Bringing E Money To The Poor. Successes and Failures PDF

DIREC TIONS IN DE VELOPMENT
Finance
Bringing E-money to the Poor

Successes and Failures
Thyra A. Riley and Anoma Kulathunga

DIREC TIONS IN DE VELOPMENT
Finance

Successes and Failures
Thyra A. Riley and Anoma Kulathunga

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ISBN (paper): 978-1-4648-0462-5

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DOI: 10.1596/978-1-4648-0462-5
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Bringing E-money to the Poor • http://dx.doi.org/10.1596/978-1-4648-0462-5

Contents
Foreword xi
Acknowledgments xiii
About the Authors xv
Abbreviations xvii
Overview 1
Background 1
Motivation and Evidence 3
Target Audience 5
Methodology: Country Selection and Financial
Inclusion Status 5
Organization of This Volume 10
Notes 12
Bibliography 13
PART I Journey toward a Cash-Lite Society and

Financial Inclusion 15
Chapter 1 The Challenge of Financial Inclusion 17

What Is Financial Inclusion? 17
Why Does Financial Inclusion Matter? 20
The Global Financial Inclusion Gap 22
South Asia’s Financial Inclusion Gap 23
Poverty, Financial Exclusion, and Financial Vulnerability
in South Asia 27
Remittance Transfers and Financial Inclusion 29
Notes 32
Bibliography 33
Chapter 2 Digitizing Financial Inclusion through Innovations 37

Types of Innovation for Financial Inclusion 37
E-money and Digital Payments 40
Toward a Cash-Lite Society 42
Bringing E-money to the Poor • http://dx.doi.org/10.1596/978-1-4648-0462-5 v

vi Contents
Risks in Digital Finance 46

Notes 51
Bibliography 51
Chapter 3 Stakeholders in Digital Financial Inclusion 53

Introduction 53
Macro-Level Stakeholders: Policy Makers, Regulators,
and Donors 54
Meso-Level Stakeholders: Enabling Institutions 55
Micro-Level Stakeholders: Institutions Offering
Digital Solutions 56
Customer-Level Stakeholders: Users 57
Bibliography 57
PART II Critical Enablers That Are Game Changers in

Successful E-money Deployments 59
Chapter 4 Policy Leadership and Enabling Regulatory

Environments 63
Introduction 63
Regulatory Balance in Financial Innovation 64
Kenya: Leadership Lesson from the Central Bank of Kenya 65
India: Jan Dhan Yojana Flagship Financial Inclusion Plan 69
Sri Lanka: Regulations Keeping Pace with Technological
Advancements 76
Thailand: A Government’s Vision and Policy to Bring
Cash to the Doorstep 84
The Philippines: The World’s Oldest Mobile Money
Initiative Has Yet to Reach Potential 91
Maldives: Mobile Money Opportunity Still Knocking
at the Door 94
Notes 98
Bibliography 101
Chapter 5 Innovative Uses of Infrastructure and Digital Ecosystems 105

Introduction 105
Interoperability in Indonesia, Pakistan, Sri Lanka,
Tanzania, and Thailand 105
Agent Network Management in Kenya 117
Digitizing Social Grant Disbursement Programs:
Brazil, Mexico, and South Africa 141
Notes 150
Bibliography 151

Contents vii
Chapter 6 Unique Identification 155

Introduction 155
The Philippines: 21 IDs and Counting 158
India’s Aadhaar Program: Potential Game Changer
in Digital Financial Inclusion 163
Sri Lanka: Mobile Connect, the Interoperable ID 171
Notes 174
Bibliography 174
PART III South Asia Digital Landscape, Future

Options, and Conclusions 177
Chapter 7 Digital Landscape in South Asia 179

Introduction 179
Macro-Level Strategies 181
Meso-Level Approaches and Issues 182
Micro-Level Models 183
Customer-Level ID Systems 184
Annex 7A Digital Financial Landscape in South Asia,
by Country: At a Glance 186
Note 193
Bibliography 193
Chapter 8 Opportunities, Challenges, and Future Options

in South Asia 195
Introduction 195
Macro Level 195
Meso Level 197
Micro Level 197
Customer Level 199
Note 199
Bibliography 199
Chapter 9 Conclusions 201

Introduction 201
Role of Governments and Regulators 202
Coordinated Action, Common Platforms,
and Interoperability 205
Outreach by Retail Institutions 206
Increasing Accessibility for Customers 207
The Journey toward a Cash-Lite Society:
Coordination and Balance 208
Appendix A Findex Data for Selected Countries 211

viii Contents
Boxes
1.1 “Financial Inclusion”: A Working Definition 18
2.1 Cash versus Electronic Payments 43
2.2 Doing Digital Finance Right: The Case for Stronger
Customer Risk Mitigation 50
4.1 M-Pesa: A Backstory and an Alternative Perspective 67
4.2 Reserve Bank of India Regulatory Reforms, 2014 76
Figures
1.1 Share of Adults with a Financial Services Account,
by Region, 2014 24
1.2 Share of South Asian Adults with a Financial Services Account,
by Country, 2014 25
1.3 Share of South Asian Adults with a Financial Services Account,
by Gender and Country, 2014 26
1.4 Access to Finance in South Asia: Supply-Side Data, 2010 27
1.5 Poverty, Financial Exclusion, and Financial Vulnerability
Indicators in South Asia, 2014 28
1.6 Remittances and Other Resource Flows to Developing
Countries, 1990–2015 30
2.1 Sample Relative Costs of Payment System Infrastructure,
from Bank Branches to Mobile Phone 43
2.2 Stages and Shifts from a Cash-Heavy to a Cash-Lite Society 45
II.1 Number of Active Mobile Money Services Worldwide,
by Region, 2001–14 61
4.1 Financial Access Strand in Kenya, 2006 65
4.2 Financial Access Trends in Kenya, 2006–13 68
4.3 Use of Financial Services in Kenya, by Type, 2006–13 69
4.4 Zero-Balance Trends in Jan Dhan Yojana Accounts, India,
2014–15 73
4.5 Number of 2G and 3G/4G Connections in India, 2008–17 75
4.6 Financial Access Strand in Thailand, 2013 85
4.7 Financial Access Strand in Thailand, by Region, 2013 85
4.8 Average Time to Financial Service Touchpoints in
Thailand, 2013 89
5.1 Market Share of Sri Lankan Mobile Service Providers, 2014 109
5.2 Schematic of End-to-End Interoperable eZ Cash System 111
5.3 Comparing Mobile Money Use in Tanzania and Kenya,
2007–13 113
5.4 Active Subscriber Market Shares of Tanzanian Mobile Service
Providers, 2014 114
5.5 Financial Account and Mobile-Phone Penetration, Indonesia
versus Selected Asian Countries, 2014 115
5.6 Mobile Money Awareness in Indonesia, 2014 116

Contents ix
5.7 Number of Financial Access Points across Developing

Countries, 2014 118
5.8 Growth in Number of M-Pesa Customers and Agents, 2007–14 120
5.9 Initial M-Pesa Agent Network Structure 123
5.10 M-Pesa Agent Network Structure with Formal Introduction
of Aggregators 124
5.11 Current M-Pesa Agent Network Structure and E-float/Cash
Management Process 126
5.12 Mobile Money Transfer Value Chain 129
5.13 M-Pesa Service Development, 2007–13 130
5.14 Growth in Number of M-Shwari Savings Accounts, 2013–14 136
5.15 Average Capital Expenditure Costs for Financial Service
Providers in Kenya, by Channel 140
5.16 Share of Adults Receiving Government Transfers, by
Region and Payment Method, 2014 142
5.17 Financial Access Strand in South Africa, 2004–14 147
6.1 Use and Awareness of Payment System Providers in the
Philippines, 2010 162
6.2 Aadhaar Registration Trends in India, 2014–15 164
6.3 Top 10 States for Aadhaar Registration in India, 2015 164
6.4 Aadhaar Registration, by Gender and Age Group in India, 2015 165
6.5 Number of Aadhaar Registrations Completed by Top 10
Service Providers in India, May 2015 166
6.6 Financial Inclusion Applications of Aadhaar 166
6.7 Mobile Connect Beta Trial Indicators 173
Maps
O.1 Universal Financial Access 2020 Focus Countries 2
4.1 Distribution of Financial Institution Branches, Automated
Machines, and EFTPOS Terminals in Thailand, by
Region, 2013 87
5.1 Number of Live Mobile Money Services for the Unbanked,
by Country, 2014 128
6.1 Global Participation in Biometric ID Programs, by Region, 2012 157
Tables
O.1 Selection Criteria for Case Study Countries 6
O.2 Use of Transaction Accounts, Case Country Comparison, 2014 7
1.1 Estimated Financial Inclusion Gap, Globally and by Region, 2008 23
1.2 South Asia Remittance Receipts, by Country, 2009–13 31
2.1 Differences between Electronic Money and Virtual Currency
Schemes 41
4.1 Jan Dhan Yojana Account Status, by Bank Type, May 2015 71

x Contents
4.2 Financial Service Providers in Thailand, by Customer and

Transaction Type, 2013 90
4.3 Cash in Circulation in Maldives, 2007–14 95
5.1 Financial Inclusion in Sri Lanka Relative to South Asia and
Lower-Middle-Income Countries, 2014 108
5.2 Transaction Cost Comparison for eZ Cash and mCash 109
5.3 Roles and Responsibilities in M-Pesa Agent Structure 120
5.4 Detailed Roles and Responsibilities in M-Pesa Agent Structure 121
5.5 Timeline of M-Pesa Expansion of Functionality and Services,
2005–13 131
5.6 Banks and MFIs Linked to M-Pesa, 2013 133
5.7 Key M-Shwari Statistics 136
5.8 Payment Approaches of Selected Grant Programs as of 2012 143
5.9 Characteristics of the SASSA Card 148
6.1 Acceptable ID Documentation for Financial Services in the
Philippines 160
6.2 Key Differences between Aadhaar and the National
Population Register 170
7.1 Financial Inclusion Data by Region, 2014 180
7A.1 Digital Financial Landscape in South Asia: At a Glance 186
A.1 India against Benchmarks for South Asia and
Lower-Middle-Income Countries 211
A.2 Indonesia against Benchmarks for East Asia and Pacific and
A.3 Kenya against Benchmarks for Sub-Saharan Africa and
Low-Income Countries 214
A.4 The Philippines against Benchmarks for East Asia and
Pacific and Lower-Middle-Income Countries 215
A.5 South Africa against Benchmarks for Sub-Saharan
Africa and Upper-Middle-Income Countries 216
A.6 Sri Lanka against Benchmarks for South Asia and
A.7 Thailand against Benchmarks for East Asia and Pacific and
Upper-Middle-Income Countries 219

Foreword
Financial inclusion can almost be taken as a given in high-income countries, but

access to finance often remains sporadic and informal in low- and middle-income
countries. And yet, there is clear evidence that financial inclusion accelerates
economic growth and enhances opportunities, especially among the poor.
Communities thrive when households and local businesses gain access to finan-
cial services.
In recognition of these benefits, the World Bank and the International
Monetary Fund launched in 2015 the Universal Financial Access 2020 (UFA
2020) initiative. UFA2020 aims to enable 2 billion financially excluded adults to
gain access to transaction accounts. The initiative focuses on 25 countries where
73 percent of all the financially excluded people live.
Three South Asian countries—Bangladesh, India, and Pakistan—account
for 30 percent of the world’s financially excluded population and represent
40 percent of the UFA2020 target population. Thus, the South Asia region draws
particular attention when it comes to broadening access to finance.
India’s transformational efforts in implementing the Aadhaar financial inclu-
sion program and the unique identification program show that success is possible.
Thanks to new technologies, transformative business models, and ambitious
reforms, universal access to financial services has evolved from an aspirational
goal to a target within reach.
Improvements in the legal, regulatory, and institutional environments—which
tend to be useful for development in general—can have a favorable effect on
financial inclusion. Also, policy makers can promote financial inclusion by sup-
porting innovative business models that increase the outreach and lower the cost
of payment and financial services.
Bringing E-money to the Poor: Successes and Failures reviews the experiences of
countries that have demonstrated notable success in applying new technologies
and institutional innovation to provide the poor and vulnerable with entry points
into the financial system. Its case studies are based on extensive field research and
interviews with financial sector practitioners, users, policy makers, and regulators.
Detailed contextual analysis and an emphasis on critical conditions help identify
the drivers of success, as well as the challenges and risks.
Although new technologies and innovative methodologies in the finance
industry are numerous, the study focuses on e-money initiatives such as mobile
Bringing E-money to the Poor • http://dx.doi.org/10.1596/978-1-4648-0462-5 xi

xii Foreword
money, interoperable and multifunctional automated teller machines (ATMs),

and prepaid debit cards for social grant programs.
The four cases selected—Kenya, South Africa, Sri Lanka, and Thailand—illus-
trate the importance of leadership by the authorities, innovation by the private
sector, and a flexible “learn before regulating” approach. The result has been a
transformative expansion of financial access not only to the poor but also
throughout the economy, as these case studies show:
• In Kenya, the rate of financial inclusion more than doubled in five years to
reach nearly 70–75 percent of the adult population. Innovation took the form
of a mobile money application (M-Pesa) by the country’s leading mobile phone
operator. A cooperative and enabling relationship between the regulator and
the operator helped M-Pesa become the country’s retail payment platform.
• In South Africa, the key innovation was the use of a biometrically secure,
“chipped” open-debit MasterCard as the platform for social transfer payments.
Financial access was extended to 10 million of the country’s poor, pushing
financial inclusion up to 86 percent of the population. The essential element
of success was the cooperation between the Social Security Agency, the private
creator of the biometrically enabled card, and a local bank.
• In Sri Lanka, a proactive development of the legislative framework enabled

the establishment of an excellent payment systems infrastructure. Sri Lanka
arguably has the best regulatory framework in the South Asia region to govern
e-money for e-commerce and e-government, as well as the world’s first end-
to-end interoperable payment solution. A range of private sector players and
mobile operators jumped in, and financial inclusion is already reaching over
83 percent of the population.
• In Thailand, 88 percent financial inclusion of households has been achieved

through efficient coordination of strategies and policies toward payment ser-
vices and reduction of infrastructure costs. Thousands of multicapacity ATMs
and automated deposit machines (ADMs) were deployed throughout the
country as a result. The leadership of the Thai Bankers’ Association was a key
element of this success.
We hope that these rich case studies stimulate debate and encourage policy
makers, regulators, financial service providers, and mobile network operators to
move forward on access to finance, especially for the poor. Their initiative, enthu-
siasm, and cooperation are needed to make universal financial inclusion a reality
in South Asia.
Martin Rama
Chief Economist, South Asia Region
The World Bank

Acknowledgments
This study was written by Thyra A. Riley (now retired) in her role as sector coor-
dinator and lead specialist, and by Anoma Kulathunga, senior financial sector
specialist––both of the World Bank’s Finance and Markets Global Practice,
South Asia region.
The authors are especially grateful to Martin Rama, chief economist of the
South Asia region, who provided invaluable support and guidance as the chair-
man of the peer-review process by which this program of study was undertaken
and published. The authors also thank Henry Bagazonzya and Niraj Verma, prac-
tice managers of the South Asia region’s Finance and Markets Global Practice,
under whose supportive auspices this product was brought to final fruition.
The authors express special appreciation for the ex officio moral support and
intellectual contributions of Christopher Dooley (senior adviser, United Nations
Capital Development Fund); Ranee Jayamaha (former deputy governor of the
Central Bank of Sri Lanka); William F. Steel (adjunct professor, University
of Ghana, Legon, and former World Bank senior adviser on microfinance and
small enterprise); and Martin Melecky (lead economist, Office of the Chief
Economist, South Asia region).
Valuable feedback and comments were provided by World Bank peer reviewers:
Simon Bell, global lead, SME Finance, Finance and Markets Global Practice;
Martin Kanz, economist, Development Economics Chief Economist’s Office;
Harish Natarajan, lead financial sector specialist, Payment Systems Development
Group, Finance and Markets Global Practice; Douglas Pearce, practice manager,
Financial Infrastructure and Access, Finance and Markets Global Practice; and
Maja Andjelkovic, senior financial sector specialist on behalf of the Innovation and
Entrepreneurship Team of the Trade and Competitiveness Global Practice.
Country e-money landscapes were prepared by World Bank or International
Finance Corporation Country Office colleagues: Sabin Shrestha, senior financial
sector specialist; Nazir Ahmad III, private sector specialist (Afghanistan); and
Santosh Pandey, senior financial sector specialist (Nepal); as well as by country-
based financial consultants: Muhymin Chowdhury (Bangladesh); Ranee Jayamaha
(Maldives); Caroline Pulver (Kenya); and K. R. Ramamoorthy (India).
Bringing E-money to the Poor • http://dx.doi.org/10.1596/978-1-4648-0462-5 xiii

xiv Acknowledgments
The authors are deeply indebted to the World Bank publications team: Jewel
McFadden, acquisitions editor; Paola Scalabrin, acquisitions editor; Stephen
Pazdan, publishing associate; Mary A. Anderson, our copy editor; and Gwenda
Larsen, our proofreader.
Last, and most important, the authors recognize the invaluable contributions
and vision of the business leaders, central bank regulators, and international
donors that incorporate e-money as a delivery mechanism to provide access to
financial services to the poor. The cases and frameworks discussed in this study
are built on the authors’ in-country fieldwork and interviews with these leaders,
their staff, their clients, and the users of e-money. The generous access provided
has made the richness of this study possible—with our very sincerest thanks!

