Uganda’s Public Procurement and Disposal of Public Assets (PPDA) Appeals Tribunal has dismissed as “incompetent” Minet Uganda Insurance Brokers Limited’s application challenging the award of an insurance brokerage contract by Uganda Electricity Transmission Company Limited (UETCL) to Clarkson Insurance Brokers Ltd.
In its decision delivered on February 20, 2026, the Tribunal held that Minet’s application had been filed outside the strict statutory timelines prescribed under the PPDA Act, thereby depriving the Tribunal of jurisdiction to consider the merits of the case.
In a unanimous decision, the seven-member Tribunal panel struck out Minet Uganda Insurance Brokers Limited’s application, holding that it was filed outside the statutory timelines prescribed under the PPDA Act. The panel, chaired by Francis Gimara SC, comprised Nelson Nerima, Geoffrey Nuwagira Kakira, Paul Kalumba, Charity Kyarisiima, Keto Kayemba, and Eng. Cyrus Titus Aomu. In its final orders, the Tribunal vacated the suspension order it had earlier issued and directed that each party bear its own costs.
“In view of the foregoing, the Application is incompetent. In the absence of a valid application, the Tribunal has no jurisdiction to inquire into the merits of the case,” the panel unequivocally stated.
The panel further emphasised that statutory time limits under the PPDA Act are matters of substantive law and must be strictly complied with, underscoring that late filing deprives the Tribunal of jurisdiction.
The Procurement Dispute in Brief
The dispute arose from UETCL’s open domestic bidding process for the provision of insurance brokerage services for the financial years 2025–2026 under Procurement Reference No. UETCL/NCON/2025-2026/00115. Six brokerage firms submitted bids, including Minet Uganda Insurance Brokers Limited and Clarkson Insurance Brokers Ltd.
On December 23, 2025, UETCL issued a Notice of the Best Evaluated Bidder (BEB), declaring Clarkson Insurance Brokers Ltd as the successful bidder. The notice indicated that Minet’s bid was unsuccessful at the financial comparison stage on the grounds that its average annual turnover — UGX 9,699,889,667 — was lower than Clarkson’s UGX 12,128,983,380.
Dissatisfied with the outcome, Minet lodged an Administrative Review complaint with UETCL’s Accounting Officer on January 7, 2026, challenging the evaluation process. After the complaint was dismissed, Minet escalated the matter to the PPDA Appeals Tribunal on January 30, 2026.
However, the Tribunal found that the application had been filed outside the statutory ten-day window required under the PPDA Act. It held that late filing rendered the application incompetent and deprived it of jurisdiction to consider the merits of the challenge.
“The ten-day period commenced on Sunday, January 18, 2026 and expired on Tuesday, 27 January 2026. The Application was instead filed on 30 January 2026, outside the statutory timeframe, rendering it incompetent,” the procurement appeals tribunal ruled.
Following Minet’s appeal, the Tribunal had issued a suspension order to halt the progression of the procurement pending the determination of the matter.
However, in its final orders, the Tribunal stated: “The Application is struck out” and “The Tribunal’s suspension order dated February 2, 2026, is vacated.”
By striking out the application and lifting the suspension, the panel effectively cleared the way for UETCL to proceed with the award to Clarkson.
Beyond the Tribunal Loss Lies a Deeper Market Share fight
Minet’s loss of this strategically important deal is even more significant because Clarkson is not just another competitor. It is the very firm that dislodged Minet from its traditional No. 1 position — a position Minet had held for many years at the summit of Uganda’s insurance brokerage market.
This is not a routine tender defeat. It is a moment within a broader, structural shift in industry leadership and the battle for market share, as analysis of Insurance Regulatory Authority (IRA) reports from 2016 to Q3 2025, premium volume, commission income and market share reveals.
Premiums reflect the scale of risk portfolios controlled. Commission represents the broker’s actual revenue earned from that premium. Market share is calculated on commission. When all three move together, leadership changes.
