Sao Tome and Prinicpe

The APCI: Your Investment Agency Interface 

What Is the APCI?

The Agência de Promoção do Comércio e Investimento (APCI)—Investment and Trade Promotion Agency—is your primary government interface for investment in São Tomé and Príncipe.

Legal status: Public law entity with administrative and financial autonomy

Established: Decree-Law 2/2012, statute approved by Decree-Law 57/2013

Tutelage: Minister responsible for commerce

Think of it as: Your one-stop shop for investment approval, registration, and support.

The APCI's Core Functions

1. Investment Promotion

Positioning São Tomé and Príncipe as investment destination (marketed as "The Friendly Country at Centre of the World")

Priority sectors promoted:

• Tourism
• Agro-business
• Fisheries
• Renewable energy
• Service delivery platform

2. Investment Single Window (Balcão Único)

Central coordination point for:

• Investment applications
• Multi-agency approvals
• CAI negotiation support
• CRIP issuance

Goal: Avoid investors navigating multiple ministries separately

3. Trade Facilitation

Support for importers/exporters, promotion of "Made in São Tomé and Príncipe" products

4. Public-Private Dialogue

Facilitating communication between investors and government to improve business environment

5. Policy Input

Contributing to regulatory framework revision and investment climate improvements

The Investment Application Process Through APCI

Step 1: Application Submission

What to submit: Three copies of complete investment proposal including:

• Project description
• Economic and financial characteristics
• Job creation projections
• Environmental impact study (if applicable)
• Proof of capital availability (20% minimum)
• Feasibility study

Where: APCI secretariat

Fee: €500 non-reimbursable processing fee (~12,250 Dobras)

Advice: Submit complete, professional documentation the first time—incomplete applications delay the clock

Step 2: Interagency Review

APCI's coordination role:

• Sends complete copies to all relevant agencies simultaneously via electronic means
• Key agencies: Customs Directorate, Tax Directorate, Planning Directorate, sector ministries

Agency response deadline: 5 working days for technical opinions

APCI compilation: 48 hours to submit fully reviewed file to Minister of Planning

Step 3: Ministerial Approval

Timeline: Projects must receive express or tacit authorization within 45 days

APCI's role: Facilitates process, advocates for approval, coordinates any clarifications needed

Step 4: CAI Negotiation

APCI supports:

• Coordination with Asset Department (DPE) for contract drafting
• Facilitation of terms negotiation
• Administrative processing

Your responsibility: Engage legal counsel for CAI review—APCI helps process, not advocate solely for your interests

Step 5: CRIP Issuance

Timeline: 3 days from project approval

APCI action: Issues certificate, initialed and authenticated by Agency head

Your verification: Confirm CRIP accuracy immediately upon receipt

Step 6: Ongoing Monitoring

Your obligation: Submit annual information to APCI on:

• Implementation progress
• Development status
• Profits and dividends
• Employment numbers

APCI action: Compiles annual descriptive report for Ministry

Purpose: Compliance verification, problem identification, policy assessment

Official Timelines vs. Reality

What the Law Says

• Agency opinions: 5 working days
• APCI ministerial submission: 48 hours
• Total approval: 45 days
• CRIP issuance: 3 days

Total legal timeline: ~50 days from submission to CRIP

What Actually Happens

Realistic timeline: 3-6 months from submission to CRIP

Reasons for delays:

• Incomplete initial submissions requiring clarification
• Agencies miss 5-day deadline (no enforcement)
• Ministerial approval backlog
• CAI negotiation complexity
• APCI capacity constraints

Your approach: Budget 4-6 months; pleasant surprise if faster

The Capacity Challenge

APCI's own institutional assessment acknowledges:

"Despite its legal framework granting organizational and financial autonomy, APCI lacks adequate resources and institutional support to effectively fulfill its role."

What This Means Practically

Limited staff: Small team handling all investment promotion, application processing, monitoring

Resource constraints: Limited budget for proactive investor support, sector promotion, capacity building

Language limitations: Website and services primarily Portuguese; limited English support

No comprehensive online portal: Unlike leading investment agencies, no digital single window in multiple languages

Minimal proactive outreach: APCI responds to applications but provides limited unsolicited guidance

APCI President's Frank Assessment

"The public administration in STP is not a friend of the investor."

