Africa’s Imitation Game in Competition Law
African competition authorities are importing the wrong model of competition enforcement—and doing so without the institutional capacity to make even the right model work.
Across the continent, regulators are reaching for Europe’s most ambitious digital frameworks. The Common Market for Eastern and Southern Africa (COMESA) Competition and Consumer Commission (CCC) recently overhauled its regime to introduce gatekeeper regulation modeled on the European Union’s Digital Markets Act (DMA). Nigeria’s Federal Competition and Consumer Protection Commission (FCCPC) fined Meta million for what it framed as a privacy and competition violation grounded in European-style reasoning—albeit flawed. South Africa’s Competition Commission (SACC) has moved from market inquiry to enforcement on digital platforms.
These moves may signal sophistication—and, at first glance, progress. The reality is less encouraging. African institutions are investing heavily in rulemaking while systematically underinvesting in the capacity to administer those rules with competence. The result is not rigorous enforcement, but mimicry. Stripped of the analytical discipline that gives it value, regulation becomes a set of empty forms.