Togo has developed a comprehensive and forward-looking legislative framework addressing information and communication technology (ICT), cybersecurity, data protection, and emerging technologies. This document provides an overview of the current state of legislation and initiatives across these critical domains.

Cybersecurity, Cybercrime & Privacy

Togo has established a robust legal framework for cybersecurity and data protection, positioning itself as an emerging leader in West African digital governance.

Data Protection Legislation

Law No. 2019-014 of 29 October 2019 Relating to the Protection of Personal Data: This comprehensive law establishes Togo's data protection framework and creates an independent regulatory authority.

Data Protection Principles: Personal data must be:

Collected and processed lawfully, fairly, and transparently
Collected for specified, explicit, and legitimate purposes
Adequate, relevant, and limited to what is necessary
Accurate and kept up to date
Kept in a form permitting identification for no longer than necessary
Processed securely with appropriate safeguards

Data Subject Rights: Togo's framework provides comprehensive rights including:

Right to information about processing
Right of access to personal data
Right to rectification of inaccurate data
Right to erasure ("right to be forgotten")
Right to object to processing
Right to data portability
Right to restrict processing
Protection against automated decision-making

Cross-Border Data Transfers: The law establishes requirements for international data transfers, including adequate protection in destination countries.

Data Protection Authority

Togo has established a data protection authority responsible for:

Enforcing compliance with data protection law
Receiving and investigating complaints
Issuing guidance and regulations
Conducting audits and inspections
Authorizing cross-border data transfers
Imposing penalties for violations

Cybersecurity Framework

National Cybersecurity Agency (ANCY): Togo established the Agence Nationale de Cybersécurité (ANCY) as the dedicated national cybersecurity agency responsible for coordinating cybersecurity efforts across the country.

National Cybersecurity Strategy 2024-2028: On May 22, 2024, ANCY announced publication of Togo's National Cybersecurity Strategy 2024-2028, which details the country's objectives, priorities, and actions to strengthen digital security and establish Togo as a regional leader in cybersecurity.

Strategic Objectives: The 2024-2028 strategy focuses on:

Governance and Legal Framework:

Strengthening legal and regulatory frameworks
Enhancing institutional coordination
Developing cybersecurity policies and standards
Ensuring compliance and enforcement

Capacity Building:

Developing national cybersecurity expertise
Training programs for government and private sector
Education initiatives at all levels
Research and development support

Critical Infrastructure Protection:

Identifying and protecting critical information infrastructure
Sector-specific security requirements
Risk management frameworks
Incident response capabilities

International Cooperation:

Regional and continental cybersecurity collaboration
International partnerships and agreements
Participation in global cybersecurity forums
Cross-border cooperation on cyber threats

Innovation and Digital Economy:

Supporting secure digital transformation
Fostering cybersecurity industry development
Enabling innovation with security
Building trust in digital services

African Center for Coordination and Research in Cybersecurity

In August 2022, the UN Economic Commission for Africa and the Republic of Togo announced an agreement to jointly establish the African Center for Coordination and Research in Cybersecurity.

Significance: This center positions Togo as a continental hub for:

Cybersecurity research and development
Regional coordination on cyber threats
Capacity building for African countries
Best practice development and dissemination
Policy guidance and technical assistance

Regional Leadership: Hosting this center demonstrates Togo's commitment to leading African cybersecurity efforts and providing technical support to other countries.

Data and Cloud

Togo is developing advanced data governance and cloud infrastructure:

Cloud Infrastructure:

Growing domestic digital infrastructure
Regional cloud initiatives
Focus on data sovereignty
Support for secure cloud adoption

Cross-Border Data Flows:

Regulated through data protection authority
Requirements for adequate protection in destination countries
Framework for secure international data transfers

Digital Economy Support:

Infrastructure to support digital businesses
Enabling environment for cloud services
Data protection as foundation for trust

Artificial Intelligence

Togo is positioned among African countries actively embracing AI:

AI Adoption: Reports identify Togo among countries including South Africa, Nigeria, Ethiopia, Kenya, Zimbabwe, Libya, and Ghana actively embracing AI technologies.

Legal Framework for AI: Togo's comprehensive data protection law provides a foundation for AI governance, offering avenues for incorporating AI-specific elements.

