct and indirect holdings together at 60%. A foreign fintech that is none of those four things cannot own its Ethiopian issuer outright, and needs either the exemption or local partners. Article 4(6) requires a foreign national to pay the minimum capital in foreign currency, and Article 4(7) requires evidence of an investment protection fee whose amount the National Bank has not published. On the operator side, Article 2.7 of ONPS/02/2020 still defines a company as one owned by Ethiopian nationals or by foreign nationals of Ethiopian origin, and that article has not been amended, so whether the operator licence is open to an ordinary foreign investor is confirmed before a structure is fixed. The register carries 27 licensees: six issuers, telebirr, M-PESA, Kacha and Yaya among them, and 21 operators with EthSwitch as the national switch. Population is 110.6 million. We run the file from Dubai and plan on nine to fifteen months.
Proclamation No. 718/2011, amended by No. 1282/2023, carries the framework. Issuers are licensed under Directive ONPS/09/2023, in force 6 October 2023 and amended by ONPS/10/2025, on Birr 100,000,000 of paid-up capital in a blocked account. Operators run on ONPS/02/2020, from Birr 3 million for a gateway to Birr 300 million for the national switch.
Both give the National Bank 60 calendar days to answer. No shareholder outside a government, a telecom operator or a licensed issuer or operator may take more than 40% of an issuer, 60% counting indirect holdings. Foreign capital is paid in foreign currency. The register carries 27 licensees. We run it from Dubai.
The routes
Payment instrument issuer, or payment system operator.
Two directives, two licences, and no overlap between them. The issuer holds user money in a trust account and puts the instrument in the customer's hand; the operator runs the switch, the terminals or the gateway underneath it. The services you sell decide which file we build.
Payment instrument issuer, or payment system operator - two directives, no overlap.
01 - PAYMENT INSTRUMENT ISSUER
Payment instrument issuer on ETB 100,000,000
The licence under Directive ONPS/09/2023, as amended by ONPS/10/2025, for issuing payment instruments, cash-in and cash-out through agents, domestic remittances and merchant and bill payments. Paid-up capital is Birr 100,000,000 in cash under Article 4(5), about USD 738,700 at the National Bank's 2024/25 average rate.
The licence under Directive ONPS/09/2023, as amended by ONPS/10/2025, for issuing payment instruments, cash-in and cash-out through agents, domestic remittances and merchant and bill payments. Paid-up capital is Birr 100,000,000 in cash under Article 4(5), about USD 738,700 at the National Bank's 2024/25 average rate.
- ✓Payment instruments, agent cash-in and cash-out, domestic transfers
- ✓Paid-up capital ETB 100,000,000 in a blocked account (Art. 4(5))
- ✓Trust account in a licensed bank, backed 100% (Art. 10)
- ✓Answer within 60 calendar days (Art. 4(20))
- ✓Digital savings, credit, insurance and inward remittances by approval (Art. 6(2))
- ✓Licence renewed every year and never transferred (Art. 16)
02 - PAYMENT SYSTEM OPERATOR
Gateway from ETB 3,000,000Payment system operator under ONPS/02/2020
The licence for a national switch, a switch, an ATM operator, a point of sale operator or a payment gateway operator under Article 4.3, on capital that follows the system. Article 4.4 lets one company hold more than one, and Article 4.7(f) then adds the figures together.
Payment system operator (ONPS/02/2020): national switch ETB 300M, switch 40M, ATM 20M, point of sale 10M, gateway 3M; 60 calendar days.
- ✓National switch ETB 300M · switch ETB 40M
- ✓ATM ETB 20M · point of sale ETB 10M · gateway ETB 3M
- ✓Payment processing, acquiring, aggregation and card personalisation (Art. 4.2)
- ✓Answer within 60 calendar days of a complete application (Art. 4.12)
- ✓Ten shareholders minimum to run more than one system (Art. 4.6(c))
- ✓National switch reserved to financial institutions and the National Bank (Art. 4.6(d))
Costs and timelines are confirmed for your case before any work begins. The National Bank prints its own charges - Birr 100,000 investigation plus Birr 300,000 licensing for a new issuer, Birr 20,000 plus Birr 30,000 for an operator other than the national switch - but not the investment protection fee, which we obtain for your file rather than quote.
Why Ethiopia
A hundred and ten million people, and a directive that writes the float rules out in full.
Ethiopia opened payments to foreign investors and then wrote down, in unusual detail, what an issuer may do with the money it holds. Both halves of that matter to anyone pricing the market.