According to IRA market reportsbetween 2016 and 2018, Minet firmly occupied the summit of Uganda’s insurance brokerage market, controlling both premium flows and commission income. In 2017 alone, Minet placed approximately UGX 53.9 billion in premiums and earned about UGX 9.46 billion in gross commission, translating into roughly 23% market share. Clarkson, by comparison, generated around UGX 2.78 billion in commission from approximately UGX 19.8 billion in premiums, holding under 7% share. The following year, the hierarchy remained intact: Minet placed roughly UGX 50 billion in premiums and earned about UGX 8.66 billion in commission (18.88% share), while Clarkson grew to approximately UGX 34.5 billion in premiums and UGX 4.95 billion in commission (10.80% share). Clarkson was rising, but Minet still led decisively. The inflection point came in 2019, when premium volumes between the two firms were nearly identical — Minet at about UGX 47.1 billion and Clarkson at UGX 46.6 billion — yet commission capture diverged sharply. Clarkson earned roughly UGX 7.05 billion in commission, compared to Minet’s UGX 5.16 billion, translating into 16.21% market share for Clarkson versus 11.86% for Minet.
The next two years, 2020 and 2021, were defined by near parity. In 2020, Minet earned about UGX 7.43 billion in commission (15.33% share), while Clarkson earned UGX 7.08 billion (14.62% share). In 2021, commission earnings were almost identical — UGX 7.72 billion for Minet and UGX 7.65 billion for Clarkson — with market shares separated by fractions of a percentage point. It was a knife-edge contest.
But from 2022 onward, the divergence became clearer. By 2023, Clarkson had expanded to roughly UGX 99.6 billion in premiums and UGX 12.55 billion in commission, capturing 16.33% market share. Minet, in contrast, placed around UGX 97.2 billion in premiums and earned UGX 10.65 billion in commission , holding 13.85% share. Clarkson controlled significantly more premium volume and translated it into higher commission income.
Afreximbank Extends $50 Million Debt Financing to Spiro Electric Mobility CompanyIn 2024, the gap widened further. Clarkson maintained premium placements above UGX 103 billion and earned approximately UGX 14.74 billion in commission, equivalent to 17.46% market share. Minet placed roughly UGX 76.9 billion in premiums and earned UGX 10.07 billion in commission, holding 11.93% share. The commission difference — nearly UGX 4.7 billion — represented not just a ranking gap but a substantial revenue advantage.
By Q3 2025, Clarkson remained ahead, earning about UGX 12.09 billion in commission (18.60% share) from roughly UGX 91.6 billion in premiums, compared to Minet’s UGX 10.22 billion in commission (15.73% share) from approximately UGX 73.7 billion in premiums.
Clarkson’s Rise to the Top in a Foreign-Dominated Financial Landscape
The rise of Clarkson, a locally owned and Ugandan-led insurance brokerage firm, to the top of the market is unprecedented in Uganda’s modern financial services landscape. For decades, the commanding heights of life insurance, general insurance, and banking have largely been occupied by majority foreign-owned institutions — subsidiaries of Kenyan, South African, Mauritian, or global financial groups.
In life insurance, the leading players are regionally or internationally backed. In general insurance, the dominant underwriters similarly trace their capital to foreign shareholders. The banking sector reflects the same pattern: most of the largest institutions are controlled by regional banking groups or multinational financial networks. Indigenous leadership at the very top of mainstream financial services has historically been the exception rather than the norm.
Minet itself operates within that broader capital architecture. Nearly 70% of Minet Uganda is held by Minet Holdings Mauritius Limited (68.14%), embedding it within a Pan-African ownership structure following Aon’s 2018 divestment. Before that exit, Minet functioned under Aon’s global umbrella — a structure that influenced strategic posture, including its historically cautious stance toward government business.
In an October 2025 interview with the CEO of East Africa Magazine, Minet Uganda CEO Edward Nambafu said that his firm’s sliding out of the number one position was because Aon, the company, was not keen on government business, yet government, especially government parastatals such as UETCL, are key players in the insurance business.