About the Authors
Thyra A. Riley, now retired, was sector coordinator and lead specialist of the World
Bank’s Finance and Markets Global Practice, South Asia region. Over a 30-year
career at the World Bank, she served in several corporate management, knowledge
management, and lead financial sector specialist positions in several regions of the
world, including Africa, Latin America and the Caribbean, and Middle East and
North Africa. As the knowledge manager for the Micro, Small Enterprise, and
Rural Finance Thematic Group, she led knowledge-sharing engagements that
brought together leading international microfinance practitioners with African
country leaders, policy makers, and donors interested in learning from the best-
practitioners themselves. Riley also led several projects and knowledge-sharing
engagements with the South African government during the postapartheid devel-
opment of the country’s policy framework for micro and small enterprises. She has
written extensively about lessons learned from high-impact development inter-
ventions, focusing on approaches that have mainstreamed access by the poor to
financial services through innovative means including traditional microfinance and
digitally enabled financial services. She was a visiting fellow in finance at the Sloan
School of Management, Massachusetts Institute of Technology. Riley holds a bach-
elor’s degree in development economics from Stanford University and a master’s
degree in public and international affairs from Princeton University.
Anoma Kulathunga is a senior financial sector specialist in the World Bank’s

Finance and Markets Global Practice, South Asia region. During her 12 years at the
World Bank, she brought her financial sector expertise to numerous projects, includ-
ing country experience spanning all South Asian countries, the Middle East and
North Africa, Indonesia, Uganda, and Vietnam. Before joining the World Bank, she
served for 11 years as regulator at the Central Bank of Sri Lanka and has also been
an assistant professor of finance at The George Washington University, Washington,
DC. An associate member of the Chartered Institute of Management Accountants,
UK, she has coauthored five books and published many papers on issues related to
financial stability and soundness. Her research interests include financial sector
development and stability, financial infrastructure, Islamic banking, worker remit-
tances, and international banking. Kulathunga holds an MBA from the University of
Sri Jayewardenepura, Sri Lanka, and master’s and doctoral degrees in international
finance and development economics from The George Washington University.
Bringing E-money to the Poor • http://dx.doi.org/10.1596/978-1-4648-0462-5 xv

Abbreviations
ACH automated clearinghouse

ADM automated deposit machine
AEPS Aadhaar Enabled Payment System
AML/CFT
Anti-Money Laundering and Combatting Funding of Terrorism
ANM agent network manager
API application programming interface
ASEAN Association of Southeast Asian Nations
ATM automated teller machine
BC business correspondent
BDO Banco De Oro (Philippines)
BFP Bolsa Família Program (Brazil)
BI Bank of Indonesia
BIS/CPMI
Bank for International Settlements Committee on Payments and
Market Infrastructures
BML Bank of Maldives
BOT Bank of Thailand
BSP Central Bank of the Philippines (Bangko Sentral ng Pilipinas)
B2P business-to-person
CBA Commercial Bank of Africa
CBK Central Bank of Kenya
CBSL Central Bank of Sri Lanka
CCAPS Common Card and Payment Switch
CDD customer due diligence
CDM cash deposit machine
CDMA Code Division Multiple Access
CEB Ceylon Electricity Board
CGAP Consultative Group to Assist the Poor
CI/CO cash-in/cash-out
CITSG Core Information Technology Support Group (Philippines)
Bringing E-money to the Poor • http://dx.doi.org/10.1596/978-1-4648-0462-5 xvii

xviii Abbreviations
CNIC Computerized National Identity Card

COSO Committee of Sponsoring Organizations of the Treadway
Commission
CPMI Committee on Payments and Market Infrastructures (of the
Bank for International Settlements)
CPS Cash Paymaster Services
CSIRT Computer Security Incident Response Team
CSP certification service provider
DBT direct benefits transfer
DFID Department for International Development (United Kingdom)
DFS digital financial service
EFT electronic funds transfer
EFTPOS electronic funds transfer at point of sale
EMI e-money issuer
EMV Europay, MasterCard, and Visa
FATF Financial Action Task Force
FDI foreign direct investment
FMI financial market infrastructure
FMIS financial management information system
FSD Financial Sector Deepening
GCC Gulf Cooperation Council
GDP gross domestic product
GNI gross national income
GSM Global System for Mobiles
GSMA Groupe Speciale Mobile Association
G2C government-to-consumer
G2P government-to-person
G20 Group of Twenty (countries)
IBFT Inter Bank Fund Transfer
ICT information and communication technology
ICTA Information and Communication Technology Agency (Sri Lanka)
ID identification
IFC International Finance Corporation (of the World Bank Group)
IMF International Monetary Fund
IMPS Immediate Payment Service (India)
IOM International Organization for Migration
IT information technology
ITMX Interbank Transaction Management and Exchange (Thailand)
JDY Jan Dhan Yojana (India)

Abbreviations xix
KCB Kenya Commercial Bank

KYC know your customer
LECO Lanka Electricity Company
LPG liquefied petroleum gas
M-Pesa Kenya’s mobile money platform
M-POS mobile point of sale
MFI microfinance institution
MGNREGA
Mahatma Gandhi National Rural Employment Guarantee Act
MMA Maldives Monetary Authority
MMU Mobile Money for the Unbanked
MNO mobile network operator
MoRD Ministry of Rural Development (India)
MOU memorandum of understanding
MPS mobile payment system
MUDRA Micro Units Development and Refinance Agency (India)
NADRA National Database and Registration Authority (Pakistan)
NBFC nonbanking finance company
NDB National Development Bank (Sri Lanka)
NFC near-field communication
NIC national identity card
NPC national payment council
NPCI National Payments Corporation of India
NPR National Population Register (India)
NSSLA nonstock savings and loan association
NSSO National Sample Survey Office (India)
NUUP National Unified USSD Platform (India)
NWSDB National Water Supply and Drainage Board (Sri Lanka)
ODA official development assistance
OECD Organisation for Economic Co-operation and Development
OTC over-the-counter
PIN personal identification number
POS point of sale
PPP purchasing power parity
PSSA Payment and Settlement Systems Act (Sri Lanka)
P2B person-to-business
P2G person-to-government
P2P person-to-person
PUM passbook update machine
RBI Reserve Bank of India

xx Abbreviations
ROSCA rotating savings and credit association

RTGS real-time gross settlement
SAARC South Asian Association for Regional Cooperation
SACCO savings and credit cooperative
SASSA South African Social Security Agency
SFI specialized financial institution
SIM subscriber identification module
SME small and medium enterprise
SMS short message service
TBA Thai Bankers’ Association
TRAI Telecom Regulatory Authority of India
TRCSL Telecommunications Regulatory Commission of Sri Lanka
UEPS Universal Electronic Payment System
UFA2020 Universal Financial Access 2020
UID unique ID
UIDAI Unique Identification Authority of India
UMID unified multipurpose ID
UNHCR United Nations High Commissioner for Refugees
USSD unstructured supplementary service data
Currencies
Currency conversions that appear in the text were current as of the time of writing
(in 2015).
B Thai baht
K Sh Kenya shilling
R$ Brazilian real
R South African rand
Rf Maldivian rufiyaa
Rs Indian rupees
SL Rs Sri Lanka rupees
T Sh Tanzania shilling

Overview
I’m confident digital tools will allow us to ignite significant progress, opening a broader
path to the goal of universal access to basic accounts by 2020. But access is just an
interim step. The full benefit of financial inclusion depends on households and small
businesses actively using a range of affordable and effective financial services, coupled
with financial education and consumer protection. That is a much taller order.
—Queen Máxima of the Netherlands, United Nations Secretary-General’s
Special Advocate for Inclusive Finance for Development, UNSGSA Annual
Report 2015
Background
Financial sector development can aid economic growth and create private and
social benefits, especially in countries at lower levels of development (Cull,
Ehrbeck, and Holle 2014; Sahay et al. 2015). An important aspect of financial
development to address the shared prosperity objective is the extension of
financial intermediation services to low-income brackets of the population.
Access to financial and payment services, including savings, credit, and social
welfare transfers, facilitates better financial inclusion and enables improved
income distribution and inclusive growth. Although financial inclusion is mostly
a foregone conclusion in the developed world, in developing countries it often
remains sporadic or at best informal for those at the base of the pyramid.1
Limited financial inclusion severely impacts financial stability, financial security,
and poor people’s economic mobility, thus effectively impeding the achievement
of shared prosperity and development. The Global Financial Development Report
2014 suggests that public policy can achieve potentially large effects on financial
inclusion through reforms (World Bank 2014). The evidence provided from
the World Bank’s Doing Business data (World Bank 2017) and Enterprise
Surveys2 indicates that improvements in the legal, regulatory, and institutional
environments—which tend to be useful for development in general—can also
have a favorable effect on financial inclusion.
The Universal Financial Access 2020 (UFA2020) goal to enable 2 billion
financially excluded adults to gain access to a transaction account—an initia-
tive established during the 2015 World Bank and International Monetary
Fund (IMF) Spring Meetings—focuses on 25 countries where 73 percent of
all financially excluded people live (map O.1).3 The largest shares of unbanked
Bringing E-money to the Poor • http://dx.doi.org/10.1596/978-1-4648-0462-5 1

2 Overview
Map O.1 Universal Financial Access 2020 Focus Countries
Achieving Universal Financial Access by 2020

Two billion people lack access to a transaction account.
Here is the percentage in each focus country: China Philippines 2.2%
11.6% Ethiopia 2.1%
Pakistan Myanmar 1.5%
Mexico 5.2%
Egypt, Congo, Dem. Rep. 1.5%
2.6% Vietnam
Arab Rep. Turkey 1.2%
2.4%
2.4%
Colombia 1.1%
Nigeria India Tanzania 0.8%
2.7% 20.6% Bangladesh Peru 0.8%
3.7%
Percentage access to Morocco 0.7%
Indonesia
financial services Brazil South Africa 0.5%
5.6%
2.4%
0–25% Côte d'Ivoire 0.4%
26–50% Mozambique 0.4%

China + India Kenya 0.3%
51–100% = 32%
Zambia 0.2%
Rwanda 0.2%
25 73%
of the world’s financially excluded.
focus
countries =
Source: World Bank, from 2014 Global Findex and International Monetary Fund (IMF) Financial Access Survey data. © World Bank. http://www
.worldbank.org/en/topic/financialinclusion/brief/achieving-universal-financial-access-by-2020. Permission required for reuse.
people are in India (which accounts for about 21 percent of the world’s finan-
cially excluded working-age population) and China (with about 12 percent).
The other top-priority countries include Bangladesh and Pakistan, with about
4 percent and 5 percent, respectively, of the world’s financially excluded
population. Thus, three South Asian countries that account for 30 percent of
the world’s financially excluded people represent 40 percent of the UFA2020
target population.
South Asia plays a key role in the global development arena, with the
world’s largest working-age population, a quarter of the world’s middle-class
consumers, the world’s greatest number of poor and undernourished people,
and several fragile states of global geopolitical importance. Led by India,
strong inclusive growth in South Asia could potentially change the face of
global poverty. Although the modern microfinance industry—which emerged
in South Asia in the 1970s with organizations such as Grameen Bank of
Bangladesh—has contributed meaningfully to expanding outreach and access
in the region, data show that the number of people with access to formal
financial services falls short of the potential that we associate with the
impressive levels of financial access and inclusive growth in the emerging
markets of East Asia.

Overview 3
Demirgüç-Kunt, Beck, and Honohan (2008) show evidence that financial

development and improved access to finance are likely not only to accelerate
economic growth but also to reduce income inequality and poverty, and they
describe how poor communities thrive economically when provided with access
to financial services.
However, having more than 40 percent of the world’s financially excluded
people, it is clear that in South Asia traditional banking has failed to adequately
reach the poor and the financially vulnerable. On the other hand, technological
innovations have responded to changing consumer behavior and tightened bank
regulations by offering alternative means to achieve inclusive finance, with some
clear success stories.
This study is based on case studies—developed through in-depth field visits
and desk research—that analyze the implementation of specific e-money and
other digital payment programs. The primary criterion for selection was the avail-
ability of relevant data to serve as evidence in analyzing the country’s experience.
Countries were then selected that had demonstrated successful outcomes where
critical enablers of success could be identified. In addition, countries were
included that showed early promise but where critical constraints could be iden-
tified that stalled progress.
Motivation and Evidence

This study aims to identify countries that have demonstrated notable success in
applying new e-money technologies and innovative thinking in providing first
entry points into the financial system for poor and vulnerable population seg-
ments. Case studies are used to emphasize detailed contextual analysis of certain
critical conditions and their relationships to the success or failure of these inter-
ventions. Although new technologies and innovative methodologies in the
finance industry are numerous, the study narrowly focuses on e-money initiatives
such as mobile money, interoperable and multifunctional automated teller
machines (ATMs), and prepaid debit cards for social grant programs as the first
entry points to financial inclusion.
The focus is on analyzing the provision of cost-effective, reliable, and safe access
to basic cash-in/cash-out, utility, and bill payment services to financially unserved
or underserved people through the selected e-money interventions. Although the
study examines cases where financial intermediation activities such as credit, savings,
insurance, and other financial products are developed through the e-money plat-
forms, it does not cover the entire spectrum of financial inclusion at these entry points.
The observed outcomes from four of the selected successful country case
studies—Kenya, South Africa, Sri Lanka, and Thailand—show that the private
sector and nonbank entities have been supported or, in some cases, been led by
flexibly designed policies and regulations, as in the following cases:
• In Kenya, the rate of financial inclusion more than doubled in five years
to reach nearly 70–75 percent (depending on methodology) of the adult

4 Overview
population as a direct result of innovations associated with a mobile money

application (M-Pesa) that has evolved into the country’s retail payment plat-
form (FSD Kenya and CBK 2013).4 While also used ubiquitously by the
banked and well-to-do, M-Pesa has especially benefited the poor and unbanked
who previously had limited and costly access to traditional bank and financial
infrastructure.
• In South Africa, the use of a biometrically secure, “chipped” open-debit
MasterCard as the platform for social transfer (government-to-persons [G2P])
payments extends financial access to 10 million of the country’s poor.5 This is
the main contributing factor to the growth in the country’s banked population
from 63 percent in 2011 to 75 percent in 2014, with financial inclusion
(adding those who use nonbank accounts for financial transactions) reaching
86 percent (FinMark Trust 2014).
• In Sri Lanka, the government and the Central Bank of Sri Lanka have pro
actively developed the country’s legislative framework, enabling the establish-
ment of an excellent payment systems infrastructure and possibly the best
regulatory framework in the region to govern e-money for e-commerce and
e-government. This policy approach has facilitated the launch of the world’s
first end-to-end interoperable mobile payment solution as another means of
enhancing financial inclusion that is already reaching over 83 percent of the
population.6
• In Thailand, 88 percent financial inclusion of households has been achieved
through efficient coordination of strategies and policies toward payment ser-
vices and reduction of infrastructure costs, partly through the deployment of
thousands of multicapacity ATMs and automated deposit machines (ADMs)
throughout the country (BOT 2014).7
This study also draws lessons from experiences in several other countries:
India, Indonesia, Maldives, and the Philippines. Some of these countries have
taken important initial steps to create the potential for rapid expansion of finan-
cial inclusion, while others have encountered obstacles that have limited their
success.
In most instances, reform packages are country-specific. For this reason,
there is considerable uncertainty as to which countries or initiatives reflect
best practice. Nevertheless, pursuing cross-country studies of successful prac-
tices or policy initiatives, along with international dialogue, can flatten the
learning curve and speed up policy learning by highlighting common traits,
implementation issues, and operational successes. Furthermore, to effectively
counter underlying barriers to financial access for underserved groups, even
within a single country, it appears to be important to follow an integrated
approach that considers the entire ecosystem at different stakeholder levels,
as explained in chapter 3.
This study also aims to identify new approaches to improving financial
inclusion in South Asia. It documents innovative uses of technology in the
form of digital financial services operating within a balanced regulatory

