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What an automated scan can actually verify for BCEAO/COBAC compliance

And what it can't. A scan doesn't replace a written security policy or a business continuity plan — but it does precisely and automatically cover three entire sections of the regulation.

October 18, 2026 · SunuCyberSecurity team

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3

compliance categories an automated scan can cover on its own

6

categories that remain necessarily human and organizational

300M FCFA

sanctions already issued by BCEAO for failing information systems security

9

regulatory texts cross-referenced in our mapping — BCEAO, COBAC, ISO 27001 and 6 others

Source: the compliance mapping built into our scan reports — BCEAO Instruction No.009-06-2015, Art.7

In the UEMOA zone, BCEAO has already issued sanctions of up to 300 million FCFA against banks for failing information systems security requirements (Instruction No.009-06-2015). For financial institutions, cybersecurity compliance isn't optional — but "we run security scans" doesn't mean "we're compliant." Every finding from our scans is mapped to a specific regulatory category, and that mapping has clear limits, which we'd rather explain than gloss over.

The 3 categories a scan covers well

These are requirements that translate into technical behavior observable from the outside — exactly what an active test can verify without privileged access or interviews with your team.

Identity and Access Management

BCEAO Instruction No.008-05-2015 Art.7 (transaction authenticity) / Instruction No.009-06-2015 (logical access management) · ISO/IEC 27001 A.9

Weak credentials, brute-force authentication, poorly protected sessions, anonymous access left open — exactly what a scan can actively test without privileged access or interviewing your team.

Network Security and Encryption

BCEAO Instruction No.008-05-2015 Art.7 (confidentiality, message integrity) · ISO/IEC 27001 A.10 and A.13

Outdated TLS, an expired or invalid certificate, missing HSTS, DNSSEC not enabled, missing security headers (CSP, X-Frame-Options) — verifiable in seconds by a scan.

Protection Against Hacking and Malware

BCEAO Instruction No.008-05-2015 Schedule III.3.2 (firewalls, intrusion detection) / Instruction No.009-06-2015 · ISO/IEC 27001 A.12 and A.14

SQL injection, XSS, remote code execution, known CVEs on outdated versions — exactly what our active testing modules (SQLMap, Nikto, CVE correlation) look for.

The 6 categories no scan can verify

These are documentary, organizational, or human requirements — a scan can't read your business continuity plan or confirm your security policy was actually approved by management:

  • Information Security Policy — a document, not an observable network behavior.
  • IT Risk Management Strategy.
  • Physical and Environmental Security of premises and equipment.
  • Data Backup and Business Continuity Plan.
  • Incident Management Plan and notification procedure.
  • Audit Trail and periodic external security audit.

An indicative mapping, not a certification

It's written plainly in our own code: this mapping does not constitute a compliance certification, only an indicative cross-reference between technical findings and usual regulatory categories. A scan report showing "0 findings in Identity and Access Management" isn't a BCEAO certificate — it's one technical signal among several that your external auditors (always required — periodic external audit is itself one of the 6 categories no scan covers) will take into account.

Beyond the UEMOA/CEMAC zone

The same mapping also cross-references, by category, Nigeria's CBN Cybersecurity Framework, South Africa's Joint Standard 2 of 2024, Kenya's CBK texts, and Rwanda's BNR Regulation No.50/2022 — on top of ISO 27001, HIPAA, SOC 2 and GDPR for organizations with international obligations. Same logic everywhere: indicative, never a certification.

See the mapping on your results

Every scan generates a PDF report with this compliance cross-reference by category.

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Methodology

Regulatory references and mapping as implemented in our backend on October 18, 2026: BCEAO Instruction No.008-05-2015 governing electronic money issuers (Art.7, Schedule III), BCEAO Instruction No.009-06-2015, COBAC Regulations R-2008/01 and R-2016/04, ISO/IEC 27001 Annex A (a standard explicitly recommended by COBAC). This content describes our own tool, not legal or regulatory advice — consult your auditors and legal counsel for any question of actual compliance.

Related reading

SunuSSLPulse: what our scans reveal about the real state of TLS What an automated security audit actually looks like, step by step

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