✓
Both capital figures are in the text
Birr 100,000,000 for an issuer in Article 4(5), and Birr 3 million to 300 million by system in Article 4.7. Neither is a discretionary supervisory number.ETB 100M issuer, 3M-300M operator.
✓
Sixty calendar days, twice
Article 4(20) for issuers and Article 4.12 for operators both give the National Bank 60 calendar days. Applicants get 10 days to answer a question, or the file is refused.Both directives print the clock.
✓
The trust account is spelled out
Article 10: a trust account in a licensed bank, backed at all times to the sum of every user balance, reconciled daily with a report to the National Bank by 10:00 the next working day.Daily reconciliation, report by 10:00.
✓
Eighty percent of the float return goes to users
Article 10(14) makes the issuer pass at least 80% of any net return on the trust account to the people whose money it is. Most regimes let the issuer keep it.At least 80% of net return.
✓
Foreign investors are in
ONPS/09/2023 admits foreign nationals to issuer licensing, with capital paid in foreign currency under Article 4(6). The ceiling is 40% per shareholder, which shapes the cap table rather than closing the door.Capped at 40% per shareholder.
✓
One switch, and everyone is on it
ONPS/10/2025 routes wallet-to-wallet interoperability through the national switch or a licensed switch operator and standardises the QR code. Every financial institution offering payment and digital financial services has to join the instant payment system EthSwitch runs.Interoperability through EthSwitch.
How it compares
How Ethiopia differs from the other East and West African routes.
Ethiopia asks the most capital of the four and is the only one with a shareholding ceiling on the face of the directive. Ghana passes more of the float return to holders; Kenya bars its issuers from earning any return from the holder.
Ethiopia vs other jurisdictions
| Feature |  Ethiopia | Other jurisdictions |
|---|---|---|
| Capital | ETB 100M issuer · ETB 3M-300M operator | KES 20M Kenya · GHS 20M Ghana · FRW 300M Rwanda |
| Decision clock | 60 calendar days in both directives | 90 days Ghana · none in Kenya or Rwanda |
| Float return | At least 80% of net return to users | 90% of interest in Ghana · issuer earns none in Kenya |
| Foreign ownership | 40% per shareholder · 60% with indirect | 30% Ghanaian equity floor in Ghana |
Capital
EthiopiaETB 100M issuer · ETB 3M-300M operator
Other jurisdictionsKES 20M Kenya · GHS 20M Ghana · FRW 300M Rwanda
Decision clock
Ethiopia60 calendar days in both directives
Other jurisdictions90 days Ghana · none in Kenya or Rwanda
Float return
EthiopiaAt least 80% of net return to users
Other jurisdictions90% of interest in Ghana · issuer earns none in Kenya
Foreign ownership
Ethiopia40% per shareholder · 60% with indirect
Other jurisdictions30% Ghanaian equity floor in Ghana
Country by country
| Country | License type | Taxation | Requirements |
|---|---|---|---|
| Ethiopia | Issuer · operator (NBE) | 30% · VAT 15% | ETB 100M · 40% shareholder cap |
 Kenya | PSP · e-money issuer (CBK) | 30% · VAT 16% | KES 5M / 20M / 50M · no clock |
 Rwanda | Categories I-IV (BNR) | 28% · VAT 18% | FRW 30M-300M · fee FRW 1M-5M |
 Ghana | DEMI · PSP tiers (Bank of Ghana) | 25% · VAT 15% + levies | GHS 0.8M-20M · 90 days |
EthiopiaLicense typeIssuer · operator (NBE)
Taxation30% · VAT 15%
RequirementsETB 100M · 40% shareholder cap
KenyaLicense typePSP · e-money issuer (CBK)
Taxation30% · VAT 16%
RequirementsKES 5M / 20M / 50M · no clock
RwandaLicense typeCategories I-IV (BNR)
Taxation28% · VAT 18%
RequirementsFRW 30M-300M · fee FRW 1M-5M
GhanaLicense typeDEMI · PSP tiers (Bank of Ghana)
Taxation25% · VAT 15% + levies
RequirementsGHS 0.8M-20M · 90 days
Before you apply
Requirements for the NBE licence.Requirements for the licence.
ONPS/09/2023 sets the capital, the trust account, the wallet tiers and the clock for issuers; ONPS/02/2020 does the same for operators. The list below is what a passing file contains.
01
A company or subsidiary incorporated and registered in Ethiopia with its head office there, and, where the owner already runs another business, a separate entity formed exclusively for the payment activity under Article 15(6).
02
Paid-up capital of Birr 100,000,000 in cash in a blocked bank account for an issuer under Article 4(5), or the Article 4.7 figure for the system an operator applies to run, from Birr 3 million to Birr 300 million.