Overview 5
environment that can be key to improving financial inclusion. When an

economy is cash-based, access to financial services is often restricted and
costly. When countries move increasingly away from cash to a “cash-lite”
economy—one in which “cash is no longer the most common means of pay-
ment” (BFA 2015)—broader financial inclusion can take place at a faster pace
and lower cost. This is because a digital solution can often be more easily
deployed to successfully address inclusion barriers and provide benefits in
terms of proximity, safety, reliability, cost, and simplicity. These are hugely
important concepts, especially for poor people. Technology or regulatory bal-
ance alone will not make an initiative successful unless it accrues one or more
of these benefits to the users.
It is important to understand that although these initiatives represent
exciting use of digital means in providing entry points to formal financial
systems, they are but the first steps toward embarking on a journey toward a
cash-lite economy. It is not an easy feat to develop inclusive digital financial
systems and have a meaningful distribution effect among poor people, let
alone reach the cash-lite or cashless stages that the developed countries have
achieved. Although the viability of adopting digital solutions varies from
market to market, these initiatives present a powerful opportunity to draw
lessons to advance financial inclusion through efficient, affordable digital
means.
Target Audience
The target audience for this study comprises national regulators, policy makers,
and market practitioners of digital financial services, primarily in the South Asia
region. Given the growing interest in e-money and digital payment solutions—and
in light of ongoing initiatives in most South Asian countries—developing a
knowledge-sharing platform both in the form of this volume and in a seminar
would allow for an interactive knowledge exchange between practitioners from
the case-study countries and their South Asian counterparts. The case study
analysis, combined with descriptions of South Asian country financial and
e-money landscapes, provides an excellent base for more-comprehensive diag-
nostic studies in the future on the digital financial potential of South Asian
countries. Researchers, experts, and private sector service providers should also
find the study informative.
Methodology: Country Selection and Financial Inclusion Status

Hawkins (1980) described an outlier as an observation that “deviates so much
from other observations as to arouse suspicions that it was generated by a differ-
ent mechanism.” The selection of countries for the case studies was first triggered
by the observance in the data of obvious outliers, as found in the Findex data,8
combined with field visits and readings that confirmed that the chosen countries
have indeed acted in different and innovative ways to achieve higher levels of

6 Overview
Table O.1 Selection Criteria for Case Study Countries

Critical constraint
Case study Evidence-based Demonstrated Critical enabler of on progress
country data successful outcomes success identified identified
Countries with documented success or constraints
Kenya X X X
Maldives X X
Philippines X X
South Africa X X X
Sri Lanka X X X
Thailand X X X
Additional countries with promising early efforts

India X X
Indonesia X X
basic financial access for their poor populations by consciously developing the
financial and payment ecosystem using digital means.
This selection process yielded six suitable countries (table O.1): four fast mov-
ers (Kenya, South Africa, Sri Lanka, and Thailand) that have successfully pursued
e-money initiatives that have also yielded transformational levels of financial
inclusion, including use of e-money by the poorest;9 and two early movers
(Maldives and the Philippines) where the momentum implementing e-money
has stalled or failed to reach its full potential but remains promising. In addition,
the study reviews the possible game-changing initiatives undertaken by a South
Asian country and a Southeast Asian country where critical enablers could be
identified but the outcomes cannot yet be documented: specifically, India’s
establishment of a unique identification system and Indonesia’s steps to achieve
interoperability among providers to help overcome geographic challenges to
outreach.
These case studies offer in-depth analysis of the elements of some innovative
e-money initiatives that have influenced project outcomes and digital financial
landscapes in terms of expansion of financial access and inclusion. The analysis
focuses on stakeholders at all levels, highlighting common critical elements or
“game changers” that fast movers have implemented, but which the early movers
overlooked, preventing them from reaching their full potential.
Summary of Findex Data

The 2014 Global Findex Survey data on each of these countries (see appen-
dix A) are used in the ex post outcome analysis. Table O.2 provides a com-
parative summary of country data on transactions (both inflow and outflow)
that measure the use of, and hence the demand for, such accounts. These
data points indicate the relationship between digital services and extension of
payment services to underserved or poor populations and, also, shed light on
the readiness of such countries and population segments to use digital
technologies.

Overview 7
Table O.2 Use of Transaction Accounts, Case Country Comparison, 2014

Percentage of respondents ages 15 years and older
South Sri World
Survey question India Kenya Philippines Africa Lanka Thailand average
Paid school fees
In the past year 22.4 51.3 40.5 26.6 29.8 26.4 —
In the past year, rural 20.5 52.8 41.1 23.7 28.3 23.2 —
In the past year, income, poorest 40% 21.7 50.6 44.8 21.7 31.6 25.7 —
Using cash 99.2 60.9 94.5 79.6 99.0 93.2 —
Using an account at a financial institution 6.2 44.0 2.9 39.7 0.2 8.7 —
Using a mobile phone 0.9 21.0 0.0 11.1 0.0 0.9 —
Paid utility bills

In the past year 39.4 33.6 55.2 37.0 62.9 86.2 60.4
In the past year, rural 34.8 31.0 56.2 33.9 62.9 89.6 57.6
In the past year, income, poorest 40% 29.3 13.7 43.5 31.4 67.0 88.6 56.7
Using cash 99.7 76.3 98.1 87.1 98.8 98.5 78.6
Using an account at a financial institution 8.7 17.1 1.9 32.9 1.8 2.0 27.7
Using a mobile phone 0.5 55.2 0.6 7.9 0.1 0.9 3.4
Received government transfers

In the past year 9.8 11.8 17.3 34.2 10.1 22.6 13.4
In cash — 14.3 63.2 29.2 49.0 66.6 36.5
Into an account at a financial institution — 51.7 23.0 82.0 52.5 39.6 60.7
Through a mobile phone — 6.5 1.0 6.9 0.0 0.4 1.3
Received payments for agricultural

products
In the past year 20.9 53.7 22.1 10.7 20.3 36.8 —
In the past year, rural 22.3 56.8 31.5 14.2 22.6 41.7 —
In the past year, income, poorest 40% 28.0 55.3 25.3 11.2 24.3 42.6 —
In cash 84.5 94.1 95.4 76.0 97.4 98.9 —
Into an account at a financial institution 11.8 12.5 1.7 35.6 5.6 8.8 —
Through a mobile phone 2.3 30.4 0.2 11.6 0.0 0.7 —
Received wages
In the past year 19.2 27.5 35.1 33.2 22.3 24.7 32.4
In cash 86.2 56.9 82.0 37.9 69.7 74.0 50.1
Into an account at a financial institution 20.1 48.7 18.0 79.1 32.1 33.6 54.3
Through a mobile phone 1.5 25.5 0.0 11.7 0.0 0.4 1.2
Source: 2014 Global Findex Survey data, http://datatopics.worldbank.org/financialinclusion/.
Note: — = not available. Not all questions were asked in all countries. The 2014 Global Findex Survey did not calculate global averages
for these indicators.
Although promising outcomes are observed in each of the cases, the heavy
presence of cash as the dominant choice of payments highlights the persistent
challenges at the entry level of getting people to fully embrace e-money as
the pathway to a fuller array of financial services including savings, credit, and
insurance.

8 Overview
Highlights of Country-Specific Comparative Data

Kenya’s Findex data show the dominance of mobile-phone–based accounts
and increased financial access driven by M-Pesa (appendix A, table A.3).
The share of adults with a transaction account is high at nearly 75 percent,10
and the shares of women and the poorest 40 percent who hold accounts are
around 71 percent and 63 percent, respectively. The share of the adult popu-
lation with mobile accounts is 58 percent. These proportions are substan-
tially higher than the averages for Sub-Saharan Africa (11.5 percent), for
low-income countries (10 percent), and even for the world (2 percent).
The shares of remittances received and sent by mobile phone (89 percent
and 92 percent, respectively) are comparatively higher than Sub-Saharan
African averages (28 percent and 31 percent, respectively). The receipt and
payment numbers confirm that, in Kenya, people prefer mobile money as a
transaction method, while the use of cash still remains high. Government
payments favor financial institutions, indicating scope for further expansion
of mobile services.
Findex data for South Africa clearly highlight the use of card payments and
the link of government grants to debit cards, with debit card ownership of
around 55 percent (appendix A, table A.5). Use of debit cards is also high:
41 percent of adults use them for payments, substantially higher than world
and upper-middle-income country averages (23 percent and 20 percent,
respectively). The shares of South Africans who send and receive remittances
using money transfer operators are also high (57 percent and 61 percent,
respectively). Government grants are channeled through financial institutions
on bank-based debit cards. Wage payments go through financial institutions at
a higher rate (27 percent) than in upper-middle-income countries and the
world average (18 percent). Mobile money accounts are possessed by only
14 percent of South Africa’s population, and cash still dominates payment
transactions. Thus conditions are favorable for e-money to facilitate greater use
of a wider range of financial services.
Sri Lanka’s financial inclusion indicators are impressively high across all
segments of the population (appendix A, table A.6). Even among the poorest
40 percent, 80 percent are included—far ahead of the South Asia,
lower-middle-income country, and world averages (38 percent, 33 percent, and
54 percent, respectively). Although Sri Lanka has launched an innovative,
interoperable mobile money solution, neither the inclusion numbers nor trans-
action volumes are driven by mobile money: only 0.1 percent of all adults have
a mobile account. Financial institutions have provided accessibility to all segments
of the population; hence mobile money is simply another option. Another fac-
tor is that mobile money was launched only recently (in 2012). In Sri Lanka,
too, it is apparent that cash still plays a significant role and thus provides an
opportunity for digital payments to expand.
Thailand also scores high on inclusion for all segments of the population:
78 percent of all adults, 75 percent of women, and 72 percent of the poorest
40 percent (appendix A, table A.7).11 ATM transactions are especially high: more

Overview 9
than 62 percent of adults identify ATMs as their main mode of withdrawal, com-
pared with the upper-middle-income country average of 56 percent. Nevertheless,
people use ATMs mainly for cash withdrawal, even though banks have enabled
these customized ATMs to also handle utility, travel, and person-to-person pay-
ments at relatively low cost. Although mobile money is available in Thailand, it
is not used to a significant degree: only 1.3 percent of all adults have a mobile
account. Debit card ownership is fairly high, at 55 percent, but debit card use
(8 percent) is lower than the East Asia and Pacific, upper-middle-income country,
and world averages (15 percent, 20 percent, and 23 percent, respectively).
In India, cash dominates all types of transactions, and financial inclusion
numbers are comparatively low (appendix A, table A.1). However, the impact of
the recent digital financial inclusion drive in India (described in Part II of this
volume, chapters 4 and 6) is evident when the 2011 and 2014 numbers are com-
pared: adults with accounts increased from 35 percent in 2011 to 53 percent by
2014. This impressive growth bodes well for achievement of the goals for
UFA2020. However, the transaction comparison shows cash dominance in all
areas, representing a challenge for the government and financial institutions alike.
The share of adults with mobile accounts is 2.4 percent, comparing favorably to
regional and world averages (2.6 percent and 2 percent, respectively), although
transactions using mobile money are negligible (except for receipts of payments
for agriculture products). Encouraging people to move away from cash would be
a priority for India.
The Philippines is included as a case study because mobile money initiatives
originated in the Philippines in 2001, long before Kenya’s M-Pesa mobile money
platform started in 2007. Given the constraints on brick-and-mortar financial
institutions due to the archipelagic nature of the country, one would have
expected mobile money to flourish. However, only 4 percent of adults have
mobile money accounts (appendix A, table A.4). While this rate is higher than
the regional and lower-middle-income country averages (0.4 percent and
2.5 percent, respectively), it compares poorly with the 28 percent of adults who have
bank accounts. The Philippines’ total rate of financial inclusion—31 percent—is
less than half the strong rate of financial inclusion in East Asia and the Pacific,
where adult inclusion averages 69 percent. Remittance numbers are higher
(34 percent receiving and 21 percent sending), but these are undertaken mainly
through money transfer operators (mostly pawnshops). All transaction types
reveal cash dominance. The discussion of the Philippines case study in Part II of
this volume (chapters 4 and 6) will highlight the reasons why mobile money
failed to gain traction.
The case of Indonesia, as noted earlier, represents achievement of interop-
erability to help overcome geographic challenges to inclusion. On most finan-
cial indicators, Indonesia remains below average in the region despite
substantial progress between 2011 and 2014 (appendix A, table A.2).
The share of adults with an account at a financial institution rose from
20 percent in 2011 to 36 percent in 2014, still below the averages of 42 percent
for lower-middle-income countries and 69 percent for East Asia and the Pacific.

10 Overview
Saving at a financial institution likewise rose from 15 percent to 27 percent,

and the share of respondents with a debit card rose even more sharply from
11 percent to 26 percent—comparable to lower-middle-income countries,
although below the regional average. Digital transactions and use of mobile
phones and money for remittances also are below average, although
Indonesians make relatively high use of ATMs, which are the main mode of
withdrawal for 71 percent of those with an account.
Maldives is not covered by Findex data. However, previous World Bank
engagements show that the country’s archipelagic nature makes it difficult to
provide financial access to the 340,000-plus people living among more than
200 islands. Over half of the population is in the outer islands, and those living
on atolls have great difficulties accessing banking and payment services.
Although banking services are woefully inadequate, a World Bank–funded
mobile-phone banking project closed without being able to successfully deploy
the much-needed mobile solution. The World Bank and the local Maldives
authorities are trying to address this issue through a different payment solution.
The case study (in chapter 4) highlights important lessons learned from the
past difficulties and problems encountered and the nonbank-based approach
being undertaken.
Organization of This Volume

Following this “Overview” chapter, Part I of the volume provides the framework
for studying the journey toward a cash-lite society and financial inclusion, as
follows:
• Chapter 1, “The Challenge of Financial Inclusion,” introduces the topic of finan-

cial inclusion, discusses its importance, and presents definitions.
• Chapter 2, “Digitizing Financial Inclusion through Innovations,” explains how
digitizing money, payments, and other financial transactions can facilitate
inclusion of the unbanked and financially underserved population. It also
addresses the risks of digital finance, including
• Political economy risks that stem from vested interests that resist the intro-
duction of disruptive technologies;
• Security risks and risks to the payments system, which may not function effec-
tively if the service providers do not adequately understand the digital cus-
tomer base or the infrastructure requirements;
• Principal-agent risks that must be addressed to minimize loss of revenue,
fines and other reprimands by the regulators, fraudulent activities and cor-
ruption, and loss of reputation; and
• Risks to customers from inadequate information and understanding of
e-money, lack of consumer protection and adequate redress mechanisms,
identity theft, and liquidity-related issues, among others—all of which may
account in part for the trust gap that impedes increased and broader use of

Overview 11
digital finance and the achievement of higher levels of financial inclusion

beyond entry-level transactional and payment services.
• Chapter 3, “Stakeholders in Digital Financial Inclusion,” sets forth the key stake-
holders in the process of applying digital innovations to achieve greater finan-
cial inclusion.
Part II presents the empirical evidence on critical enablers that are game
changers in successful e-money deployments, as follows:
• Chapter 4, “Policy Leadership and Enabling Regulatory Environments,” focuses

on the macro environment, including leadership in policy and regulatory
reforms that are both successful and less successful in achieving results in
terms of financial inclusion.
• Chapter 5, “Innovative Uses of Infrastructure and Digital Ecosystems,”
examines measures at the meso level (the institutional framework) to
establish enabling infrastructure, institutions, and social grant payment
systems that are essential alternative payment system platforms designed
to drive demand and use by the poor and unbanked. In chapter 5, particu-
lar attention is paid to the micro-level private service providers and how
they have responded and rapidly built up agent networks. Kenya’s unusu-
ally rich set of mobile money applications and private development of the
digital ecosystem have allowed nonbank provision of payment services to
include the poor in an array of credit, savings, insurance, and other finan-
cial products.
• Chapter 6, “Unique Identification,” looks at different experiences with national
identification (ID) systems, because a unique national ID is found to be a criti-
cal condition to link e-money platforms and other digital solutions to bank
accounts in order to transform financial inclusion of the poor, rural, and
unbanked.
Part III draws on the lessons of experience to distill guiding principles for suc-
cess and measures that would help avoid deficiencies that have constrained the
pace of scaling-up in several South Asian countries, as follows:
• Chapter 7, “Digital Landscape in South Asia,” summarizes the e-money land-

scape across countries in the South Asia region. Although such an overview
cannot replace in-depth diagnostic assessment of how best to digitize the
delivery of financial services in each country, it provides a basis for the discus-
sion in chapter 8.
• Chapter 8, “Opportunities, Challenges, and Future Options in South Asia,” sug-
gests key options that could be applied in South Asian countries.
• Chapter 9, “Conclusions,” reviews the conclusions regarding the critical enablers
and game-changing measures for digital applications to help transform finan-
cial inclusion in developing countries more generally.

