The 3-color card trick in Africa and a possible continental vehicle insurance scheme

Many African Regional Economic Communities (RECs) have adopted regional motor vehicle insurance schemes to cover third-party liabilities and medical expenses for the drivers in case they suffer any bodily injury as a result of a road accident. The advantage of such schemes is that they facilitate cross border movement of vehicles between States, as drivers can travel within these Regions without the need to obtain an insurance cover in each country where they travel. 

To date, there are many regional motor insurance systems around the world. The oldest and largest system was launched in 1949 by UNECE, and is called “Green Card“. This scheme is currently operational in 48 countries, including Morocco and Tunisia. The green card is an international certificate of insurance that provides a protection mechanism for victims of cross-border road traffic accidents, by avoiding the need for drivers to obtain an additional insurance cover when they exit the country where the vehicle is registered for entering into a new one. The only condition, obviously, is that the country where the driver travels accepts the green card.  

In Africa, regional motor vehicle insurance schemes are currently operational in 3 main RECs: COMESA, ECOWAS and CEMAC. An additional regional system is adopted by the League of Arab States, but is not exactly an African regional motor insurance system, as it is also applicable in many Middle East countries. The African countries implementing this scheme, called “Orange card”, are currently Mauritania, Morocco, Algeria, Libya, Tunisia, Egypt, Sudan and Somalia. Djibouti and Comoros, on the other hand, despite being members of the League of Arab States, do not implement the scheme.

The Common Market for Eastern and Southern Africa (COMESA)  has developed the Yellow Card, that provides third party legal liability coverage and compensation for medical expenses resulting from road traffic accidents caused by motorists. This scheme however, is currently used only in twelve (12) out of the 21 COMESA Member Countries: Burundi, Democratic Republic of Congo, Djibouti, Eritrea, Ethiopia, Kenya, Malawi, Rwanda, Sudan, Uganda, Zambia and Zimbabwe and Tanzania. For example, if an Ethiopian driver wishes to drive to Kampala, Uganda, passing through Kenya, he can purchase a Yellow Card from an insurance company in Ethiopia for the required period of time to cover the countries he will travel through. The alternative is to buy a national insurance cover in these countries, as both nations require drivers entering their territory to have a motor vehicle liability insurance cover. If on his way to Kampala the driver is involved in an accident, for instance in Kenya, all he will be required to do is just to report to the Kenya focal point representing all the insurance companies issuing Yellow Cards in Kenya, and the traffic police. The National Bureau will then handle and settle the claim arising from this accident. The same if the accident happens in Uganda.

The Economic Community of West African States (ECOWAS) has developed the Brown Card, introduced by the Protocol on Brown Card Third Party Motor Insurance (Protocol A/P1/5/82) , subsequently integrated by the Supplementary Protocol (A/SP./12/01). A Convention for the indemnification of victims of road accidents was also approved by ECOWAS on October 2008 for harmonizing legislation and compensation systems in the field of motor insurance in the Region. The scheme is currently used by 14 out of the 15 ECOWAS members (Benin, Burkina Faso, Gambia, Ghana, Guinea, Guinea-Bissau, Ivory Coast, Liberia, Mali, Niger, Nigeria, Senegal, Sierra Leone and Togo), with the only exception of Cabo Verde.

The Central African Economic and Monetary Community (CEMAC)  has developed the Carte Internationale d’Ássurance de Responsabilité Civile (CIARCA) scheme, commonly called CEMAC Pink Card, whose purpose is to facilitate the payment of damages by insurance companies in case of accidents. The pink card serves as an extension on national insurance coverage to other CEMAC counties and is aimed at harmonising the modalities for processing compensation claims for accidents occurring in any of the member countries of the Community. However, although the Règlement n°2/00/UEAC-001-CIARCA-CM-04 du 21 juillet 2000 made mandatory the use of the pink card in the CEMAC region, this is not yet fully adopted by drivers working in the cross-border transport sector.


As described above, all these schemes just cove third-party liabilities and medical expenses for the drivers (including truck drivers transporting goods) travelling from a country to another within a single REC, while they do not cover inter-REC transport, i.e. transport from a country member of a certain REC to another REC. If, on one hand, intra-REC cross-border transport operations (between countries belonging to the same regional block) does not generally pose a problem because of the higher degree of standardisation and approximation of transport regulations (which in turn are the consequence of transport liberalisation and facilitation policies adopted by almost all RECs in Africa), travelling on inter-REC transport corridors can be really challenging and expensive because of the multiple insurance schemes that transporters need to activate.

Considered the fact that regional insurance schemes are adopted almost worldwide because of their advantages in terms of facilitation of cross-border transport and trade, due to elimination of the need for drivers to take out an insurance every time they cross a border, it would be opportune to consider the possibility to merge them in a single continental insurance scheme so that inter-REC transport is facilitated.

This solution would lower costs for transportation on long distances in Africa and facilitate intra-regional trade… Could this be a new topic to be included into the trade in service Agenda under the AfCFTA?

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