03
A share register built to the ceiling in Article 4(b)(vii) and (viii): 40% for any shareholder that is not a government, a telecom operator, a licensed issuer or a licensed operator, and 60% once indirect holdings are counted. The issuer directive prints no minimum number of shareholders.
04
Capital paid in foreign currency where the shareholder is a foreign national under Article 4(6), with evidence of the investment protection fee under Article 4(7) - an amount the National Bank sets case by case and does not publish.
05
An investment permit from the relevant government authority where the applicant subsidiary is foreign-owned, under Article 4(4)(c)(iv).
06
A memorandum of association drafted in Amharic and English and approved by the National Bank before it goes to the commercial registry.
07
Directors approved in writing before appointment under Article 5(1), each holding a first degree, adequate experience and at least 30 years of age, with a chief executive carrying seven years of work experience of which three are managerial. Neither directive sets a residency or nationality rule for the board.
08
A trust account in a licensed bank opened on written National Bank approval, holding the cash equivalent of every e-money balance, with at least 10% of it in cash and no more than 15% of the holding bank's capital placed there.
09
Wallet tiers built to Article 8 - Birr 10,000 of balance and Birr 20,000 of daily turnover at level 1, Birr 150,000 and Birr 300,000 at level 2 - with two-factor authentication above Birr 5,000 and accounts denominated only in birr.
10
AML and KYC policies under Proclamation No. 780/2013, plus the reporting calendar: quarterly returns within 7 calendar days, audited accounts within 90, and an annual renewal with a tax clearance certificate within 120 days of the fiscal year end.
01
Company registered in Ethiopia, head office there.
02
Capital ETB 100,000,000 in a blocked account.
03
40% shareholder cap, 60% with indirect holdings.
04
Foreign capital in foreign currency (Art. 4(6)).
05
Investment permit and investment protection fee.
06
Memorandum in Amharic and English, NBE-approved.
07
Directors and CEO approved before appointment.
08
Trust account: 100% backed, 10% cash, 15% bank cap.
09
Wallet tiers per Art. 8; 2FA above Birr 5,000.
10
AML under Proclamation 780/2013; quarterly reporting.
Reflects Proclamation No. 718/2011 as amended by No. 1282/2023, Directive ONPS/09/2023 (in force 6 October 2023) as amended by ONPS/10/2025 (in force 12 May 2025), Directive ONPS/02/2020 and Directive ONPS/07/2022, as of 2026. None of those directives requires local data hosting; what Article 13(3) requires instead is National Bank access to the issuance system for remote monitoring.Proclamation 718/2011 as amended by 1282/2023; ONPS/09/2023 as amended by ONPS/10/2025; ONPS/02/2020; ONPS/07/2022.
How it works
From first call to the NBE licence.
01
Route and structure
Issuer or operator; the cap table tested against the 40% and 60% ceilings; capital, fees and budget fixed in writing.Issuer or operator; cap table tested.
02
Company and capital
Ethiopian entity registered, memorandum cleared by the National Bank, Birr 100,000,000 paid into the blocked account in the required currency.Registered, ETB 100M in a blocked account.
03
The application file
Business plan, governance, AML and KYC, system and security documentation, director and CEO approvals, trust-account arrangement with the bank.Plan, AML, systems, director approvals.
04
Review and pilot
Sixty calendar days from the last condition met, questions answered inside 10 days, and a pilot of up to six months where the National Bank asks for one.60 calendar days; pilot up to six months.
05
Licence and launch
Licence issued, operations started within six months, quarterly reporting and the daily trust reconciliation running from day one.Operations started within six months.
Quick facts
RegulatorNational Bank of Ethiopia
LawProclamation 718/2011 as amended by 1282/2023
Issuer directiveONPS/09/2023 as amended by ONPS/10/2025
Operator directiveONPS/02/2020 (fee articles repealed)
CapitalETB 100M issuer · ETB 3M-300M operator
Decision60 calendar days
Licence termOne year · renewed annually · not transferable
Corporate tax30% · VAT 15%
Article 4(20) counts its 60 days from the last date every required condition is met, not from the day the file arrives. Article 4(16)(c) then lets the National Bank refuse an application whose applicant does not answer a question within 10 calendar days.
Your Ethiopia desk
Run from our East Africa desk.
Prifinance - East Africa desk
Dubai · coordinating Ethiopian mandates
33 Level, Al Saqr Business Tower, Dubai
01
Ethiopian company formation
A share company or subsidiary registered in Ethiopia, the memorandum drafted in Amharic and English and cleared by the National Bank before registration, and the cap table built to the 40% ceiling.Share company, memorandum cleared by NBE.