This candid acknowledgment from APCI's own leadership signals:

• Bureaucratic resistance exists
• APCI advocates for investors but faces internal constraints
• Investor patience and persistence are required
• Don't expect seamless, investor-friendly processes

Achievements and Progress

Despite constraints, APCI has notable accomplishments:

2019: Shortlisted for "Best Investment Promotion Agency in Africa" award

October 2025: Registered first offshore banking company (Consenso Bank Offshore, S.A.)

Investment volume: Publicized over €14 million in projects submitted for approval

Free Zone management: Handles pending Free Zone Authority matters pending new entity creation

Message: APCI is functional and achieving results, just not at the efficiency level of well-resourced agencies

How to Work Effectively With APCI

1. Engage Early

Before formal application:

• Visit APCI office in person if possible
• Discuss project informally
• Understand current priorities and concerns
• Get preliminary feedback on viability

Why: Personal relationships matter in small markets; face-to-face contact helps

2. Submit Complete, Professional Documentation

Hire local consultant to prepare application:

• Ensures compliance with format expectations
• Uses appropriate Portuguese terminology
• Addresses anticipated agency concerns
• Knows APCI staff and process nuances

Cost: €3,000-€8,000 for professional application preparation—worthwhile investment

3. Follow Up Proactively

Don't wait passively:

• Call/email APCI weekly for status updates
• Offer to provide clarifications immediately
• Gently remind of legal timelines
• Maintain friendly but persistent contact

Why: Resource-constrained agencies prioritize squeaky wheels; passive applications languish

4. Use Legal Counsel for CAI Negotiation

APCI facilitates but doesn't negotiate for you:

• Hire experienced São Toméan lawyer for CAI review
• APCI coordinates with Asset Department, but you need advocate
• Legal counsel ensures favorable terms

5. Maintain Good Ongoing Relationship

Annual reporting requirement:

• Submit on time, professionally formatted
• Highlight positive impacts (jobs, investment, exports)
• Flag challenges early
• Request support when needed

Why: APCI can help resolve issues with other ministries, expedite permits, provide sector intelligence

6. Be Patient But Firm

Acknowledge constraints while insisting on legal rights:

• Understand APCI capacity limits
• Don't expect instant responses
• But politely cite legal timelines when delays are excessive
• Escalate to Ministry if deadlines wildly exceeded

Sanction Procedures: Your Rights

If APCI initiates penalty procedures against you:

Mandatory hearing: Right to present your case before penalties applied

Lawyer representation: Right to be accompanied by counsel

Evidence submission: Opportunity to provide documentation

Advance notice: Minimum 20 days before hearing

Why this matters: You have due process rights even in sanction procedures

Contact and Information

APCI location: São Tomé (check current contact details as staff/location may change)

Website: Exists but primarily Portuguese-language

Challenge: Limited English materials; no comprehensive online portal

Recommendation: Engage local consultant/lawyer to interface with APCI in Portuguese

Alternatives and Workarounds

If APCI Delays Are Unacceptable

Ministerial escalation:

• After 60+ days with no approval, request meeting with Ministry of Planning
• Politely note legal 45-day timeline
• Ask for intervention

Diplomatic channels (for larger investments):

• Engage your embassy/consulate
• Request diplomatic note to Ministry
• High-level investors sometimes get priority processing

Media/publicity (use carefully):

• Press coverage of major investment can accelerate approvals
• But can backfire if perceived as pressure
• Only for significant projects with government political interest

The Bottom Line

APCI is your mandatory interface for investment in São Tomé and Príncipe with important functions:

✓ Processes investment applications ✓ Coordinates multi-agency approvals ✓ Issues CRIP certificates ✓ Provides ongoing monitoring ✓ Advocates for investor-friendly policies

But operates with significant constraints:

❌ Limited resources and institutional support ❌ Slow actual processing vs. legal timelines ❌ Minimal proactive investor support ❌ Language barriers for non-Portuguese speakers ❌ General public administration not "friend of investor" (per APCI President)

Your approach:

1. Budget 4-6 months for approval process (not 45 days)
2. Hire local consultant for application preparation and APCI interfacing
3. Follow up persistently but respectfully
4. Engage legal counsel for CAI negotiation
5. Maintain good relationship through professional annual reporting
6. Be patient with constraints while firm on legal rights
7. Escalate appropriately if delays become excessive

APCI functions and has achieved results—but don't expect the efficiency of well-resourced investment agencies in more developed markets. Treat engagement as relationship-building in a resource-constrained environment rather than transactional process with guaranteed timelines.

For investors willing to work within these realities, APCI provides the gateway to São Tomé and Príncipe's investment opportunities. Just plan accordingly for what "single window" actually means in practice.

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