12 Overview
Notes
1. Throughout this volume, “developing countries” refers to low- and middle-income
economies as defined in the World Bank’s Income Classifications, based on estimates
of gross national income (GNI) per capita, calculated using the World Bank Atlas
method. As of July 1, 2016, low-income economies are those with 2015 GNI per
capita of US$1,025 or less. Middle-income economies are those with 2015 GNI per
capita of US$1,026 to US$12,475 (“upper-middle-income” economies having 2015
GNI per capita of US$4,036 to US$12,475). “Developed countries” refers to
high-income economies, which are those with 2015 GNI per capita of US$12,476 or
more. Classification by income does not necessarily reflect development status.
For more information, see https://datahelpdesk.worldbank.org/knowledgebase
/articles/906519-world-bank-country-and-lending-groups.
2. Enterprise Surveys refer to firm-level surveys of a representative sample of an econo-
my’s private sector. The surveys cover a broad range of business environment topics
including access to finance, corruption, infrastructure, crime, competition, and perfor-
mance measures. Since 2002, the World Bank has collected these data from face-to-
face interviews with top managers and business owners in over 155,000 companies in
148 economies. For more information about the Enterprise Surveys, see http://www
.enterprisesurveys.org/.
3. For more about the UFA2020 initiative, see the overview brief on the World Bank
website: http://www.worldbank.org/en/topic/financialinclusion/brief/achieving
-universal-financial-access-by-2020.
4. Data also from Global Findex 2014 Survey, http://datatopics.worldbank.org
/financialinclusion/. The name of “M-Pesa,” Kenya’s mobile-phone–based branchless
banking service, is derived from M for mobile and “pesa” (Swahili for money).
5. South Africa has issued 10 million cards covering 16 million beneficiaries.
6.
Data from Global Findex 2014 Survey, http://datatopics.worldbank.org
/financialinclusion/.
7. The total inclusion figure differs from that in the Global Findex 2014 data (appendix A,
table A.7) because the BOT (2014) methodology differs from that of Findex. Among
other differences, 7.8 percent of households that voluntarily do not use financial services
are not considered “excluded” in the BOT survey, so they are implicitly counted within
the BOT (2014) “inclusion” figure.
8. Findex data come from the Global Findex Database, http://datatopics.worldbank.org
/financialinclusion/. The data are compiled using the Gallup World Poll Survey and
measure how adults in 143 economies around the world manage their day-to-day
finances and plan for the future.
9. Also treated in this study (chapter 5) along with South Africa as exemplary social
grant transfer payment programs are Mexico’s Oportunidades and Brazil’s Bolsa
Família programs, which were considered for in-depth case study fieldwork.
The choice was made to pursue fieldwork and in-depth treatment of South Africa’s
biometric chipped debit card program because it is considered a more flexible
e-money product as an effective entry point into the financial system by the poor.
That is, poor grant recipients can use their chipped card at any bank ATM or point of
sale (POS). By comparison, the prepaid cards used in Mexico and Brazil are “closed
loop” and are primarily used for identifying the grant beneficiary for cash-in/cash-out
transactions at limited locations.

Overview 13
10. Figure may differ from other data sources depending on definitions and methodology.
FSD Kenya and CBK (2013) provide a 70 percent figure for overall financial inclusion
in Kenya.
11. Figures depend on definitions and methodology. For Thailand, for example, BOT
(2014) reports somewhat higher figures for financial inclusion than the Findex Survey
2014.
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“FinAccess National Survey 2013: Profiling Developments in Financial Access and
Usage in Kenya.” Survey results report, FSD Kenya and CBK, Nairobi.
Hawkins, D. 1980. Identification of Outliers. London, New York: Chapman and Hall.
Sahay, R., M. Čihák, P. N’Diaye, A. Barajas, R. Bi, D. Ayala, Y. Gao, et al. 2015. “Rethinking
Financial Deepening: Stability and Growth in Emerging Markets.” IMF Staff
Discussion Note SDN/15/08, International Monetary Fund, Washington, DC.
Tambunlertchai, K. 2015. “Financial Inclusion, Financial Regulation, and Financial
Education in Thailand.” ADBI Working Paper 537, Asian Development Bank Institute,
Tokyo.
World Bank. 2014. Global Financial Development Report 2014: Financial Inclusion.
Washington, DC: World Bank.
———. 2017. Doing Business 2017: Equal Opportunity for All. Washington, DC:
World Bank.

PA R T I
Journey toward a Cash-Lite

Society and Financial
Inclusion
Part I introduces the topic of financial inclusion (chapter 1), discusses its impor-
tance, presents definitions, and explains how digitizing money, payments, and
other financial transactions can facilitate inclusion of the unbanked and finan-
cially underserved population (chapter 2). It also sets forth the key stakeholders
in the process of applying digital innovations to achieve greater financial inclusion
(chapter 3).

CHAPTER 1
The Challenge of Financial Inclusion
What Is Financial Inclusion?

This chapter introduces the concept of financial inclusion and why it matters for
development. The gaps in financial inclusion in South Asian countries are
analyzed along several dimensions and are related to poverty status. Particular
attention is paid to the role of remittance transfers.
Financial inclusion has gained greater prominence in recent years as a key
priority in the reform and development agenda to achieve sustainable and
inclusive economic growth. In 2009, the Group of Twenty (G20) included
financial inclusion on its agenda (G20 2009); since that time, donor communi-
ties, standard-setting bodies, national-level policy-making and regulatory bod-
ies, and academia have embarked on various initiatives to further financial
inclusion.
The benefits of financial inclusion are widely accepted. This volume does
not aim to undertake a full-fledged literature review to explain the theoreti-
cal underpinnings of financial inclusion or evaluate the development benefits
that would accrue from having inclusive, low-cost, accessible, and reliable
financial systems. However, the relevance of financial inclusion to the devel-
oping world, especially to the South Asian countries that motivated this
study, is described below with the financial inclusion gap as the axis for the
analysis.
The Consultative Group to Assist the Poor’s (CGAP 2011) working defi-
nition of financial inclusion (box 1.1) explains the need to address access,
use, and quality of service dimensions in order for a financial system to be
truly inclusive. Two other important points are also highlighted: that certain
groups are excluded by the financial system, and that exclusion happens in
payments as well as in traditional intermediary markets such as savings,
credit, and insurance.

18 The Challenge of Financial Inclusion
Box 1.1 “Financial Inclusion”: A Working Definition

“Financial inclusion” refers to a state in which all working-age adults, including those currently
excluded by the financial system, have effective access to the following financial services
provided by formal institutions: credit, savings (defined broadly to include current accounts),
payments, and insurance.
“Effective access” involves convenient and responsible service delivery, at a cost
affordable to the customer and sustainable for the provider, with the result that finan-
cially excluded customers use formal financial services rather than existing informal
options.
“Financially excluded” refers to those who do not have access to or are underserved by for-
mal financial services.
“Responsible delivery” involves both responsible market conduct by providers and
effective financial consumer protection oversight.a The specific characteristics of
excluded consumers have significant implications for effective consumer protection reg-
ulation and supervision, and therefore also for standards and guidance aimed at enabling
financial inclusion. Relevant characteristics are likely to include limited experience with,
and sometimes distrust in, formal financial service providers; lower levels of education
and financial literacy and capability; few formal providers to choose from, if any; and
remote locations.
“Formal institution” refers to a financial service provider that has a recognized legal status
and includes entities (and, in some countries, even some individuals) with widely varying
regulatory attributes, subject to differing levels and types of external oversight. However,
the fact that a customer’s financial service provider has a recognized legal status does not
mean she or he should be considered “financially included” under the definition used: for
this, all the conditions of “effective access” must be met. Moreover, formal products and
providers do not in all cases offer customers a better value proposition than informal prod-
ucts and providers. The reality for many financially excluded households is that informal
options may be the best they have available for the foreseeable future for at least some of
their financial service needs.
Source: CGAP 2011.
a. “Responsible market conduct” by providers includes reasonable steps to ensure transparency and fair treatment, and to
mitigate consumer risks.
According to Kempson and Whyley (1999a, 1999b), there are five major
forms of exclusion:
• Access exclusion, where segments of the population remain excluded from the
financial system because of either remoteness or the process of risk manage-
ment of the financial system
• Condition exclusion, when exclusion occurs because of conditions that are
inappropriate for some people
• Price exclusion, when financial products are unaffordable

The Challenge of Financial Inclusion 19
• Marketing exclusion, when targeted marketing and sales of financial products

lead to exclusion
• Self-exclusion, which takes place when certain groups of people exclude them-
selves from the formal financial system owing to fear of refusal or other
psychological barriers
Financial inclusion, therefore, is not merely the outcome of a process, but a

process in itself. Because of its multidimensional nature, it remains hard to
interrelate such dimensions over time. As a self-reinforcing cycle that results
from the accumulation of a number of disadvantages, it is difficult to attribute
causality to one specific factor or another.
Recognizing the multidimensionality of financial inclusion has led to changes
in the way it is measured. Similarly, an understanding has emerged that financial
inclusion is not static, but rather dynamic, and that different individuals or groups
find themselves in different stages of the financial inclusion process, at times
temporarily, recurrently, or continuously. Moreover, financial exclusion can occur
in one or more of the essential markets, that is, transaction banking, savings,
credit, and insurance. One can therefore argue that no single intervention can
address all of these complexities and achieve the desired state of inclusiveness.
Hence, even well-developed financial markets have their own financially
excluded segments of the population. Developing countries should assess the
rapidly changing financial and social landscapes and focus on whether vulnerable
groups face increased risks of financial exclusion.
Although the measurement of financial inclusion using simplistic indicators is
adequate for assessing the size of the exclusion problem, it may not be sufficient
to properly inform policy makers in these developing countries; as such, the best
means of measuring inclusion is still under debate. A literature review reveals
that different approaches have been proposed, including the use of a variety of
financial inclusion dimensions, measurable proxies, and a few econometric
estimations. Because consensus is lacking about a better indicator that can be
easily measured, all available datasets (Findex 2011 and 2014 Surveys;1 Honohan
2008; Sophastienphong and Kulathunga 2010) use banking inclusion (both
demand- and supply-side) as analogous to financial inclusion.
In the second Global Findex Survey (2014), a more rounded understanding of
financial inclusion is developed to identify opportunities to remove barriers that
may prevent people from using financial services. Historically, financial inclusion
was associated with the branch banking model, and therefore almost all measure-
ments of financial inclusion were based on banking density, proximity, availability
of banking facilities, and affordability of banking products. The 2014 Findex
Survey revised this narrow view. By adding digital platforms, such as mobile
money accounts (using mobile phones), to its financial inclusion measures, a
wider array of indicators (in particular, payment service indicators) are recog-
nized, allowing for more realistic interpretations and comparisons. Thus, for the
first time, the contribution of digitized payments in furthering financial inclusion
has been measured globally.

It should be noted that this measurement of inclusion is still an evolving pro-

cess. Policy makers must often take a broader view of economic and financial
development by observing worldwide trends, innovations, and the full range of
policy initiatives that they might use to design, implement, and monitor progress
for the promotion of financial inclusion.
Why Does Financial Inclusion Matter?

According to the 2014 Global Findex Survey,2 around 38 percent of adults (ages
15 and older) living in low- and middle-income economies cannot access basic
services such as bank accounts, bill payment facilities, mobile money accounts,
loans, insurance, and other simple financial services because of excessive costs,
travel distance, documentation needs, and even lack of awareness. The majority
of this population is at the base of the pyramid and hence is highly vulnerable to
being unable to cope with unexpected events, such as sickness or death of the
breadwinner, loss of employment, crop failure, and natural calamities.
Income and expenditure shocks foster disruptive financial practices in an
effort to smooth consumption, such as borrowing from loan sharks at prohibitive
rates and selling off assets. As a result, the poor are often unable to climb out of
the poverty trap. Access to the financial system provides fairer opportunities for
those living in poverty to improve their income and their standard of living.
As stated by the Commission on Growth and Development (CGD 2008), if the
financial system fails to reach large portions of the population, household savings
will be stunted. People need a secure, accessible vehicle in which to store their
wealth. If the banks do not provide such vehicles, people will save less or will
simply store their money in less liquid forms that do not serve well the wider
economy.
The Link between Financial System Growth and Social Inclusion

In recent literature, economists agree on the positive impacts of financial sector
development on economic growth. These are well documented in studies by
Creane et al. (2004) and Merton and Bodie (1995) on the ways in which devel-
opment of the financial system enhances the efficiency of intermediation and
results in better resource allocation; in Levine’s (2005) seminal paper on the
merits of financial sector development; and in more recent work by Claessens
and Feijen (2006) and Ahmad and Malik (2009).
Well-functioning financial systems not only play a critical role in sustaining
paths of high economic growth by mobilizing savings from the public and
allocating the funds to productive investments; they also help make growth
more inclusive by providing access to finance for all, which is associated with
more rapid growth and job creation, better income distribution, and poverty
reduction (Kulathunga 2012).
Financial intermediation is a critical factor for growth and social inclusion.
One of its core functions is to mobilize financial resources from surplus agents
and channel them to those with deficits. It thus allows investor entrepreneurs to

expand economic activity and employment opportunities. It also enables house-

hold consumers, as well as micro- and small-business entrepreneurs, to expand
their own welfare and earnings opportunities and seek to smooth their lifetime
outlays. In all cases, financial intermediation drives economic growth and contrib-
utes to social inclusion, provided it is conducted in a sound and efficient way
(Grais and Kulathunga 2007). Hence, financial intermediation is a key link
between a country’s overall economic growth and its level of social inclusion.
In underdeveloped financial systems, access is limited. People must resort to
high-cost informal sources, either because formal financial intermediaries are
geographically unavailable or because their products are inaccessible because of
cost and distance. This constrains participation in economic activities, affecting
growth patterns spatially and across social and economic levels. In contrast, a
key feature of financial deepening is that it accelerates economic growth by
expanding access to those who lack adequate finance.
The Link between Financial Inclusion and Poverty Reduction

Access to financial services provides individuals with the opportunity to manage
risk, broaden their menu of economic choices, and smooth their consumption.
Increasing financial access provides capital for enterprise expansion, protects
against both covariate and idiosyncratic shocks, helps move money between fam-
ily members across the world, and generally improves the well-being and eco-
nomic sustainability of the poor.
Theoretically, this promotes economic development, thereby contributing to
poverty reduction. For example, Beck, Demirgüç-Kunt, and Levine (2007) used
cross-country data to show that financial development disproportionately raises
the incomes of the poorest quintile, both by directly reducing income inequality
and, more powerfully, through impacts on aggregate economic growth.
In their paper introducing the Global Findex Database 2014, Demirgüç-Kunt
et al. (2015) describe how policy makers and regulators are increasingly making
financial inclusion a priority in financial sector development. Accordingly,
67 percent of 147 jurisdictions have a mandate to promote financial inclusion,
and international organizations—including the G20 and the World Bank—are
also beginning to formulate strategies that promote financial inclusion.
The Benefits of Financial Inclusion: The Evidence

It is also important to assess the evidence that inclusive and efficient financial
markets have the potential to improve the lives of citizens, reduce transaction
costs, spur economic activity, and improve delivery of other social benefits and
innovative private sector solutions. A 2014 CGAP Focus Note examines the
evidence and provides a comprehensive evaluation attesting to the positive
impacts (Cull, Ehrbeck, and Holle 2014):
• At the microeconomic level, small businesses benefit from access to credit,

while the impact on the broader welfare of the borrower’s household might be
more limited.