02
The NBE application
Business plan, governance, AML and KYC policies, system description and the Annex III fit-and-proper questionnaires, filed and defended through the question rounds inside the 60-day clock.Plan, policies, Annex III questionnaires.
03
Capital and currency
The Birr 100,000,000 paid into a blocked account, in foreign currency where the shareholder is foreign, with the investment permit and the investment protection fee settled before filing.Blocked account, permit, protection fee.
04
Trust account and rails
The trust account agreed with a licensed bank, the daily reconciliation and 10:00 reporting built into operations, and interoperability arranged through the national switch.Bank agreed, switch interoperability set.
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Good to know
Taxation of payment companies in Ethiopia.
A 30% corporate rate, 15% VAT with a Birr 2,000,000 registration threshold, 10% on dividends, and a set of National Bank charges that behave like a tax on the licence.
Corporate income tax 30%
The business income rate under Federal Income Tax Proclamation No. 979/2016. An amending proclamation, No. 1395/2024, exists; the ministry sites that would confirm whether it moves the rate were unreachable, so we verify it for your structure.Proclamation 979/2016; 1395/2024 verified per case.
VAT 15%
Article 8(2) of Value Added Tax Proclamation No. 1341/2024, with registration compulsory from Birr 2,000,000 of turnover under Article 12(2). Whether financial services sit in the Schedule 2 exemption is checked against the product mix.Registration from Birr 2,000,000.
Dividends 10%
The withholding rate published by the Ethiopian Investment Commission. No separate non-resident rate appears on an official page, so the position of a foreign parent is confirmed before profits are planned.Non-resident rate not published.
Licence and oversight fees
Directive ONPS/07/2022: Birr 100,000 investigation plus Birr 300,000 licensing for a new issuer, Birr 200,000 to renew each year, and an annual oversight fee of Birr 500,000 to Birr 1,000,000 by size.Birr 100,000 + 300,000; renewal 200,000.
No mobile-money levy found
Neither a financial-sector levy nor an excise on wallet transactions appears in any official source we could read. What exists instead are the National Bank's own charges under ONPS/07/2022.Birr 500,000 - 1,000,000 a year.
Repatriating profit
Foreign Exchange Directive FXD/01/2024 floated the birr and, at Article 16.3, allows dividends of registered foreign investments out on board minutes, audited accounts, the capital registration letter and tax receipts. Article 16 still bars unauthorised capital account transactions.FXD/01/2024 art. 16.3, on documents.
Tax summary
Corporate income tax30% (Proclamation 979/2016)
VAT15% · registration from Birr 2,000,000
Dividend withholding10%
New issuer licenceBirr 100,000 + Birr 300,000
Annual chargesRenewal 200,000 · oversight 500,000-1,000,000
Profit repatriationFXD/01/2024 art. 16.3, on documents
*Figures as of 2026. The 30% corporate rate and the 10% dividend withholding come from the Ethiopian Investment Commission's published material; Income Tax (Amendment) Proclamation No. 1395/2024 exists and we could not read whether it changes either figure, so both are verified per structure. VAT is from Proclamation No. 1341/2024.
Turnkey professional support
Experienced lawyers and international consultants.
We provide end-to-end support, from company registration and the application file to regulatory interaction and compliance oversight - with an individualized approach to each client.
Oleksii Kindratenko
Builds the application itself: Ethiopian share company, AML/KYC policy pack, capital structure and tax registrations. His document sets are the reason reviews finish in months, not years.
Eugeniu Bevziuc
First point of contact for international founders. Runs the whole setup remotely, across time zones and languages - from the first call to a live, licensed issuer.
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The Ethiopian payment licence, answered.
What licence does a payment business need in Ethiopia?+
One of two. A payment instrument issuer licence under Directive ONPS/09/2023, as amended by ONPS/10/2025, if you issue wallets and hold user money; a payment system operator licence under ONPS/02/2020 if you run a switch, ATMs, point of sale terminals or a payment gateway. The National Bank's register lists 27 licensees, six of them issuers - telebirr, M-PESA, Kacha and Yaya commercialised, Vitabirr and ToloPay still in pilot. Ethio telecom publishes no subscriber count for telebirr, so anyone sizing the incumbent works from its revenue share instead.
How much capital is required?+
Birr 100,000,000 for an issuer, in cash, in a blocked account in the name of the company under formation, under Article 4(5) as replaced by ONPS/10/2025. That is about USD 738,700 at the National Bank's 2024/25 weighted average of 135.37 birr to the dollar. Operators pay by system: Birr 300 million for the national switch, 40 million for a switch, 20 million for ATMs, 10 million for point of sale and 3 million for a gateway.
