Overview (TLDR)
Uganda’s Internet ecosystem has achieved remarkable progress over the past three decades. Sound regulation, private-sector investment, and community collaboration have created one of the most competitive markets in the region. Wholesale bandwidth prices have dropped from roughly $5,000 to $0.50 per megabit in just 15 years, and nearly all networks now interconnect locally through the Uganda Internet Exchange Point (UIXP), a neutral, non-profit service that enables fast, secure, and affordable traffic exchange.
Uganda’s well functioning industry has attracted investment from infrastructure developers, international wholesalers, global content providers, and local access networks – fostering competitive pricing dynamics and sophisticated commercial collaborations. Uganda also recently attracted its first carrier-neutral data center, Raxio, which is a critical facility for hosting large-scale content, facilitating interconnection, and strengthening Uganda’s position in the regional digital economy.
Recently, however, the National Information Technology Authority (NITA-U) announced plans to launch a government-run Internet Exchange Point (IXP) with an ambiguously worded requirement for "Mandatory Domestic Peering" which suggests that ISPs may be obligated to exchange domestic traffic at the new IXP, though the scope and enforcement of this requirement remain unclear. Separately, consultants hired by the Uganda Communications Commission (UCC) produced a market study which recommends the deployment of additional IXPs in secondary cities based on uncorroborated sources and questionable methodologies provided by ChatGPT.
While these initiatives may be well-meaning, they are not based on market demand. As a result, they could unintentionally oversupply and fragment the market, slow sector growth, and weaken the country’s prospects as an emerging regional Internet hub. In particular, the launch of a mandatory government IXP constitutes a state entry into a private-sector industry which could discourage investment, deter new entrants, and pave the way for a de jure national monopoly.
While there is a growing need for redundancy in Uganda's IXP ecosystem, international experience shows that this is best achieved through private-sector competition. If the government requires redundancy beyond what private IXP operators can provide, bilateral Private Network Interconnections (PNIs) are the best solution. PNIs, also known as cross-connects, are simple and cheap to deploy and maintain, and can be used for mandatory public/private interconnections without introducing the risks associated with a multilateral government IXP.
Uganda’s Internet ecosystem is already on a successful path. If we stay the course, the country will soon reach the scale where multiple private IXPs can coexist sustainably based on market demand, similar to the natural growth experienced in Kenya, Nigeria, South Africa, and other regional markets. The government can accelerate this outcome by reconsidering its plan to launch an IXP in favour of safer alternatives such as Private Network Interconnects (PNIs), by reducing taxes to stimulate demand, by making it easier to do business in Uganda, and by continuing to nurture the existing private-sector ecosystem.
A Note on Perspective
As Uganda’s only existing IXP operator, we recognise that some may view our position as self-interested. However, the UIXP was founded in 2001 as a non-profit community initiative and has actively defended open market access including the right for other IXPs to compete based on voluntary market dynamics. Our position is guided not by self-preservation, but by experience, data, and international best practice which we encourage readers to verify through the references provided.
Over nearly two decades, we have built a strong and respectful relationship with the Government of Uganda based on transparency, trust, and collaboration. Multiple government networks are now connected to our exchange and even pay to support the platform’s sustainability. Two of these networks (UTL & NITA) have partnered with us on initiatives such as the Google and Akamai caching projects. We also work closely with various government agencies on security and technical matters from time to time.
In that spirit, our hope is that this post can provide an evidence-based contribution that helps the government avoid actions that could unintentionally harm Uganda’s Internet ecosystem and national economy.
How the Internet & IXPs Work
The Internet is not a single network, but a "network of networks," whereby thousands of independent networks operated by service providers, governments, and content companies interconnect to exchange data. These interconnections can occur in several ways, but the most efficient and scalable way is through Internet Exchange Points (IXPs) which are neutral switching platforms where multiple networks meet to exchange data traffic directly.
A simple economic rule underpins the Internet: "Distance = Cost." The closer content and users are to each other, the faster and cheaper their communication becomes.
In Uganda, most of the content and services people access are hosted abroad. This international traffic reaches the country via submarine cables landing in Mombasa and Dar es Salaam, then travels inland through cross-border fibre connections. Because this data must traverse long distances, it is relatively costly to deliver and slower to reach end users.
IXPs like the Uganda Internet Exchange Point (UIXP) make it easier and more cost-effective for networks and platform providers to host content and services locally. This allows them to serve users from Uganda rather than from abroad. This lowers the overall cost of Internet service delivery, improves Internet performance, reduces Uganda’s reliance on international links, and makes investment in data centers and digital infrastructure more attractive.