Future AI Strategy: While a dedicated national AI strategy is not yet published, Togo's proactive approach to digital governance suggests AI frameworks will be developed as technology adoption increases.

Emerging Technologies

Togo's regulatory approach to emerging technologies is proactive:

Regulatory Framework: The National Cybersecurity Strategy 2024-2028 addresses emerging technologies and their security implications.

Innovation Support: Togo seeks to balance innovation enablement with appropriate safeguards through:

Supportive regulatory environment
Security standards for new technologies
Capacity building for emerging tech
Public-private partnerships

ICT Infrastructure

Togo has made significant progress in ICT infrastructure development:

Telecommunications Sector:

Competitive mobile telecommunications market
Expanding fixed broadband infrastructure
Growing internet penetration
Modern telecommunications networks

Digital Services:

Advanced mobile money services (Togo was early adopter)
Growing e-commerce sector
Digital payment platforms
Online government services

Infrastructure Development:

Submarine cable connectivity
National fiber-optic backbone
Metropolitan networks in major cities
Regional connectivity hub potential

E-Government: Togo has made notable progress in digital government:

Online public services
Electronic administrative procedures
Digital identity initiatives
Government service digitalization

Strategic Location:

Regional connectivity hub potential
Gateway position in West Africa
Submarine cable landing point
Strategic for regional data flows

Regional Conventions

Togo is an active member of ECOWAS (Economic Community of West African States):

ECOWAS Implementation: Togo has implemented ECOWAS requirements through comprehensive national legislation demonstrating commitment to regional harmonization.

Regional Cooperation: Through ECOWAS, Togo participates in:

Regional cybersecurity initiatives
Cross-border cooperation on cybercrime
Harmonized digital governance approaches
Technical assistance and capacity building

Regional Leadership: Hosting the African Center for Coordination and Research in Cybersecurity positions Togo as a regional leader and hub for West African cybersecurity cooperation.

Continental Initiatives

Malabo Convention: Togo ratified the African Union Convention on Cybersecurity and Personal Data Protection (Malabo Convention) and is one of the 15 countries whose ratification brought the Convention into force on June 8, 2023.

Implementation: Togo's comprehensive data protection and cybersecurity frameworks align with Malabo Convention requirements:

Independent data protection authority
Comprehensive data subject rights
Mechanisms for transparency and accountability
Framework for cross-border data transfers
National cybersecurity agency and strategy

African Center Hosting: Togo's agreement to host the African Center for Coordination and Research in Cybersecurity demonstrates continental leadership and commitment to supporting other African countries' cybersecurity development.

Global Conventions and Frameworks

Budapest Convention: While not yet a party to the Budapest Convention on Cybercrime, Togo's comprehensive cybercrime legislation demonstrates alignment with international standards.

International Cooperation: Togo actively participates in:

Global cybersecurity forums
International partnerships on digital governance
UN Economic Commission for Africa initiatives
Technical cooperation agreements

International Standards: Togo's frameworks demonstrate alignment with:

GDPR-inspired data protection principles
International cybersecurity best practices
ISO/IEC standards adoption in key sectors
Global cooperation mechanisms

Cybersecurity Posture

Togo's cybersecurity posture is rapidly strengthening:

Institutional Capacity:

Dedicated National Cybersecurity Agency (ANCY)
Operational data protection authority
Published cybersecurity strategy
Host of African cybersecurity center

Capacity Development:

Growing pool of cybersecurity professionals
Training and education programs
Regional cooperation and learning
International technical assistance

Strategic Vision: The 2024-2028 strategy sets clear objectives for making Togo a regional cybersecurity leader, with concrete actions and timelines.

Challenges

Despite significant progress, Togo faces challenges:

Resource Constraints:

Limited government budget for comprehensive cybersecurity
Competing development priorities
Need for sustained funding
Capacity building requirements

Implementation Capacity:

Translating strategy into operational capabilities
Building technical expertise at scale
Ensuring comprehensive coverage across sectors
Maintaining momentum on reforms

Infrastructure Limitations:

Urban-rural digital divide
Electricity reliability in some areas
Need for continued infrastructure investment
Geographic coverage gaps

Private Sector Engagement:

Ensuring business compliance with regulations
Building cybersecurity culture in companies
Supporting SMEs with limited resources
Fostering public-private partnerships

Regional Coordination:

