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Legal systems of Africa: common law, civil law and OHADA
Which legal tradition each of the 54 countries follows, the official languages, and the 17-country OHADA business-law zone.
The short answer
Africa’s legal systems mostly follow English common law, French, Portuguese or Belgian civil law, or a mix – often alongside customary and Islamic law. Seventeen countries also share uniform business law through OHADA.
Common law
Countries with an English legal heritage – for example Nigeria, Ghana, Kenya, Uganda and Tanzania – rely on statutes and on court decisions as precedent.
Civil law
Countries with French, Portuguese, Belgian or Spanish legal heritage – most of West and Central Africa, North Africa, Angola and Mozambique – rely mainly on written codes.
Mixed systems
Southern African countries such as South Africa, Botswana, Namibia, Lesotho and Eswatini use Roman-Dutch law influenced by English law. Others, such as Cameroon, Mauritius, Seychelles and Rwanda, combine traditions. Customary and Islamic law also apply in many countries, often for family and land matters.
OHADA
OHADA (the Organization for the Harmonization of Business Law in Africa) was created by a treaty signed in Port Louis in 1993. Its member states apply common Uniform Acts on company law, commercial law, securities, insolvency, arbitration and more, with a common court of justice and arbitration in Abidjan. The 17 members are: Benin, Burkina Faso, Cameroon, Central African Republic, Chad, Comoros, Congo, Cote d'Ivoire, DR Congo, Equatorial Guinea, Gabon, Guinea, Guinea-Bissau, Mali, Niger, Senegal, Togo. OHADA explained.
Country by country
| Country | Legal system | Official languages | OHADA |
|---|---|---|---|
| Algeria | civil law (influenced by Islamic law) | Arabic, Tamazight | |
| Angola | civil law | Portuguese | |
| Benin | civil law | French | Yes |
| Botswana | mixed (Roman-Dutch law and English common law, plus customary law) | English, Setswana (national language) | |
| Burkina Faso | civil law | National languages (since the 2023 constitutional revision), French (working language) | Yes |
| Burundi | civil law (with customary law) | Kirundi, French, English | |
| Cabo Verde | civil law | Portuguese | |
| Cameroon | mixed (English common law in the North-West and South-West regions, Fr | French, English | Yes |
| Central African Republic | civil law (with customary law) | French, Sango | Yes |
| Chad | civil law (with customary and Islamic law) | French, Arabic | Yes |
| Comoros | mixed (French civil law, Islamic law and customary law) | Comorian, Arabic, French | Yes |
| Congo | civil law (with customary law) | French | Yes |
| Cote d'Ivoire | civil law | French | Yes |
| Djibouti | mixed (French civil law, Islamic law and customary law) | French, Arabic | |
| DR Congo | civil law | French | Yes |
| Egypt | civil law (French-influenced) with Islamic law as the principal source | Arabic | |
| Equatorial Guinea | civil law (Spanish-based, with customary law) | Spanish, French, Portuguese | Yes |
| Eritrea | civil law (codified), with customary and Islamic law in personal matte | No official language; Tigrinya, Arabic and English are the main working languages | |
| Eswatini | mixed (Roman-Dutch common law and Swazi customary law) | English, siSwati | |
| Ethiopia | civil law (codified, with customary and Islamic law in some matters) | Amharic (federal working language) | |
| Gabon | civil law (with customary law) | French | Yes |
| Ghana | common law (with customary law) | English | |
| Guinea | civil law (with customary law) | French | Yes |
| Guinea-Bissau | civil law (Portuguese-based, with customary law) | Portuguese | Yes |
| Kenya | common law (with customary and Islamic law in personal matters) | Kiswahili, English | |
| Lesotho | mixed (Roman-Dutch common law and Basotho customary law) | Sesotho, English | |
| Liberia | common law (Anglo-American, with customary law) | English | |
| Libya | civil law with Islamic law | Arabic | |
| Madagascar | civil law (French-based, with Malagasy customary law) | Malagasy, French | |
| Malawi | common law (with customary law) | English, Chichewa (national language) | |
| Mali | civil law (French-based, with customary and Islamic law in personal ma | National languages (since the 2023 Constitution), French (working language) | Yes |
| Mauritania | Islamic law + civil law | Arabic | |
| Mauritius | mixed (French civil law and English common law) | English (de facto), French (de facto) | |
| Morocco | mixed (French-based civil law and Islamic law) | Arabic, Amazigh (Tamazight) | |
| Mozambique | civil law (Portuguese-based, with customary law) | Portuguese | |
| Namibia | mixed (Roman-Dutch common law, English-influenced, with customary law) | English | |
| Niger | civil law (French-based, with customary and Islamic law) | Hausa (national language under the 2025 Refoundation Charter), French (working language), English (working language) | Yes |
| Nigeria | mixed (English common law, Islamic (Sharia) law in northern states, an | English | |
| Rwanda | mixed (civil law and common law) | Kinyarwanda, English, French, Kiswahili | |
| Sao Tome and Principe | civil law (Portuguese-based) | Portuguese | |
| Senegal | civil law (French-based, with customary and Islamic law in family matt | French | Yes |
| Seychelles | mixed (French civil law and English common law) | Seychellois Creole, English, French | |
| Sierra Leone | common law (with customary law) | English | |
| Somalia | mixed (civil law, Islamic (Sharia) law and customary (xeer) law) | Somali, Arabic | |
| South Africa | mixed (Roman-Dutch civil law, English common law and customary law) | English, Afrikaans, isiZulu, isiXhosa | |
| South Sudan | mixed (common law-based statutes with customary law) | English | |
| Sudan | mixed (Islamic law + civil law, with common-law heritage) | Arabic, English | |
| Tanzania | common law (with customary and Islamic law) | Kiswahili, English | |
| The Gambia | mixed (English common law, Islamic (Sharia) law and customary law) | English | |
| Togo | civil law (French-based, with customary law) | French | Yes |
| Tunisia | civil law (French-based, with Islamic law influence in personal status | Arabic | |
| Uganda | common law (with customary and Islamic law in personal matters) | English, Kiswahili | |
| Zambia | common law (with customary law) | English | |
| Zimbabwe | mixed (Roman-Dutch law and English common law, with customary law) | English, Shona, Ndebele, Chewa |
General description from official and standard sources, checked October 2026. Not legal advice.