The development of an Islamic finance industry in Africa could help plug the region's large infrastructure gaps over the coming decade, according to a new report by Standard & Poor's Ratings Services.

According to the report titled Regulations And Fiscal Incentives Could Speed Islamic Finance Development In Africa, a framework of regulation and fiscal adjustments will be necessary to foster African sukuk markets, provide wider investment options for potential Islamic investors, and attract a pool of Islamic liquidity.

To date, African sovereigns have issued about $1bn of sukuk instruments, compared with global sukuk issuance of an average $100bn per year over the past five years.

Meanwhile, widening fiscal deficits and large infrastructure gaps will likely require multibillion-dollar additional financing needs over the next decade.

S&P said that experience in South Africa and Senegal has shown that a significant amount of time can elapse between governments' announcement of intent to issue sukuk and their effective issuance, as governments gauge market interests and try to address the legal hurdles and cost of issuance.

Samira Mensah, Standard & Poor's Credit Analyst, said: "We believe legislation gaps are the main causes of delay between a country's intent to issue and its effective issuance of sukuk.”

For example, the success of Malaysia in South-East Asia as a hub for Islamic finance lies, among other things, in the strong regulatory framework to support the sector's growth.

Malaysia also moved quickly in 2009 to address the standardization of instruments and interpretation of Sharia law.

Tax regimes are equally important to consider when encouraging sukuk issuance.

Sharia-compliant instruments require equal treatment with conventional instruments for investors to consider them.

Malaysia introduced various tax incentives that made Islamic finance a cheaper economic alternative for institutions to raise funding.

The involvement of major multilateral institutions could accelerate the development of African sukuk issuance, the report said.

As such, increasing technical assistance by the Islamic Development Bank (IDB) and Islamic Corporation for the Development of the Private Sector (ICD), is gradually facilitating sovereign sukuk issues.

"We believe that a growing interest in Islamic finance could encourage some North African countries, as well as sub-Saharan countries Cote d'Ivoire, Nigeria, and Kenya, which have fairly well developed capital markets by regional standard, to issue sukuk in the future," said Mensah.