Can a foreign investor own an Ethiopian payment instrument issuer?+
Not outright. ONPS/10/2025 caps any single shareholder at 40% of subscribed shares, or 60% once indirect holdings are counted, unless that shareholder is a government, a telecom operator, a licensed payment instrument issuer or a licensed payment system operator. A foreign fintech outside those categories builds a cap table with partners. For operators the position is different again: Article 2.7 of ONPS/02/2020 still describes the licensee as Ethiopian or Ethiopian-origin owned, and it has not been amended, so we confirm that route before relying on it.
How long does the National Bank take?+
Sixty calendar days under Article 4(20) for issuers and Article 4.12 for operators. The issuer clock runs from the last date every required condition is met, and Article 4(16)(c) lets the National Bank refuse an application whose applicant stays silent for 10 calendar days. With company formation, capital, the investment permit and a possible pilot, plan on nine to fifteen months end to end.
How is user money protected?+
Article 10 requires a trust account in a licensed bank whose balance and liquid assets equal the sum of all user e-money accounts at all times. The money belongs to the users. The issuer reconciles daily and reports to the National Bank by 10:00 the next working day, fixes any discrepancy by noon the day after, keeps at least 10% of the balance in cash, and may not place more than 15% of the holding bank's capital in that account.
Who keeps the return on the float?+
Mostly the users. Article 10(14) requires the issuer to pass at least 80% of any net return on the trust account to them and lets it retain the rest. Investment of the float needs written National Bank approval and is limited to liquid assets the National Bank prescribes; Article 10(20) rules out anything else.
What are the wallet limits?+
Level 1 carries a Birr 10,000 balance and Birr 20,000 of aggregate daily transactions. Level 2 carries Birr 150,000 and Birr 300,000, within which person-to-person transfers are capped at Birr 75,000 a day and payments to merchants, including the standardised Ethiopian QR code, at Birr 250,000. Two-factor authentication applies above Birr 5,000, and accounts are denominated only in birr.
What does the licence cost and how long does it last?+
Directive ONPS/07/2022 charges a new issuer Birr 100,000 for investigation and Birr 300,000 for the licence, with Birr 200,000 to renew and an annual oversight fee of Birr 500,000 to Birr 1,000,000 by size. The licence runs for a year and is renewed annually with a tax clearance certificate and an auditor's report; Article 16(4) makes it non-transferable.
Can profits be taken out of the country?+
Foreign Exchange Directive FXD/01/2024 floated the birr in 2024 and, at Article 16.3, allows profits and dividends of recognised and registered foreign investments to be remitted against authenticated board minutes, audited accounts, the capital registration letter and tax receipts, with the National Bank stating it will not refuse where those documents are supplied. Article 16 still bars capital account transactions by residents without explicit authorisation, and a pre-directive dividend backlog goes onto a repayment schedule. The practical risk sits in foreign currency availability rather than in the rule. The National Bank has since published a relaxation notice and Directive FXD/04/2026, and we read those against your remittance plan before capital goes in.
Why Ethiopia rather than Kenya or Ghana?+
Ethiopia is the population: 110.6 million against Kenya's census count of 47.6 million, with six licensed issuers serving it and interoperability routed through one national switch. It is also the dearest of the three at Birr 100,000,000 and the only one that caps a shareholder at 40%. Kenya asks KES 20 million of an e-money issuer, sets no decision deadline and has the deeper mobile-money market; Ghana asks GHS 20 million, decides in 90 days and requires at least 30% Ghanaian equity of its own. Groups that want the size of the market start here and price the cap table first.
Which licence?+
Issuer (ONPS/09/2023) or operator (ONPS/02/2020).
Capital?+
ETB 100M issuer; ETB 3M-300M operator.
Foreign ownership?+
40% per shareholder, 60% with indirect.
How long?+
60 calendar days; 9-15 months realistic.
User money?+
Trust account, 100% backed, reconciled daily.
Float return?+
At least 80% goes to users (Art. 10(14)).
Wallet limits?+
L1 balance 10,000, daily 20,000; L2 150,000 / 300,000.
Fees?+
100,000 + 300,000; renewal 200,000 a year.
Repatriation?+
FXD/01/2024 art. 16.3, against documents.
vs Kenya / Ghana?+
Bigger market, higher capital, 40% cap.
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Prifinance is an independent law and advisory firm. We are not a regulator and are not affiliated with, endorsed by, or acting on behalf of the National Bank of Ethiopia or any other public authority. Authorisations are granted by, and obtained directly from, the competent authorities.