• Savings help households manage cash flow spikes, smooth consumption, and
build working capital.
• Access to formal savings options can boost household welfare.
• Insurance can help poor households mitigate risk and manage shocks.
• New types of payment services can reduce transaction costs and seem to
improve a household’s ability to manage shocks through shared risks.
• Financial access improves local economic activity: at the macroeconomic level,
empirical evidence shows that financial inclusion is positively correlated with
growth and employment.
• Financial inclusion can improve the effectiveness and efficient execution of
government payment of social safety net transfers (government-to-person, or
G2P, payments), which play an important role in ensuring the welfare of many
poor people.
• Financial innovation can significantly lower transaction costs and increase
reach, which is enabling new private sector business models that help address
other development priorities.
The Global Financial Inclusion Gap

Financial inclusion is a global challenge. Inclusive financial systems—allowing
broad access to appropriate financial services—are especially likely to benefit
poor people and other disadvantaged groups (Demirgüç-Kunt and Klapper 2013).
The Global Findex 2014 data show that 54 percent of the adults from the
world’s poorest 40 percent of households do not have accounts, not only because
of poverty, but also because of prohibitive costs, travel distance, and the paper-
work involved.3
Globally, the financial inclusion gap, according to Findex 2014, represents
around 38 percent of the total adult population. According to Findex 2011
data—in which financial inclusion had been measured based on the number of
adults having accounts only in formal financial institutions—the comparable
global financial access gap was around 50 percent. Thus, adding and measuring
mobile money transaction accounts in the Findex 2014 Survey helped to
narrow the inclusion gap between 2011 and 2014 and also portrays a more
complete picture.
Before the publication of the first Findex Survey data in 2011, Honohan
(2008) estimated the fraction of the adult population using formal and semi-
formal financial services (that is, from unregulated microfinance institutions)
for more than 160 countries by combining data from banks and microfinance
institutions with household surveys. Matching this information with 2005
population data as a basis, the financially excluded population was estimated
at around 54 percent of the total adult population in Banking the World:
Empirical Foundations of Financial Inclusion (Cull, Demirgüç-Kunt, and
Morduch 2013). Honohan’s estimate (table 1.1) is reasonably consistent with
Findex data. It reveals that financial service use in low- and middle-income
countries—which averages around 37 percent—is woefully low compared

Table 1.1 Estimated Financial Inclusion Gap, Globally and by Region, 2008
Share using
Adult population Using financial Not using financial financial services
Region (millions) services (millions) services (millions) (%)
Middle East and North Africa 191.70 63.28 128.42 33
Central Asia and Eastern Europe 381.87 195.00 186.87 51
East Asia 1,471.20 607.90 863.29 41
High-income OECD 588.94 539.65 49.29 92
Latin America and the Caribbean 387.13 136.82 250.31 35
South Asia 1,039.50 435.76 603.74 42
Sub-Saharan Africa 370.02 74.43 295.60 20
Total 4,430.35 2,052.83 2,377.52 46
Sources: Cull, Demirgüç-Kunt, and Morduch 2013, based on Honohan 2008.
Note: OECD = Organisation for Economic Co-operation and Development. “Adult population” is defined as ages 15 years and older. “Financial
services” includes both formal and semiformal financial services (that is, from unregulated microfinance institutions but not from mobile
money accounts).
with high-income Organisation for Economic Co-operation and Development

(OECD) countries, where 92 percent of adults use financial services. The rate
of exclusion in South Asia is roughly 58 percent, while that of Sub-Saharan
Africa is highest, with 80 percent of the adult population in the excluded
category.
South Asia’s Financial Inclusion Gap

The South Asia region is home to many of the developing world’s poor.
According to the World Bank’s most recent poverty estimates for 2012, about
309.2 million people in the region survive on less than US$1.90 a day (the rees-
timated extreme poverty line),4 and they make up more than 34.3 percent of the
developing world’s poor (World Bank 2016).
Thanks to robust economic growth averaging 6 percent per year over the past
20 years, South Asia has experienced declining poverty and impressive improve-
ments in human development. The percentage of people living on less than
US$1.25 a day (the extreme poverty line prior to 2015) fell in South Asia from
61 percent to 24.5 percent between 1981 and 2011 (World Bank 2015a).
At US$1.90 a day, this was projected to drop further, to 13.5 percent, by 2015
(World Bank 2016).
However, factors such as weak global demand and lower foreign investment
pursuant to the global financial crisis, political uncertainties, power outages, and
weak monsoons resulted in the slowing of economic growth in the region to
around 4.2 percent in 2012, from an estimated 7.2 percent in 2011. If these vola-
tilities are addressed effectively, it is expected that South Asia can grow by an
average of around 6.5 percent over the next three years. Nevertheless, the slow-
down in global growth patterns, conflicts, and volatile markets are continuing
challenges.

Figure 1.1 Share of Adults with a Financial Services Account, by Region, 2014
East Asia and Pacific 69
Europe and Central Asia 51
Latin America and the Caribbean 51
South Asia 46
Sub-Saharan Africa 34
Middle East 14
0 10 20 30 40 50 60 70 80
Percent
Source: Global Findex Survey 2014 data, http://datatopics.worldbank.org/financialinclusion/.

Note: Adults are those aged 15 years or older. “Financial services” includes both services from formal financial institutions and
mobile money accounts.
In terms of financial access, South Asia ranks above the Middle East and
Sub-Saharan Africa regions, with around 46 percent of the adult population hav-
ing accounts (figure 1.1).5 Thus the financial inclusion gap—measured in terms
of the number of adults without an account in a formal financial institution or a
mobile money account as the proxy—is around 54 percent.6
In recent times, retail payment systems development in Asia as a whole
has been impressive, although growth rates in South Asia have been low
relative to those in East Asia (China, Japan, and the Democratic People’s
Republic of Korea) and in Southeast Asia (Indonesia, Malaysia, Singapore,
and Thailand). It is also noted that technology-driven retail payment ser-
vices have clearly demonstrated their contribution to reducing poverty
(especially in East Asian and Southeast Asian countries) by ensuring the
availability and affordability of financial services—in other words, financial
inclusion.
However, until recently, no meaningful correlation has been established
between payment services and poverty reduction, although some prelimi-
nary attempts to establish such a relationship are now apparent (as in Cull,
Demirgüç-Kunt, and Morduch 2013). As such, the potential of retail pay-
ment services as a poverty reduction measure has still not been explored
fully, primarily because of the narrow range of indicators used to measure
poverty reduction as well as the labeling of payment services as an informa-
tion and communication technology (ICT) or information technology (IT)
enabler rather than as a business proposition or a potential measurement of
the social well-being of the people. Ideally, this perception will change with

the reclassification of the definition of account ownership to include mobile

money accounts, with the 2014 Findex data as a starting point.
Country-Specific Inclusion Gaps

Analysis of country data shows that almost all South Asian countries fall below
the regional average (46 percent) for financial inclusion except for Sri Lanka,
which has 83 percent inclusion.7 At roughly 10 percent and 13 percent, respec-
tively, Afghanistan and Pakistan register the lowest rates in the region (figure 1.2).
In South Asia overall, 54 percent of adults, or around 585 million people, remain
outside of the formal financial system.
In the developing world as a whole, it is interesting to note that lack of money
is the most commonly reported reason for being unbanked. Other reasons for not
having access to formal financial services include distance to banks and the costs
associated with maintaining an account at a formal institution such as a bank,
credit union, savings and credit cooperative, post office, or microfinance institu-
tion (Demirgüç-Kunt and Klapper 2013).
Further analysis of South Asian country data shows a different dimension
of the inclusion gap: gender-based inequality. Findex data highlight this
inequality within and across gender: in all South Asian countries except Sri Lanka,
fewer women than men have financial services accounts (figure 1.3). There is
striking disparity in Afghanistan and Pakistan, where less than 4 percent of
women have formal financial access compared with rates nearly four times
greater for men, at 15.8 percent and 14.2 percent, respectively. Even in India,
the rate for men (62.5 percent) is 47 percent higher than the rate for women
(42.6 percent).
Figure 1.2 Share of South Asian Adults with a Financial Services Account, by Country, 2014
Sri Lanka 83
India 53
Nepal 34
Bhutan 34
Bangladesh 31
Pakistan 13
Afghanistan 10
0 10 20 30 40 50 60 70 80 90
Percent

Note: Adults are those aged 15 years or older. “Financial services account” includes either an account with a formal financial
institution or a mobile money account.

Figure 1.3 Share of South Asian Adults with a Financial Services Account, by Gender and
Country, 2014
Sri Lanka 82.2

83.1
India 62.5
42.6
Bhutan 39.0
27.7
Nepal 36.7
31.3
Bangladesh 32.9
25.2
Afghanistan 15.8
3.8
Pakistan 14.2
3.0
0 10 20 30 40 50 60 70 80 90
Percent
Male Female

Note: Adults are those aged 15 years or older. “Financial services account” includes either an account with a formal financial
institution or a mobile money account.
The Supply-Side Dimension: Finance Accessibility

Because Findex depicts only demand-side data and does not include Maldives,
the study also reviews the factors in the supply-side dimension for all South
Asian countries, using the Getting Finance in South Asia 2010 database
(Sophastienphong and Kulathunga 2010). Figure 1.4 shows standardized data for
South Asia for the period 2004–08. Maldives and Sri Lanka both register high
scores on these indicators of accessibility of finance.
It should be mentioned that, although the penetration numbers for banking
access are high for Maldives (in terms of geographic and demographic penetra-
tion of automated teller machines [ATMs] or branches), the ratios alone do not
reflect the true picture, because geographic dispersion of the population among
the atolls is not taken into consideration in the calculations. Most bank branches
or ATMs are concentrated on the main island of Malé, while the Maldives popu-
lation of 338,400 is scattered throughout 200 islands in 26 atolls. Most people
who live on atolls are a two- to four-hour round-trip ferry ride away from the
nearest bank branch or ATM; thus, to date, although the financial access figure is
estimated at around 50 percent of the population, cost and proximity issues cre-
ate untold hardships for Maldivians to access financial services.
India scores well on all indicators, while Pakistan’s results suggest a need to
focus on the use of financial services, notably the provision of loans and the
mobilization of deposits (Sophastienphong and Kulathunga 2010). Bangladesh
scores low on demographic penetration for both bank branches and ATMs, while

Figure 1.4 Access to Finance in South Asia: Supply-Side Data, 2010
45
40
35
Total score, 2004–08
30
25
20
15
10
tio h
tio ic
op ts
op ts
tio M
tio M
tra nc
tra ph
pe un
pe un
tra AT
tra AT
n
n
le
le
n
n
ne bra
ne ra
00 co
00 co
ne ic
ne ic
pe og
,0 ac
,0 ac
pe aph
pe aph
pe hic
ch em
r 1 sit
r 1 an
r
r
ra
og
pe po
og
pe Lo
D
og
Ge
De
m
Ge
De
an
br
Afghanistan Bhutan Maldives Pakistan

Bangladesh India Nepal Sri Lanka
Source: Sophastienphong and Kulathunga 2010.

Note: ATM = automated teller machine. Scores are based on each country’s position on a scale from 5 (lowest-performing country) to 40
(highest-performing country) for each indicator.
Bhutan scores low on geographic penetration. Nepal’s scores suggest a need to

work on all aspects of access to finance, though increasing the number of players
in the market has not produced the desired effect. Afghanistan scores lowest on
all indicators.
Poverty, Financial Exclusion, and Financial Vulnerability in South Asia

The overall findings on poverty, the financial inclusion gap, and financial vul-
nerability in South Asia are summarized in figure 1.5. According to Findex
2014 data, the majority of the adult population in South Asia (54 percent, or
around 585 million people)8 is financially excluded. According to World Bank
(2015a) data, the population’s extreme-poverty headcount ratio (below
US$1.25 per person per day) in 2014 was around 24 percent (399 million
people). Taken together, these data indicate that, in addition to the extreme
poor, some 186 million people (around 11 percent of the South Asian adult
population) are financially vulnerable though not in the extremely poor
category.

Figure 1.5 Poverty, Financial Exclusion, and Financial Vulnerability Indicators in

South Asia, 2014
70
65
59
60
50
40
Percent
35
30
24
20
10
0
Total adults Financially Below US$1.25 Below US$2
excluded adults a day a day
Source: Calculations based on Global Findex Survey 2014 data (http://datatopics.worldbank.org

/financialinclusion/) and World Bank 2015a.
Note: “Financially excluded adults” refers to people ages 15 and older who lack any kind of account for
financial transactions, either through a formal financial institution or a mobile money service. “US$1.25 a day”
represents the 2014 international per capita “extreme poverty” line, using 2005 purchasing power parity (PPP)
exchange rates. “Below US$2 a day” represents the median poverty line of all developing countries, also at
2005 PPP, as calculated by Chen and Ravallion (2010).
The fact that South Asia accounts for a third of the world’s poor (World
Bank 2016) indicates the challenge that these financial inclusion indicators
pose for addressing poverty in the region. However, one needs to be prudent in
interpreting these statistics or generalizing the results, as they may not have
fully captured the more recent technology-based financial services that are
being successfully delivered in some countries in South Asia, especially in
Bangladesh, India, and Sri Lanka.
Age dependency on the working-age population is another important
dimension that cannot be ignored, especially when considering a country’s
poor.9 At the base of the pyramid, living with less money means having very
little control over economic outcomes and virtually no ability to save for
unforeseen events. The ramifications of financial exclusion for working-age
adults inevitably pass on to their dependents. In South Asia, the age depen-
dency ratios of the young (ages 0–14 years) and old (ages 65 years and older)
are 46.4 percent and 7.9 percent, respectively.10 Therefore, in South Asia,
there are nearly 55 dependents per 100 working-age adults, on average.
Thus, the total financially excluded population in South Asia can be considered
to exceed 1.5 times the number of working-age adults identified as financially
excluded.