Operationalizing the African Center effectively
Delivering on regional leadership commitments
Coordinating with diverse stakeholders
Securing sustained funding for regional initiatives

Opportunities

Togo has exceptional opportunities based on its strategic positioning:

Regional Hub Status:

Host of African Center for Coordination and Research in Cybersecurity
Strategic location for regional connectivity
Platform for West African cooperation
Influence on regional standards and approaches

International Partnerships:

UN Economic Commission for Africa collaboration
Access to technical and financial support
Platform for knowledge sharing
Regional training center potential

Economic Development:

Attract digital businesses through strong governance
Build trust in digital economy
Support for innovation and startups
Cybersecurity as competitive advantage

Strategic Vision:

Clear roadmap through 2024-2028 strategy
Commitment to regional leadership
Alignment with continental priorities
Institutional frameworks in place

Youth and Innovation:

Young, technology-savvy population
Growing startup ecosystem
Government support for digital innovation
Potential for technology sector development

Recommendations

To achieve its regional leadership ambitions, Togo should:

Immediate Priorities:

Fully operationalize African Center for Coordination and Research in Cybersecurity
Continue implementing 2024-2028 strategy with adequate resources
Strengthen data protection authority enforcement capacity
Expand cybersecurity awareness programs nationwide
Develop sector-specific security guidelines

Medium-Term Actions:

Develop comprehensive AI governance framework
Expand digital infrastructure to underserved areas
Establish regional cybersecurity training programs through African Center
Foster public-private partnerships on cybersecurity
Build capacity for cyber threat intelligence and response

Long-Term Goals:

Establish Togo as West Africa's cybersecurity excellence center
Provide technical assistance to other African countries through African Center
Develop domestic cybersecurity industry and export services
Lead regional approaches to emerging technology governance
Build sustainable funding models for cybersecurity initiatives

Regional Leadership Actions:

Host regular regional cybersecurity conferences and workshops
Develop training programs for other African countries
Create knowledge repository and best practice database
Facilitate South-South cooperation on cybersecurity
Lead development of regional cybersecurity standards

International Engagement:

Consider accession to Budapest Convention
Strengthen bilateral cooperation agreements
Participate actively in global cybersecurity forums
Share Togo's experience and lessons learned
Build partnerships with leading cybersecurity nations

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Conclusion

Togo has emerged as one of West Africa's most forward-looking countries in cybersecurity and data protection governance. The establishment of the National Cybersecurity Agency (ANCY), publication of the National Cybersecurity Strategy 2024-2028, and comprehensive data protection legislation demonstrate sustained commitment to digital governance. Most significantly, Togo's agreement with the UN Economic Commission for Africa to host the African Center for Coordination and Research in Cybersecurity positions the country for continental leadership. This is a remarkable achievement for a small country and demonstrates ambition to play a role beyond its size. Togo's ratification of the Malabo Convention as one of the 15 countries bringing it into force, combined with implementation through comprehensive national frameworks, shows alignment with continental priorities. The 2024-2028 strategy's explicit goal of making Togo a regional cybersecurity leader provides clear direction and demonstrates strategic thinking. Togo faces challenges common to developing countries: resource constraints, capacity gaps, infrastructure limitations, and the need to balance security with development. However, the country's strategic positioning, institutional frameworks, and international partnerships provide strong foundations for progress. The success of Togo's regional leadership ambitions will depend on effectively operationalizing the African Center, delivering on commitments to other African countries, maintaining momentum on strategy implementation, and securing sustained funding for cybersecurity initiatives. Togo's experience offers important lessons for other African countries: the value of clear strategic vision, the importance of dedicated institutions like ANCY, the benefits of regional cooperation and positioning, and the potential for small countries to achieve regional leadership through strategic commitment and effective partnerships. As Africa continues its digital transformation, Togo is positioning itself not just as a model for effective cybersecurity governance, but as a resource and partner for other African countries seeking to strengthen their own frameworks. The establishment of the African Center provides infrastructure for this continental contribution. With sustained commitment, adequate resources, and effective implementation of the 2024-2028 strategy, Togo can achieve its ambition of regional cybersecurity leadership and make lasting contributions to African digital governance. The country's progress demonstrates that size is not destiny—strategic vision, institutional development, and international partnerships can enable even small countries to play outsized roles in continental digital transformation.