Beyond improving performance and affordability, IXPs strengthen national resilience and security by keeping domestic traffic within Uganda, ensuring that it can continue to flow even if international links are disrupted. However, IXPs are not the only way networks can interconnect: operators can also establish Private Network Interconnects (PNIs) or exchange traffic regionally through facilities in neighboring countries. A healthy Internet ecosystem supports multiple interconnection models while letting the market determine the most effective approach.
The State of the Internet in Uganda
For three decades the government, industry, and local community have fostered healthy competition and growth. Today, Uganda’s Internet ecosystem is strong, resilient, and sophisticated:
- Multiple cross-border fibre routes connect Uganda to the global Internet via the Kenyan and Tanzanian coast, and inland to Rwanda, South Sudan, and the DRC.
- The backbone and metro fibre markets are open and competitive with robust infrastructure sharing and advanced service offerings including dark fibre.
- The access market is vibrant with a variety of local, regional, and global operators covering mobile, wireless, and fixed-line communications. Competitive dynamics have led to tower sharing and rapid retail price reductions and Uganda now boast some of the lowest access prices in the African region.
- Data center infrastructure is diversifying as evidenced by the 2021 launch of Raxio, the country’s first carrier-neutral colocation facility.
- The non-profit UIXP interconnects nearly all networks within the country, operates with excess capacity, and has strong community support. The UIXP is considered a model IXP within the region and plays a leading role in various pan-African institutions. Its success has attracted regional networks and global content providers including Akamai, Meta, and Netflix which now host their data locally, directly improving user experiences and keeping value within the country.
But Uganda does not operate in isolation; it competes directly with Kenya, a more established regional hub where the private sector has produced multiple IXPs and data centers. With coastal access and a larger economy, Kenya holds structural advantages, so Uganda must capitalise on its own strengths and avoid policy missteps that could undermine its attractiveness to investors, content providers, and other industry players.
What Is the Government Proposing?
In October 2025, NITA-U announced the creation of a government-run IXP called the National IP Peering Exchange (NIPX), with a "Mandatory Domestic Peering" requirement which states that networks would be "encouraged and, where applicable, required to exchange domestic traffic at the NIPX." The stated goals include improving performance, reducing international dependency, and strengthening digital sovereignty. Yet no industry or public consultation appears to have been conducted prior to the announcement, and the referenced National Peering Policy is not publicly available beyond the information included in the announcement.
Separately, the UCC recently engaged consultants who generated an extensive market analysis report that recommends building two more IXPs in secondary cities based solely on population-based formulas cited from an uncorroborated ITU report. Alarmingly, this recommendation and the wider report appears to have been generated by ChatGPT, casting doubt on its methodological rigor. We understand that the UCC conducted a validation workshop for this report, but we were not included in that process and do not know if they intend to pursue this specific recommendation.
These initiatives, though independent and presumably well intentioned, raise serious concerns because they would introduce significant structural changes to the market without clear evidence of demand or national benefit.
Exploring the Motivations for a Government IXP
The rationale stated in NITA’s IXP announcement sounds appealing — increased digital sovereignty, faster speeds, lower costs, and greater security — but in Uganda’s case, these issues are already addressed:
- Digital Sovereignty: Nearly all networks in Uganda already interconnect voluntarily via the UIXP and various Private Network Interconnects (PNIs), so the capacity to localise traffic and content already exists. Rather than duplicating this capacity, the government should build on it by creating an enabling environment that attracts more content and cross-border interconnection to existing private-sector facilities such in order to stimulate additional investment in the sector.
- Performance & Cost: Because the capacity to localise domestic traffic and content already exists, a new IXP would not materially improve national Internet performance unless it succeeds in attracting additional content and interconnection beyond what the existing ecosystem already enables. Since government-operated IXPs tend to under-perform and are typically less
attractive to network operators than private IXPs, a new government IXP is unlikely to achieve this.
Furthermore, because the cost of peering via the UIXP is a relatively insignificant component of overall service delivery costs, a government IXP would not
materially reduce national Internet access costs even if it offered its
service for free.
- Security: With a significant portion of domestic traffic already being localised via the UIXP and various PNIs, Uganda’s reliance on foreign transit networks and cable systems for internal communications is already reduced, significantly lowering the risk of external eavesdropping and traffic manipulation. When it comes to state security, the government has dedicated network infrastructure, encrypts its inter-network traffic, and has a wide range of tools to enforce its monitoring and censorship authority including regulatory compliance systems hosted inside Uganda's various access networks — a far more direct and effective point of control amid Uganda's increasingly complex web of interconnections.