The extent of concentration of the world’s extremely poor in South Asia

argues for policy actions and approaches to address the resulting financial inclu-
sion gap. For example, World Bank (2016) data establish that in 2012, Bangladesh
(at 43.6 percent, or 66 million people) and India (at 21.2 percent, or 268 million
people) were among the top 10 countries with the largest numbers of extreme
poor in the world.
At the same time, it is encouraging to see that India led the five top con-
tributors to poverty reduction from 2008 to 2011 by lifting a staggering
140 million people out of extreme poverty (World Bank 2015a). These num-
bers tell us that, if appropriate policy responses and corrective actions are taken
to close financial inclusion gaps in South Asia, these significant poverty figures
can be further reduced by giving poor people more opportunities to participate
in the economic development process in these countries. The World Bank’s
expectation is that the extreme poor population in South Asia will be further
reduced to 249.6 million (35.8 percent of the world’s extreme poor popula-
tion) by 2020, and to a remarkable 42.5 million (10.3 percent of the world’s
extreme poor) by 2030 (World Bank 2015a). Nevertheless, policy makers and
researchers have not been able to capture the full contribution to poverty
reduction of technology-based payment services because of the limited avail-
ability of reliable information.
Remittance Transfers and Financial Inclusion

Introducing the Global Findex 2014 Database, Demirgüç-Kunt et al. (2015)
highlight the importance of domestic remittances in developing economies.
According to Findex Surveys, 15 percent of adults in developing economies
reported having sent money to a relative or friend living in a different part of
the country, and 19 percent report having received such a payment in 2014.
While 48 percent of adults questioned in Sub-Saharan Africa reported having
either sent or received remittances, in South Asia this figure reached only
around 17 percent.
Although cash remains by far the most common method of sending or receiv-
ing domestic remittances, sending money digitally is gaining popularity, with
mobile money being the preferred method. Hence remittances are examined
here as a potential driver of increased use of mobile money, which in turn is an
entry point for access to additional financial services.
Significance of Remittances to Developing Countries

For many developing economies, remittances are an important source of real
convertible currency. On a macroeconomic level, remittances are more stable
than other sources of foreign exchange because their variation is often counter-
cyclical, helping to sustain consumption and investment during downturns.
The value of remittance flows to developing economies is now more than three
times that of official development assistance (figure 1.6). For countries such as
Bangladesh, the increasing flow of remittances has reduced external aid dependency,

Figure 1.6 Remittances and Other Resource Flows to Developing Countries, 1990–2015
700
600
FDI
500
US$, billions
400 Remittances
300
200 Private debt and

portfolio equity
ODA
100
e
91
01
20 1
90
92
93
98
99
00
02
03
08
09
10
94
04
95
96
05
06
97
07
20 f
20 f
f
12
1
13
14
15
19
20
20
19
19
19
19
19
20
20
20
20
20
20
19
20
19
19
20
20
19
20
20
Source: Ratha, Ayana Aga, and Silwal 2012, from World Bank estimates and World Development Indicators Database.
Note: FDI = foreign direct investment; ODA = official development assistance. e = estimated; f = forecast. “Developing countries” refers to low- and
middle-income economies as defined in the World Bank’s Income Classifications. As of July 1, 2016, low-income economies had 2015 gross
national income (GNI) per capita of US$1,025 or less. Middle-income economies had 2015 GNI per capita of US$1,026 to US$12,475.
while for Sri Lanka remittances offset as much as 85 percent of the country’s
trade deficit in 2010 (Samuel 2016).
Remittances have become a significant source of external funding in the
developing world in general, having quadrupled in the past decade, with an
apparent opportunity to increase flows to South Asia. According to the
International Organization for Migration (IOM), more than 105 million people
around the world are migrant workers seeking better opportunities in a foreign
country.11 Global international remittances in 2012 were estimated at US$514
billion, a 10.8 percent increase from 2011, including US$401 billion sent to
developing countries (Klapper and Singer 2014).
For South Asian countries, remittances have been a stable source of
income, with strong growth potential mostly driven by steady economic
opportunities in the Gulf Cooperation Council (GCC) countries.12 Nepal is
among the top recipients of migrant remittances in the world:13 in 2012, the
share of remittances reached 25 percent of its gross domestic product
(GDP) and climbed to a staggering 29 percent of GDP by 2013 (table 1.2).
In 2012, India was the top recipient in the world in terms of value, with
over US$70 billion in receipts; Pakistan was seventh on the list of top earn-
ers, with remittance receipts totaling US$14 billion (Ratha, Ayana Aga, and
Silwal 2012).

Table 1.2 South Asia Remittance Receipts, by Country, 2009–13

Percentage of GDP
Country 2009 2010 2011 2012 2013
Afghanistan 1.22 2.08 1.38 1.88 2.65
Bangladesh 10.48 9.79 10.08 10.68 9.24
Bhutan 0.38 0.52 0.57 0.99 0.66
India 3.60 3.13 3.39 3.75 3.73
Maldives 0.23 0.15 0.14 0.15 0.14
Nepal 23.14 21.69 22.37 24.96 28.77
Pakistan 5.19 5.47 5.74 6.24 6.30
Sri Lanka 7.93 8.32 8.71 10.10 9.56
Source: World Development Indicators Database, http://data.worldbank.org/products/wdi.
Impacts of Remittance Methods on Financial Inclusion

Studies on the effects of international remittance transfers on domestic
financial systems have confirmed that remittances have a positive impact on
financial inclusion and financial sector development (Aggarwal, Demirgüç-
Kunt, and Martinez Peria 2006; Anzoategui, Demirgüç-Kunt, and Martinez
Peria 2011; Gupta, Pattillo, and Wagh 2009). However, not much evidence
pointed to the use of credit markets by the recipients, as the need for credit
may have been alleviated as a result of money remitted. Indeed, in South Asian
countries with strong remittance flows, the unbanked percentages neverthe-
less remain high, indicating that poor people still rely principally on cash for
daily financial transactions. This is confirmed by the large share of funds tied
up as notes and coins in circulation. In South Asia, the ratio of notes and
coins is, on average, around 10 percent of GDP—almost twice the rate in
developed economies—denoting greater use of cash in the settlement pro-
cess (Sophastienphong and Kulathunga 2010).
Because of proximity issues, cost, problems with the means of identifica-
tion, and other factors, senders and receivers of remittances lack safe and
affordable ways to save, borrow, and send money. This creates an opportunity
for e-money, to the extent that innovative methodologies can solve these
problems.
South Asia has the advantage of being the least-cost region to send money
to, costing an average of 5.7 percent (of the amount sent) over 2008–15 (World
Bank 2015b).14 Overall, the global average total cost was around 7.7 percent
and shows a declining trend. The relatively high costs relate in part to limited
competition, Anti-Money Laundering and Combatting Funding of Terrorism
(AML/CFT) regulatory restrictions, and the impact of potential penalties on
transfer operators that further limit entry into the remittance market (Todoroki
et al. 2014).
On the other hand, transaction cost is not the only factor that matters for
inclusion. Proximity to a transfer agent matters greatly, since lack of proximity
implies travel and opportunity costs such as loss of daily wages. Because transfer

agents are largely absent in rural areas, mobile money may offer a solution to
these problems.
Although the world has recognized remittance flows as a key contributor
to poverty alleviation, little effort has been devoted to improving payment
instruments and services through which remittances flow from one country
to another or from remitter to receiver. Many remitters are frustrated at the
remitting point (capturing end) because of the nonavailability of direct pay-
ment instruments and the high cost of transactions. Remittance receivers, for
their part, are equally frustrated at the receiving end (disbursement point)
because of delays in crediting accounts (transmission delays or bank floats)
and high commissions or fees.
Recent innovations by the nonbank money transfer service providers (such
as Western Union and MoneyGram) have helped to speed transfer services, but
at a cost to remitters and, in some instances, to the remittance receivers as well.
Banks have made few attempts to speed up remittance flows at affordable
costs in a satisfactory manner. The remittance corridors that have been estab-
lished have remedied bank-based remittance issues to some extent, although
further improvements can be made to payment instruments and services.
It is clear that there is a huge opportunity for South Asian countries to
improve financial inclusion—particularly for the poorer segments of the
population—by using innovative methods, tools, and applications to harness
inward remittance flows. Effective e-money solutions should provide benefits to
customers in terms of proximity, safety, reliability, cost, usability, and diversified
services that match the needs of the customers, who would, in most cases,
otherwise be excluded from the formal financial system.
Notes
1. Findex data from the Global Findex Database, http://datatopics.worldbank.org
/financialinclusion/. Findex data are compiled using the Gallup World Poll Survey
and measure how adults in 143 economies around the world manage their
day-to-day finances and plan for the future. The indicators are constructed using
survey data from interviews with more than 150,000 nationally representative and
randomly selected adults over the 2014 calendar year (approximately 1,000 people
from each country).
2. For the 2014 Global Findex Survey data, see http://datatopics.worldbank.org
3. Global Findex 2014 Survey data, http://datatopics.worldbank.org/financialinclusion/.
4. In 2015 the international extreme poverty and poverty lines were reestimated at
US$1.90 and US$3.10 per person per day, respectively, using 2011 purchasing power
parity (PPP) exchange rates. The previous extreme poverty and poverty lines had been
US$1.25 and US$2.50 per person per day, respectively, using 2005 PPP exchange
rates.
5. Global Findex 2014 Survey data, http://datatopics.worldbank.org/financialinclusion/.
6. Although, according to the Honohan (2008) study (table 1.1), 58 percent of South Asian
adults do not use or have access to available financial services, the Findex 2011

data showed the rate of financial exclusion to be around 67 percent, and the 2014
Findex exclusion rate is calculated to be around 54 percent (figure 1.1). The difference
in data collection methodologies may account for the different estimates. Honohan’s
study is based on household surveys as well as on data from banks and microfinance
institutions, many of which may not qualify as “formal” by the Findex definition. The
Findex data are culled from a random sampling survey. Arguably, Honohan’s study
includes more variables and data points that may explain South Asia’s microfinance
phenomena and the region’s higher level of inclusion when compared with Findex
2011 data. The Global Findex 2014 data include not only accounts at formal financial
institutions but also formal transaction accounts, such as mobile money.
7. The other South Asian exception, Maldives, is not included in the Global Findex
dataset.
8. The number of adults represents around 35 percent of South Asia’s total population.
9. The age dependency ratio is a measure showing the number of dependents (ages 0–14
years and over 65 years) in relation to the total working-age population (ages 15–64
years).
10. Age dependency ratios are based on data from the Global Findex Survey 2014 (http://
datatopics.worldbank.org/financialinclusion/) and the World Bank’s 2015 World
Development Indicators dataset (http://data.worldbank.org/products/wdi).
11. For this and other data on international labor migration, see the IOM website: https://
www.iom.int/labour-migration.
12. The GCC member states include Bahrain, Kuwait, Oman, Qatar, Saudi Arabia, and
the United Arab Emirates.
13. Country remittance data (as a share of GDP) are from the World Bank’s 2015 World
Development Indicators Database (http://data.worldbank.org/products/wdi).
14. The cost of sending money to East Asia and the Pacific remained substantially stable
during the period, at 8.1 percent, while in Latin America and the Caribbean, the cost rose
marginally to 6.8 percent (World Bank 2015b). The average for the Middle East and
North Africa declined to 8.2 percent, while in Eastern Europe and Central Asia, the aver-
age cost was 6 percent including the Russian Federation (7 percent excluding Russia).
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CHAPTER 2
Digitizing Financial Inclusion

through Innovations
Types of Innovation for Financial Inclusion

South Asia is the birthplace of modern microfinance and today still has some of
the world’s most sophisticated cash-based financial systems for poor people. It is
important to explore how these existing methods of financial inclusion can be
augmented through innovative digital financial services (DFSs) or solutions.
Technology-based solutions offer tremendous opportunities to transform the
landscape of access to financial services for the poor, women, and people living
in remote areas. Doing so can spur development and reduce poverty.
Godinho (2010) states that recent advances made by Brazil, China, or India
stem to a large extent from building their countries’ national innovation systems.
However, he also cautions that developing countries will need wise policies as
innovation becomes a central component of economic development, as is hap-
pening in China, India, and other emerging economies. Appropriate policies will
ensure that innovative processes are pro-poor, so that distributional outcomes are
socially inclusive.
Developing a technology and innovation strategy requires having an under-
standing of the different forms of innovation. Henderson and Clark (1990)
describe two main forms of innovation:
• Incremental innovations exploit the potential of established designs, and often

reinforce the dominance of established firms. They improve the functional
capabilities of existing technology by means of small-scale improvements in
the technology’s value by adding attributes such as performance, safety, qual-
ity, and cost. Generational or next-generation technology innovations are
incremental innovations that lead to the creation of a new but not radically
different system.
• Radical innovations introduce new concepts that depart significantly from past
practices and help create products or processes based on a different set of engi-
neering or scientific principles and often open up entirely new markets and

38 Digitizing Financial Inclusion through Innovations
potential applications. They provide new functional capabilities unavailable in

previous versions of the product or service. More specifically related to busi-
ness, radical innovation has been defined by O’Connor and Ayers (2005) as
“the commercialization of new products and technologies that have a strong
impact on the market, in terms of offering wholly new benefits, and on the
firm, in terms of its ability to create new businesses.”
Trends in Financial Service Innovation

Banks typically opt for an incremental launch of innovative products, services, or
tools in retail banking. The deregulation and liberalization of the financial sector
in the 1970s witnessed the advent of numerous innovations in the form of pay-
ment (credit and debit cards); transaction processing (automated teller machines
[ATMs], telephone and online banking, and e-commerce for financial assets);
saving options (such as investment funds and structured products); loans (auto-
mated credit scoring); and risk management techniques (derivatives and securi-
tization). Breakthroughs in information technologies are largely responsible for
these new developments that boost productivity, permit a better diversification
of risk, and generate economies of scale in internal activities, to mention a few
of the benefits (Vives 2010).
Although these innovations brought greater financial inclusion, they also
increased a domino-effect contagion, largely due to excessive risk taking, deregu-
lation, and regulatory arbitrage, as evidenced in the global financial crisis of
2007–08. In the wake of the financial fallout and economic downturn, banks
have been actively pursuing strategies centered on digital technologies and solu-
tions to provide a holistic service to their clients in an effort to regain their trust,
boost flagging customer loyalty, and increase their market share by offering an
integrated and seamless customer experience. In both developed and emerging
markets, consumers increasingly prefer multichannel banking, with full digital
access and more personalized products and services. Interestingly, in these mar-
kets, retail banks face serious competition from online-payment specialists and
digital merchants such as Square, PayPal, Simple, Google Wallet, Venmo, Amazon,
eBay, and the like.
While innovations tend to diffuse across all markets, those same innovations
may not generate market development or financial inclusion in developing coun-
tries that are at different stages of development and where large segments of
society are financially excluded. Moreover, innovations do not always flow in one
direction—from more-developed to less-developed markets.
The case studies in this volume highlight innovations in less-developed mar-
kets that have not yet been introduced into more-mature markets. The status quo
in banking and finance will have to change to accommodate around 2.2 billion
poor people in the world (around one-third of the world’s population, who are
surviving on less than US$2 a day).1
What is needed are radical innovations in the way financial services are pro-
vided that engender transformational outcomes. Such innovations can create
true competitive advantage as well as build new market segments and business

Digitizing Financial Inclusion through Innovations 39
opportunities by scaling up. Radical innovations are revolutionary in nature and

involve significantly more risk taking, which is why it is rare to see established
banking institutions initiating such practices. Breakthrough innovations in
financial services could enable large portions of the population to access and
use the financial system, thus providing opportunities to work toward better
living standards.
Impacts of Recent Innovations on Financial Inclusion

The significance and trends of innovation in retail payment systems and products,
along with the impact on financial inclusion from a payment systems perspective,
were documented in the 2010 survey conducted in 139 countries by the World
Bank’s Payment Systems Development Group. The Global Payment Systems
Survey observed that there had been a fairly widespread adoption of electronic
payment channels for the initiation of payment transactions using innovative
retail payment mechanisms (World Bank 2012). In terms of usage, innovative
payment products are still used much less frequently than traditional retail pay-
ment products. However, they are important for financial inclusion in over
14 percent of the surveyed countries. Although nonbanking entities are playing
a significant role in the provision of innovative retail payment products and
mechanisms, banks remain a significant player in this field.
Collaboration among various types of entities is widespread, with over one-
third of the products involving joint provision of a product or service, almost all
of which involved a bank and a telecom company (World Bank 2012). In 60
percent of the cases, customer funds were protected fully. Furthermore, innova-
tive payment products appear to have fairly well-developed pricing models.
Merchant payments, utility bill payments, and person-to-person (P2P) transfers
were the most common transaction types supported by the innovative payment
mechanisms; less than 10 percent of the products supported government-to-
persons (G2P) payments.
Most of the innovative products or mechanisms have limited interoperability,
with less than 20 percent of the products reported to be fully or partially interop-
erable (World Bank 2012). Also, traditional clearing and settlement infrastructure
is not generally used, and more than 50 percent of the innovative products
reported in the survey were settled in the books of the issuer, with only around
24 percent settling in central bank money. Security and fraud risks seem to be
getting inadequate attention. Central banks identified themselves as the over-
seers of around 60 percent of the products; however, 10 percent of the products
were subject to collaborative oversight.
In contrast to the detailed transaction data available for traditional retail pay-
ment systems and products, the details available for innovative payment prod-
ucts and payment systems are limited. In general, central banks are not overly
optimistic about the anticipated impact of innovations on retail payment sys-
tems and financial inclusion in their respective jurisdictions. Of the 132 partici-
pating central banks, 31 anticipated that the use of electronic payment
instruments would increase, 16 foresaw a positive impact on financial inclusion,

and 8 expected a positive impact on efficiency (World Bank 2012). Seven

central banks anticipated no significant impact on inclusion from ongoing

innovations.
E-money and Digital Payments

Though the digital economy is still in its infancy, it is fast taking shape in response
to technological advancements and innovations, even in developing countries.
Not too long ago, payment systems only dealt with the transfer of money. While
electronic payment systems date back to the 1970s, when Western Union intro-
duced the electronic funds transfer (EFT), recent transformative innovations
such as mobile applications, e-wallets, near-field communication, and card pay-
ments have broadened the array of available electronic payment modalities.
Across the globe, digital payments and e-money products are expanding
rapidly, mostly because of their potential to make small-value payments
cheaper and safer for both payer and payee. In their article titled “The Future
of Global Payments,” Bruno, Istace, and Niederkorn (2014) state that the
emergence of digital technology is leading to faster and more convenient
payments solutions, and a subsequent rise in the expectations of both
retail-consumer and commercial clients, thereby expanding financial inclu-
sion. They forecast that payments revenue will grow by 8 percent each year
through 2018, at which point annual revenue will reach US$2.3 trillion and
account for 43 percent of all banking services revenue, compared with 34
percent in 2009. Although e-money provides a viable means of enhancing
financial inclusion, it is not a panacea. Nevertheless, e-money and digital pay-
ment systems help address barriers to inclusion and ensure connectivity to
mainstream financial services.
What Is E-money?
The World Bank (2012) defines electronic money (e-money) instruments as
access mechanisms to prefunded accounts held at banks or nonbank institu-
tions that can be used through the Internet, payment cards, or mobile phones.
Such instruments have the potential to further reduce the dependence on
paper-based payment instruments by dramatically broadening access to elec-
tronic payments for a larger number of consumers, especially unbanked and
underbanked consumers.
According to the definition in the “Electronic Money Directive” issued by the
European Union, “electronic money” is monetary value as represented by a claim
on the issuer that is (a) stored electronically (including magnetically); (b) issued
on receipt of funds of an amount not less in value than the monetary value
issued; and (c) accepted as a means of payment by undertakings other than those
of the issuer (ECB 2009).
It is not necessary for e-money to be associated with a bank in making the
payment transaction, because e-money acts as a prepaid bearer instrument.