“Historically, we hadn’t been so active in government business, largely because of the group’s position at the time. Aon, given its global heritage, considered the government risky in terms of brand exposure,” he said.
Following Aon’s exit, that posture shifted: “Since Aon divested in 2018 and Minet became a purely Pan-African entity, our leadership agreed that we couldn’t’t ignore the government space. We have since explored that space too, and it’s one of the areas we’re now actively engaging.”
Minet’s failure to wrestle the UETCL mandate from Clarkson therefore represents more than a lost contract — it is a significant dent in its renewed push into government business, a pillar Edward Nambafu has openly identified as central to the company’s resurgence strategy since taking over as CEO in September 2022. In the context of a broader comeback plan aimed at reclaiming market leadership, losing a high-profile parastatal account to the very competitor that displaced it from the top spot is a material setback.
That aside, Minet’s resort to litigation can be read as a defensive counteroffensive — a signal of how strategically important flagship government accounts have become to its comeback plan — but it also carries reputational risk, as prolonged procurement disputes may influence market perceptions about competitiveness, strategic resilience, and client confidence in an intensely relationship-driven brokerage industry.
The Future of Brokerage Competition in Uganda
The UETCL dispute is therefore not just a procurement quarrel. It is a tell-tale sign of a brokerage market entering a more competitive, more concentrated, and more strategically unforgiving era, where, among others, the structure of insurance distribution is changing. The brokerage channel, which once commanded 35.03% of total industry premiums in 2021, has seen its share decline to 30.94% in 2024 and further to 27.2% by Q3 2025. Meanwhile, bancassurance premiums have surged from UGX 142.7 billion in 2022 to UGX 225 billion in 2024, growing faster than the overall market. Brokers are no longer expanding in tandem with industry growth. They are fighting to defend their share within a channel that is itself losing proportional ground.
This intensifies the pressure within the brokerage segment. As of Q3 2025, the top five brokers controlled approximately 60.9% of total brokerage commission, while the bottom ten account for barely 0.56% combined. Scale is consolidating upward. Smaller firms face margin compression and relevance risk. The regulator has already signalled that consolidation is not only welcome but necessary to build stronger, better-capitalised intermediaries capable of underwriting larger and more complex risks.
French broker Olea’s entry through the acquisition of Ballpack in 2023 and its subsequent merger with Marsh Uganda in 2025 underscore that consolidation in Uganda’s brokerage market is not theoretical — it is already happening. In effect, Marsh Uganda — part of the American giant Marsh McLennan, the world’s largest insurance broker — was absorbed into a regional Pan-African platform, surrendering its standalone position in the market. The disappearance of a global brand as an independent competitor signals just how intense, competitive and scale pressures have become. In a market where premium concentration is rising and distribution share is tightening, even a multinational pedigree does not guarantee permanence.
The future competitive question may therefore not be simply local versus foreign-owned. It may instead be specialist versus generalist. As risks become more technical — oil and gas, infrastructure, cyber, ESG-linked exposures — brokers that can demonstrate technical depth, claims management expertise, and structured risk advisory may gain an advantage over those competing primarily on legacy relationships or brand visibility. In a concentrated market, differentiation increasingly hinges on specialisation and execution.
For Clarkson, maintaining leadership will require continued premium control and disciplined commission capture in a shrinking channel. For Minet, reclaiming lost ground remains central to its comeback strategy under CEO Edward Nambafu. For Olea and other challengers, consolidation and cross-border integration offer a route to scale. For smaller brokers, survival may depend on niche focus or strategic partnerships.
In that environment, the UETCL suit is less an isolated legal episode than a reflection of how high the stakes have become. When nearly one-third of a UGX 1.5 trillion industry flows through brokers, and when over 60% of that commission pool is concentrated in five firms, every flagship account matters.
The future of brokerage competition in Uganda will not be decided by heritage, ownership structure, or branding alone. Leadership will belong to those who control premium flow, monetise it efficiently through commission capture, and defend their position in an increasingly consolidated and technically demanding market. In brokerage, as the numbers now make clear, dominance is earned — not inherited.