Beyond the stated objectives, some might wonder if the government's motivation includes a desire for financial income, but we think this would be misguided because most IXPs are not money-making ventures and the opportunities for profit in Uganda are extremely limited. The UIXP, for example, operated entirely on volunteer effort and donations from 2001 to 2017. Even today, with around 30 connected networks, it only earns enough income to cover operations, pay salaries, and ensure long-term sustainability. Simply put, there is no "gold mine" and a government-run IXP is more likely to become a recurring cost than a source of revenue.
In light of the above, we believe a mandatory government IXP would offer no clear commercial, public, or national benefit, and would introduce significant risks compared to the safer alternative of mandatory PNIs.
The Likely Impact on Uganda’s Digital Ecosystem
Regardless of any benefits, the imposition of a mandatory government IXP could have several unintended consequences:
- Premature Fragmentation: Forcefully splitting Uganda's demand for multilateral network interconnection across multiple facilities could unnecessarily dilute network effects which, in turn, could slow the growth of Uganda's data center ecosystem and hinder the country's development as an inland regional Internet hub.
- Higher Service Delivery Costs: Similarly, forcing ISPs to connect to a new IXP without corresponding market demand could artificially increase network complexity and inflate service delivery costs.
- New Market Barriers: Mandatory multilateral peering requirements would discourage some networks from entering Uganda. International networks are often unwilling to enter markets where they would be forced to interconnect with competitors or customers against their will.
- Reduced Investment: In addition to the above, top-down policy shifts, especially government forays into private markets, introduce uncertainty and risk in a sector that depends heavily on stability and predictability.
- Slower Economic Growth: Premature fragmentation, increased operational costs, new market barriers, and reduced investor confidence would slow market development, job creation, and broader economic growth.
- Wasted Public Funds: Building redundant infrastructure when private solutions already exist diverts resources from more pressing national priorities.
In summary, mandatory government IXPs can distort market dynamics, increase service delivery costs, discourage market participation, deter investment, and slow economic growth — outcomes that run counter to Uganda's development objectives. They also carry a significant risk of mandate expansion that could concentrate control over domestic interconnection.
In contrast, when a new private IXP enters the market, it offers services and succeeds only if there is genuine demand; otherwise the market naturally filters out unnecessary facilities. This voluntary, demand-driven model avoids premature fragmentation and maintains the coherence of the domestic interconnection environment.
In time, as Uganda’s economy grows and the regional Internet ecosystem expands, a second IXP will become both viable and healthy for the market — but it should emerge naturally from market demand, not through a top-down intervention.
What Should Be Done Instead
- Mandate Private Network Interconnects (PNIs) between government and private networks to gain more redundancy and control over critical traffic flows without incurring all of the costs and risks associated with launching a government IXP.
- Reduce Internet taxes which now account for over 50% of the cost of access in order to improve accessibility, grow demand, and improve market competitiveness.
- Facilitate investment and competition by making it easier to do business in Uganda and by avoiding unpredictable and undesirable market interventions.
- Continue collaborations with community stakeholders including the UIXP in order to identify effective ways to further develop Uganda’s Internet ecosystem and strengthen its regional position.
- Promote carrier neutral data centers like Raxio by deploying government services (such as NIRA) inside these facilities, and by avoiding actions that would unnecessarily dilute their ecosystems.
- Authorise LEO satellite systems with in-country ground stations, traffic-localisation requirements, and other restrictions to prevent market distortions.
- Engage in open consultation with industry and civil society before undertaking significant actions or policy changes to ensure alignment with local and regional market realities.
- Promote broader economic development because the Internet industry cannot grow unless the overall economy does.
Conclusion
Uganda’s Internet industry has thrived on market-driven investment, competition, and collaboration. A second IXP could strengthen this ecosystem, but only where there is sufficient natural demand to sustain it. A mandatory government-run exchange, by contrast, would offer no clear benefit, risk premature fragmentation of the Internet ecosystem, and weaken Uganda’s long-term growth prospects.
We encourage the government to take a step back, consult openly with stakeholders, and base its next moves on evidence and market realities. Uganda’s incredible progress over the past two decades has been driven by enabling innovation, not imposing it, and this strategy remains key to future growth.
By staying true to these principles, Uganda can protect the gains that have made its Internet industry one of the most advanced in the region.
Formal Submission
In order to ensure that our views are considered by the government, the UIXP made a formal submission to NITA-U and the Ministry of ICT & National Guidance on December 11, 2025. A copy of this submission can be found on our website.