Table 2.1 Differences between Electronic Money and Virtual Currency Schemes
Aspect Electronic money schemes Virtual currency schemes
Money format Digital Digital
Unit of account Traditional currency (euro, Invented currency (Linden Dollars,a
U.S. dollars, pounds, etc.) that bitcoins, and other types) without
have legal tender status legal tender status
Acceptance By undertakings other than Usually within a specific virtual
the issuer community
Legal status Regulated Unregulated
Issuer Legally established electronic Nonfinancial private company
money institution
Supply of money Fixed Not fixed (depends on issuer’s
decisions)
Possibility of redeeming Guaranteed (and at par value) Not guaranteed
funds
Supervision Yes No
Type(s) of risk Mainly operational Legal, credit, liquidity, and
operational
Source: ECB 2012.
a. Linden Dollars are a currency used in the virtual world Second Life (SL), whereby SL users buy from and sell to one another
using the Linden, which is exchangeable for U.S. dollars or other currencies on market-based currency exchanges.
Virtual currency schemes such as Bitcoin are a form of e-money; however, unlike
virtual currency, the link between e-money and the fiat currency against which
the e-money is issued remains intact, because funds are expressed in units of that
currency such as U.S. dollars or euros (table 2.1).
It should also be noted that there is an ongoing debate on whether e-money
can be considered “money.” The principal objections raised, as discussed by Geva
and Kianieff (2005), are the following: First, e-money does not provide a distinct
unit of account. Second, payment with e-money may not be anonymous, because
the third-party obligor may keep a record of each transfer. Third, e-money may
be created other than by withdrawal from a reservable deposit with a commer-
cial bank, so as to undermine the central bank’s hold on monetary policy. Fourth,
e-money cannot constitute legal tender. However, these conditions can be
addressed (though not entirely eliminated) if e-money is universally accepted
and if the economy becomes truly digital.
The impact of developing e-money on a country’s monetary policy is a funda-
mental concern. Essentially, monetary policy is aimed at preserving price stabil-
ity; to do that, the monetary authority manages the money supply through
various policy tools. If e-money is created by converting cash or deposit accounts,
there won’t be new money creation, hence no additional impact on monetary
policy. Consequently, digital financial applications typically ensure that the total
value of e-money is mirrored in a bank account in the banking system. Although
the bank account can earn interest on the balance, e-money in the digital pay-
ment system cannot.

Digital Payment Systems

The World Bank (2012) analysis of the evolution of retail payments over the past
five to six decades shows that
• Successful adoption of advances in technology have played a key role in the

development of new channels for payment initiation, improved authentica-
tion, and efficient processing;
• The development of new payment needs (transit payments, Internet auction
sites, and social networking sites) have also led to the creation of new payment
mechanisms; and
• Payment infrastructure created for one payment product has been successfully
leveraged for other payment products, such as using an automated clearinghouse
(ACH) for online banking–enabled payments or the successful leveraging of
infrastructure created for credit cards by debit cards.
Payment systems enable people and businesses to pay bills, buy goods and
services, remit money, and collect dues. Moreover, they help governments and
regulators to pay salaries, pensions, and other remunerations, disburse social
grants and other benefits; and collect taxes, fees, and dues from the general
public. Transformative innovations in the payment systems offer alternative
digital channels, such as real-time payments using mobile phones and smart-
phones, cards, and Internet, thereby enabling faster, more secure, and more effi-
cient services at lower cost. While some of these options may not work for the
financially excluded, others, such as ubiquitous access to mobile phones, can
enable efficient and low-cost payment alternatives to traditional methods.
Tarazi (2011) highlighted the cost implications of branch versus branchless
banking, demonstrating that significant savings can be achieved in moving toward
branchless banking, which would positively affect the value propositions
involved in offering services to poor people (figure 2.1). Often, digitizing pay-
ments is the first step toward becoming a cash-lite society. Many countries may
not go beyond this point, but even so, the impact of this measure alone on finan-
cial inclusion would be significant.
Toward a Cash-Lite Society

Although financial inclusion is increasingly becoming a national strategy in many
countries, embracing digital payments and moving toward a cash-lite society
rarely is seen as a national development priority. Lack of visible and tangible
results in the short run may be the reason. However, growing evidence on the
benefits offered by electronic payments over cash in terms of safety, convenience,
least cost, fighting crime and corruption, and advancing financial inclusion sug-
gests that a strategically driven and coordinated approach managed by regulators
and policy makers, along with bank and nonbank operators, is needed to unlock
the potential of DFS technology in developing countries (box 2.1).

Figure 2.1 Sample Relative Costs of Payment System Infrastructure, from Bank Branches to Mobile Phone
Reducing the cost of banking infrastructure
$250,000
Traditional
branch $50,000
$10,000
Branch
in store
ATM
$2,000
Agent with
POS terminal
$400
Agent with
mobile
$0
No agent
(cashless)
Source: Tarazi 2011. © Consultative Group to Assist the Poor (CGAP). Reproduced, with permission, from CGAP. Further permission required for reuse.
Note: ATM = automated teller machine; POS = point of sale. Dollar amounts shown indicate the approximate capital cost of each
technology.
Box 2.1 Cash versus Electronic Payments

Today, around 85 percent of all retail payment transactions are done with cash, which equates
to 60 percent of retail transaction value. Although much of the world’s population has access
to many options for making payments other than cash, it continues to persist as a major
means of exchange. Cash takes time to get at, is riskier to carry, and by most estimates, costs
society as much as 1.5 percent of gross domestic product (GDP).
Electronic payments, on the other hand, have been proven to boost economic growth,
while advancing financial inclusion. It is for these reasons that countries around the world are
working to make their payment systems less dependent on cash.
Source: Thomas, Jain, and Angus 2013.

Even today, many central banks and policy makers in the bankcentric develop-
ing countries consider payments as part of information and communication
technology (ICT) and information technology (IT) and continue to ignore the
potential of mobile-based payment systems. This is primarily because of igno-
rance and also a vested interest in traditional financial service providers—that is,
banks and approved financial institutions.
On the contrary, many advanced-country central banks have appointed
national payment councils (NPCs) to educate all stakeholders involved in pay-
ment system development for both large-value and retail payments. Although a
tremendous amount of progress has been achieved in advanced markets such as
Australia, Canada, and the United Kingdom, little or no achievement is recorded
in developing- and emerging-country NPCs.
Some central banks have become “onlookers” as market practitioners, and
financial market infrastructure (FMI) providers have overtaken them by
keeping up with emerging trends in technology. In this context, it is imperative
to enhance the capacities and knowledge of senior policy makers and regulators
as to the wide-ranging benefits of payment system development when it comes
to achieving broader social and economic advantages—including those related
to effective monetary management, the establishment of financial system
stability, poverty reduction, and the promotion of financial inclusion and access
to finance.
In most developing countries, adopting these systems can be a revolutionary
experience by providing access to a previously unbanked population. Digitizing
payments can lead to tangible efficiencies in the form of huge cost savings and
increased efficiency for payers, as in the following examples:
• In Mexico, by digitizing and centralizing its payments, the Mexican govern-

ment is saving an estimated US$1.27 billion per year—or 3.3 percent of its
total expenditure—on wages, pensions, and social transfers. In 2012,
97 percent of pension payments were made by electronic transfers (Babatz
2013).
• In Kenya, mobile payments made through M-Pesa played a central role in
improving financial inclusion—increasing the share of adults having access to
financial services from 18.9 percent in 2006 to 66.7 percent in 2013 (FSD
Kenya and CBK 2013) and clearing K Sh 192.6 billion (US$2.09 billion)
worth of mobile transactions in March 2014.
• In Brazil, when the government disbursed Bolsa Família grants through
electronic benefit cards, administrative costs were reduced from 14.7 per-
cent to 2.6 percent of the total grant value (Pickens, Porteous, and Rotman
2009).
Transitioning toward a cash-lite society starts with digitizing the payments

channel. Bankable Frontier Associates (BFA 2012) identifies four stages on the
path from a “cash-heavy” society at one end (in which cash is by far the

predominant payment instrument) toward a “cash-lite” society at the other (in

which cash is no longer the most common means of payment), as follows
(figure 2.2):
1. In a cash-heavy society, paper-based instruments (such as cash or perhaps

checks) are the main ones in use.
2. The first shift happens when bulk payers in an economy—such as government,
large employers, or development aid distributors—decide to pay electronically.
3. The second shift takes place as opportunities grow for recipients to spend or
transfer money electronically.
4. Finally, a cash-lite society has been achieved when even the majority of small
payments—usually transactions between people and merchants (person-to-
business [P2B]) for everyday items like groceries—also become electronic.
Figure 2.2 Stages and Shifts from a Cash-Heavy to a Cash-Lite Society
Stage 0 Stage 1 Stage 2 Stage 3

Cash-heavy Bulk payer transition Increasing e-usage Cash-lite
Shift 1 Shift 2 Shift 3
Stage 0 Stage 1 Stage 2 Stage 3

Cash-heavy Bulk payer Increasing Cash-lite
transition e-usage
Flow of electronic
payments Few to many Many to few Many to many
Main payment Mainly paper Mixture: paper and Mainly electronic Almost all electronic
instruments (typically cash; maybe electronic (cards (mobile used for bill (use of mobile and/or
in use some checks) used at ATMs, some payments and card at point of sale
online banking) remittances) through inter-
connected switches)
What is needed Sufficient cash-out Ability of business Pervasive acceptance

to shift to this points; B2P and G2P and consumers to of electronic
level? shifts make cheap electro- payments at POS and
nic payments via mobile phone,
computer, standing compelling financial
order, ATM (P2P, P2B) products
Examples Haiti, Niger Colombia Kenya Canada,

northern Europe,
United States
Source: BFA 2012. © Bankable Frontier Associates (BFA). Reproduced, with permission, from BFA. Further permission required for reuse.
Note: ATM = automated teller machine; B2P = business-to-person; G2P = government-to-person; POS = point of sale; P2B = person-to-business;
P2P = person-to-person.

The BFA (2012) study recognizes that these shifts may not always be
linear; however, each shift can bring significant benefits in terms of cost, reli-
ability, safety, proximity, and even access to new markets and opportunities
for users.
The earlier examples from Brazil, Kenya, and Mexico provide evidence to
amply demonstrate that the use of innovative e-money and digital payment solu-
tions has brought previously excluded people into the formal financial system.
These developments are encouraging for cash-based South Asian countries,
where only 46 percent of adults are financially included.2 Moving away from
cash, therefore, would continue to open access to the formal financial system for
many of South Asia’s unbanked.
Risks in Digital Finance

As the detailed explanation in Part II of this volume (chapters 4–6) suggests,
technology alone does not bring truly transformational outcomes, and technology
is certainly not a “silver bullet.” It is the human element—vision, long-term com-
mitment, cooperation between public and private stakeholders, and trust—at
each stakeholder level that provides the leadership necessary to confront and
overcome barriers to achieving greater levels of financial inclusion for the poor
in a sustainable manner. Although the technology, model, transmission channels,
and products may be new in DFSs, traditional risk management methods of
identifying risks and of quantifying and assessing the likelihood of occurrence
remain true for DFSs as well. The following risks (as discussed in more detail in
the subsections that follow) can derail the successful scaling-up and use of
e-money at all stakeholder levels:
• Political economy risks stem from vested interests that resist the introduc-
tion of disruptive technologies, as well as legal and regulatory risks arising
from lack of governance codes, payments laws, Anti-Money Laundering and
Combatting Funding of Terrorism (AML/CFT) laws, other laws and
regulations.
• Cybersecurity risks may result from the failure to enable institutions with the
capacity to ensure the efficient functioning of systems and protect against
cyberthreats.
• Risks to the payments system may compromise system functions if the service
providers do not adequately understand the digital customer base or the infra-
structure requirements.
• Principal-agent risks must be addressed to minimize revenue losses, fines and
other reprimands by the regulators, fraudulent activities and corruption, and
loss of reputation.
• Risks to customers result not only from inadequate information and under-
standing of e-money but also from lack of consumer protection and ade-
quate redress mechanisms, identity theft, and liquidity-related issues, among
others.

