KM-A Data Protection & Privacy Regulation

Regulator & Framework

The underlying state of Comoros data-protection law, which bears directly on Anjouan as an island within the Union, is unsettled in a way that is itself the finding rather than a gap to be filled later. A 2023 civil-society legal mapping states plainly that Comoros does not have a dedicated data protection law, and identifies a 2014 draft, Loi n 14-029/AU, that does not appear to have been enacted. A separate, more general country-level source likewise states that Comoros currently has no comprehensive data protection legislation. Against this, a 2026-dated country-profile source states that Comoros has a personal data protection law providing the basis for regulating personal data processing, while noting that public information on an operational supervisory authority remains limited. These two positions are in direct conflict on the most basic question, whether any data-protection statute has ever been enacted at national level, and the conflict cannot be resolved from the material gathered.

What is understood to be consistent across both positions is that no dedicated data-protection supervisory authority has been confirmed operational for Comoros, or for Anjouan specifically. Even the source asserting that a law exists stops short of identifying a functioning regulator exercising powers under it. For Anjouan, this means that whatever the resolution of the statutory question turns out to be, the practical absence of a confirmed operational authority is the more immediately relevant fact: there is, on the evidence gathered, no body known to be receiving complaints, issuing guidance, or exercising enforcement powers over data processing on the island or at the national level that would reach it.

The disputed status of Loi n 14-029/AU sits at the centre of the disagreement. If the 2014 draft was never enacted, as the civil-society and general country sources suggest, then any claim of a Comoros personal data protection law resting on that instrument would be describing a draft rather than an enacted statute. No primary text from the Journal Officiel des Comores has been located to settle which account is accurate. This is presented here as a disputed state of the law, to be read by readers as an open legal question rather than as a research shortfall that a future search is expected to close.

Outlook

The path to resolution runs through a primary legislative text. Should the Journal Officiel des Comores record show Loi n 14-029/AU, or a successor instrument, formally enacted, that would settle the statutory question in one direction; continued absence of such a record across further monitoring would reinforce the no-enactment account. Separately, and regardless of how the statutory question resolves, confirmation of any operational supervisory body with actual complaint-handling or enforcement activity would mark a materially different development from anything found, since no such body has been identified under either account of the law.