Political Economy Risks

Digital finance is a “disruptive technology,” especially when it is operated by
nonbanks such as technology companies or mobile network operators (MNOs).
Existing regulated financial institutions represent vested interests that may
oppose the introduction of nonbank competitors, whose lower-cost business
model is seen as unfair competition and a threat to existing bank-based opera-
tions and potential profits.3
Although the economics of e-money at the macro level are driven by supply
and demand and the fixed cost of providing infrastructure, political economy
considerations shape the issue of regulating e-payments. Given the influence of
special interests and their collective powers, often the strength and leadership of
the regulator alone determines the success or failure of perfectly legitimate
e-money initiatives. This aspect is highlighted in the case studies.
The regulator’s role in setting and achieving financial inclusion objectives
includes leveling the playing field by introducing regulations that enable entry
and competition by these “disruptors” while putting in place flexible and effec-
tive risk management frameworks to protect consumer funds. This may require
adjusting know-your-customer (KYC) and registration requirements that limit
uptake and use. The outcome substantially affects the business risk to the digi-
tal financial operator because the large, long-term nature of the investment in
infrastructure and customer touchpoints requires widespread customer use for
the venture to be cost-effective and eventually profitable. In some cases, the
unwillingness of the regulator to challenge vested interests—by facilitating
nonbank competitors’ entry—partly explains the slow pace of growth of suc-
cessful e-money deployments.
Cybersecurity Risks
In promoting financial inclusion through digital payment instruments and chan-
nels, policy makers and regulators should also pay attention to external disruptive
elements such as cybercrimes that can compromise databases and the function-
ing of technology-based products and services. Although policy makers have
urged market participants to work together to combat cybercrimes, service pro-
viders in most emerging and developing markets have not taken such calls seri-
ously enough. Nor have they consented to coordinate or cooperate with peers in
reducing costs involved in establishing preventive measures, including legal and
regulatory measures.
In general, high-value payment systems, such as real-time gross settlement
systems, are closely monitored, and service providers observe best practice and
work within rigorous regulatory frameworks. As such, high-value payment
systems are relatively safer than retail payment services, which consist of an
array of payment instruments and channels, mostly digital. Retail service pro-
viders include nonbank institutions, whose commitment to prudent payment
services can be questionable, given the scale and use of ad hoc infrastructure
platforms. Whereas potential damage to a high-value payment system can be
far more severe, given the high volume and value as well as the criticality of

such transactions, retail payment services also require prudence and effective-
ness in surveillance and monitoring.
The Bank for International Settlements Committee on Payments and
Market Infrastructures (BIS/CPMI) 24 guidelines4 are important to ensure
that digital services and devices are safe and do not exclude the poor, as these
guidelines have been prepared to capture operations of all financial market
infrastructure providers and participants. In the local context, the applicability
of some of the existing legal and regulatory frameworks may not be adequate
to cover digital payment services. Hence, policy makers and regulators may
need technical advice and support from international organizations in dealing
with external disruptions such as cybercrime.
Although relatively small in value, a cyberthreat against retail and micro-
level digital finance service providers can have serious consequences for the
poor and vulnerable. The micro-level service providers can be wiped out, while
the clientele can lose their lifetime savings and wealth (if any), even under a
mild form of cyberattack. Unfortunately, because of heavy competition as well
as their small scale and lower profitability, many service providers in developing
countries do not appear sufficiently concerned about the potential impacts of
cyberattacks to observe international best practice cyber protocols and security
guidelines intended to cushion the impact of cyberthreats. In this regard, efforts
are needed by both international and national bodies that deal with cyber-
threats to coordinate and promote the observance of international protocols
and best practice by DFS providers.
Risks to the Payments System

The essence of a payments system is to offer transactional services with the
minimum amount of risk. Digital payments as narrowly discussed in this
study do not introduce new types of risks to the payment system, and digital
payment systems are generally not considered to be systemically important
(with the exception of Kenya’s M-Pesa and the South African Social Security
Agency [SASSA] social grants system). It is important to note that large-
value payments are typically managed by central banks, which have the abil-
ity to address impending risks online on a real-time basis. Other retail
payment systems typically handle transactions between prudentially regu-
lated financial institutions that have their own risk management frameworks,
already vetted by the central banks.
In contrast, new digital technologies often result in large numbers of low-
value transactions, scattered across a country and bringing in a vast number of
players (both payment system providers and their agent networks) with little
if any prudential training, risk management abilities, or understanding of the
types of risks and requirements of handling financial transactions. It is for this
reason that most regulators are often hesitant to bring nonbank operators into
the payment arena. In this regard, there may be a case for establishing an NPC
to play a role in ensuring that such payments risks are minimized. Nevertheless,
the NPCs often are seen to pay scant attention to the retail payment systems

and focus mostly on the large-value systems. The case studies reflect the impor-
tance of developing e-money, as defined in this report, as an integral part of a
country’s national payments framework that is covered by the payments law
and enabling provisions.
Principal-Agent Risks
The principal-agent risk or problem arises because the MNO or DFS provider
must depend upon a network of agents to provide on-the-ground services
directly to the customer. Because of the large geographical distribution of
agents, network management often is employed to monitor and manage agent
performance and ensure that agent incentives are aligned with those of the
principal, the DFS provider. Agents and agent networks introduce new opera-
tional, financial crime, and consumer risks, many of which are due to the physi-
cal distance between agents and the provider or the agent network manager and
the resulting challenges to effective training and oversight. Operational risks
include fraud, agent error, poor cash management by the agent, and poor data
handling. In addition to the financial crime risks of fraud and theft (including
data theft), agents may fail to comply with AML/CFT rules regarding customer
due diligence, handling records, and reporting suspicious transactions. Agents
may also take actions that reduce transparency (for example, on pricing, terms,
and recourse), engage in abusive treatment of customers (including overcharging),
or fail to handle customer data confidentially (McKee, Kaffenberger, and
Zimmerman 2015).
Risks to the Customer

At the consumer level, evidence from research conducted in 16 countries by
McKee, Kaffenberger, and Zimmerman (2015) reveals information on customers’
perceptions and experiences with risks and the ways in which these risks harm
their trust, uptake, and use of the services. Although customers highly value and
benefit from many basic DFSs, many users are not only new to both formal
finance and technology but also live precarious financial lives that allow little
room for error.
Also revealed is strong evidence that providers are actually not realizing the
full potential of growing numbers of DFS deployments. In many cases this is
because customers experience challenges or problems that erode their trust and
therefore limit their use of DFSs—often to over-the-counter (OTC) transactions,
which do not require an account. When nonusers (potential customers) observe
friends and family struggling with digital platforms, they frequently conclude
that the services are simply too risky. The report identified seven key risk areas
for customers of DFSs (box 2.2).
Such risks can translate into loss of savings, indebtedness, loss of identification,
and loss of faith in the financial system, leading to reexclusion from the financial
system. Practical steps undertaken to protect customers from the risks of digital
finance and to facilitate consumer trust, uptake, and use of e-money are addressed
in the case studies at different stakeholder levels.

Box 2.2 Doing Digital Finance Right: The Case for Stronger
Customer Risk Mitigation
Research in 16 countries concerning customers’ perceptions of and experiences with digital
financial services (DFSs) revealed seven perceived risk areas:
• Inability to transact due to network or service downtime. This most commonly cited risk area
can lead to risky customer behaviors such as leaving cash with an agent to conduct a trans-
action later when the network is back up. It also presents challenges if customers need
money urgently and cannot cash out until the network resumes.
• Insufficient agent liquidity. This is the second most common risk-related area that com-
monly prevents customers from transacting and accessing their money. This problem
particularly plagues bulk payment recipients (such as G2P [government-to-persons]
recipients): because many receive their transfers all on the same day and want to cash out
immediately, agents struggle to meet liquidity demands. The recipients are often among
the poorest in a country, and the extra fees and the delay in receiving their benefits can
seriously affect their ability to meet basic needs.
• Complex and confusing user interfaces. This customer risk is exemplified by the difficult-to-
resolve experience of a user who sends money to a wrong number, which often also
results in financial loss. Difficulties with the menu also cause many customers to seek
assistance conducting transactions, requiring them to share private information (such as
their personal identification number [PIN]) with an agent, family member or friend—
exposing them to potential fraud by the person providing help.
• Inadequate provider recourse. Complaints and dispute resolution options are unclear, caus-
ing the customer to lose time, money, and mobile-phone airtime to either travel to cus-
tomer care centers or wait on hold for call center staff who may or may not be able to solve
the problem.
• Nontransparency of fees and other terms. This issue prevents customers from fully under-
standing the details of services and leaves them vulnerable to agent misconduct and
price fraud.
• Fraud perpetrated on customers. Customers can experience fraud at the hands of provider
employees or external fraudsters who use “social engineering” scams such as phony pro-
motions to obtain money or information from unsuspecting customers.a Agents can also
perpetuate fraud by charging unauthorized fees.
• Inadequate privacy and protection of customers’ personal data. Disclosure of data-handling
practices is often weak, with details available only on a website to which few consumers
have access and in “legalese” that is difficult to understand.
Source: McKee, Kaffenberger, and Zimmerman 2015.

a. “Social engineering scams” refers to scams whereby a hacker tricks the target themselves, or perhaps an unwitting
customer service agent, into revealing information that gives the hacker access to victims’ passwords or accounts.

Notes
1. Data from the Poverty Topic Overview, World Bank, http://www.worldbank.org/en
/topic/poverty/overview. US$2 a day represents the median poverty line of d
eveloping
countries in 2005 purchasing power parity (PPP) terms (Chen and Ravallion 2010).
2. South Asian financial inclusion data from the Global Findex Survey 2014, http://
datatopics.worldbank.org/financialinclusion/.
3. This opposition persists despite the fact that the target clientele for digital payments
are generally the unbanked and the poor, whose market needs, multitude of small
transaction values, and remote locations are extremely costly and not at all interesting
to traditional financial institutions.
4. In June 2014, the Committee on Payment and Settlement Systems (CPSS) was
renamed as the Committee on Payments and Market Infrastructures (CPMI) under a
new charter. Hence the BIS/CPSS 24 guidelines issued in 2012 (BIS and IOSCO
2012) were renamed the BIS/CPMI 24 guidelines.
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Government’s Shift to Electronic Payments.” Evidence Paper, Better Than Cash
Alliance, New York.
BFA (Bankable Frontier Associates). 2012. “The Journey toward ‘Cash Lite’: Addressing
Poverty, Saving Money, and Increasing Transparency by Accelerating the Shift to
Electronic Payments.” BFA study for the Better Than Cash Alliance, Somerville, MA.
BIS and IOSCO (Bank for International Settlements and International Organization of
Securities Commissions). 2012. Principles for Financial Market Infrastructures. Basel:
BIS; Madrid: IOSCO.
Bruno, P., F. Istace, and M. Niederkorn. 2014. “The Future of Global Payments.” Excerpt
from “Global Payments 2014: A Return to Sustainable Growth Brings New
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Chen, S., and M. Ravallion. 2010. “China Is Poorer than We Thought, but No Less
Successful in the Fight against Poverty.” In Debates on the Measurement of Global
Poverty, edited by S. Anand, P. Segal, and J. Stiglitz, 327–40. Oxford: Oxford University
Press.
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Directive 2009/110/EC of the European Parliament and of the Council of
16 September 2009. Official Journal of the European Union L 267: 7–17.
———. 2012. Virtual Currency Schemes. Frankfurt: ECB.
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Report of the Global Payment Systems Survey 2010, World Bank, Washington, DC.

CHAPTER 3
Stakeholders in Digital Financial

Inclusion
Introduction
In examining how financial inclusion can be advanced through the use of digital
channels, four levels of stakeholders that are essential to financial inclusion
pathways can be identified:
• Macro: policy makers, regulators, and donors

• Meso: organizations that support financial services providers
• Micro: digital financial services (DFSs) providers
• Customer
Digital innovations that can influence financial inclusion through these

pathways include e-money, mobile-phone access to e-wallets or bank accounts,
card systems, near-field communication (NFC)–enabled systems, agent and cor-
respondent financial services, remittances, and government-to-persons (G2P)
and person-to-government (P2G) payments through partially or fully elec-
tronic means. To determine which innovations in the digital space can enhance
financial inclusion, it is important to identify the ways in which customers—as
well as micro-, meso-, and macro-level actors—can be influenced and leveraged
to achieve greater financial inclusion using innovative digital means and path-
ways. To that end, each level has a role to play in promoting digital financial
inclusion:
• Policy makers must provide leadership and vision in setting the policy agenda,
and regulators should develop an enabling, nonprohibitive regulatory environ-
ment that may be iteratively layered as the market matures.
• Enabling institutions should develop a rich ecosystem and infrastructure in
which digital finance can grow.

54 Stakeholders in Digital Financial Inclusion
• DFS providers should develop and operate various digital solutions and options
that create, preserve, and enhance positive value propositions for the custom-
ers who are predominantly from the base of the pyramid.
• Customer preferences should be identified, and customers must be given the
opportunity to acquire financial education to better understand how they can
benefit from financial inclusion and use digital financial services to manage
their needs as well as access other economic opportunities in a much more
cost-effective manner.
Macro-Level Stakeholders: Policy Makers, Regulators, and Donors

Macro-level stakeholders can be defined as national policy makers, donors,
funders, national regulatory and supervisory bodies, and even international
knowledge exchange and advocacy bodies. The goals of most of those listed
are either to perform or direct micro- or meso-level interventions, or to influ-
ence national governmental players. From the donors’ perspective, macro-level
interventions are the second-most funded interventions after micro-level.
Indeed, many multilateral donors have separate departments to support
public (macro) and private (micro and meso) sector development.
Governments as policy makers are the key players in driving the national
digital financial agenda, and they oversee coordinated policy actions. In some
developing countries today, it is heartening to see government agencies them-
selves developing policies, drafting legislation, sharing knowledge among them-
selves (in organic South-South knowledge exchanges), and achieving such levels
of innovation that donors can be seen trying to keep up. In such instances, gov-
ernments are seen to be managing the transition to DFSs not only by mandating
but also by consciously supporting the transition.
Regulators are macro-level stakeholders whose responses to financial innova-
tion need careful attention. From the point of view of financial systemwide sta-
bility, the apprehensions of central banks and regulators should be appreciated
but should not inhibit the much-needed promotion of financial inclusion. It is
important for central banks and regulators to permit and even facilitate techno-
logical innovations insofar as they promote financial inclusion and poverty reduc-
tion, while ensuring that they do not outstrip or circumvent prudential
regulations to maintain the safety of the financial system and customers’ funds.
An enabling regulator should focus on policies and strategies that target financial
inclusion and broaden financial access through the entry of new players, while
regulating risks associated with lower-cost intermediaries entering the financial
space.
However, in a highly dynamic, innovative digital space, imperfect knowledge
about digital products and systems leaves regulators permanently in catch-up
mode. As digital systems evolve and new players enter the payment space, new
kinds of risks emerge, especially outside the banking system. Concerns about
Anti-Money Laundering and Combatting Funding of Terrorism (AML/CFT)
and consumer protection issues have to be addressed quickly and efficiently.

Stakeholders in Digital Financial Inclusion 55
Hence, regulators have to be proactive while avoiding regulatory overkill that

might stifle financial innovations that can expand financial inclusion of the
unbanked and underbanked masses.
Hence, central banks and regulators should step up their supervision and over-
sight capabilities rather than refuse approvals or use delaying tactics to prevent
nonbanks—mobile network operators (MNOs), in particular—from entering
into payment spaces. Furthermore, they should offer technology-based payment
solutions to deal with basic payment transactions (such as cash-in/cash-out in
domestic remittances), bill-pay facilities, and similar transaction services as an
important stepping-stone toward entering the formal financial system.
Meso-Level Stakeholders: Enabling Institutions

Meso-level stakeholders do not provide direct financial services but strengthen
and support mainly micro-level players. They typically provide information,
support services, and infrastructure and include the following:
• Technical services providers for consumer and financial institution training,

consulting, and product support, potentially for each product type
• Industry research organizations such as research institutes and universities,
consulting firms, and rating agencies
• Policy advocates, industry associations, and networks (local, regional, and
international)
• Technology service and payment service providers for hardware, software, and
information technology (IT) technical support for payments systems;
automated teller machines (ATMs); core banking software; and mobile
banking
• MNOs that provide services on behalf of micro-level players
• Agents, such as agent networks of MNOs, because although they are the
customer touchpoints for mobile money, they act on behalf of MNOs in a sup-
porting role
Not all of these players participate in developing digital finance systems in

each country. Their involvements will vary with the level of development of the
systems, donor activities, regulatory and policy structures, and so on. They sup-
port private sector operators in setting up and managing new systems, as well as
strengthen the existing micro-level actors to be more financially sustainable and
sophisticated (and thereby offer better service to their clients). They also influ-
ence the micro-level players to extend their client base and provide knowledge,
training, and information on national and international best practice. Meso-level
stakeholder support and participation in the development process will also
reduce market distortions and enhance the efficiency and effectiveness of the
micro-level stakeholders. In addition, they are well positioned to provide finan-
cial education services to the consumers and can play an advisory role to the
macro-level stakeholders as well.

56 Stakeholders in Digital Financial Inclusion
The 2012 Bank for International Settlements Committee on Payments and

Market Infrastructures (BIS/CPMI) 24 guidelines for financial management
information systems (FMISs) recognize the critical importance of all service pro-
viders in payment system development and the need for compliance with such
guidelines for safety, efficiency, reliability, and affordability of payment services
(BIS and IOSCO 2012). In a way, these guidelines bring market discipline—a
lacuna in the payment landscape for some time—to all payment system
providers.
Although meso-level service providers and stakeholders are also expected to
observe standards and market ethics, the regulators are expected to monitor
observance through effective surveillance systems. Some countries in Asia
(Malaysia and Singapore) have already complied with many of the CPMI
guidelines—as seen from the endorsements received from the International
Monetary Fund’s and World Bank’s Financial Sector Assessment Program evalu-
ation teams—while other countries seem to lag behind. It is important that
national payment councils in other countries take the initiative to educate
meso-level service providers on the importance of observing these best practices
to develop healthy payment systems (for retail payments, in particular) that offer
numerous benefits in promoting financial inclusion and access to finance.
Micro-Level Stakeholders: Institutions Offering Digital Solutions

Micro-level stakeholders are entities that provide DFSs to customers. They include
banks and other licensed financial institutions; nonbank financial institutions that
are authorized to operate mobile money solutions (typically MNOs); authorized
e-money issuers; and other payment service providers.
It is important to have a national agenda on digital financial inclusion so that
micro-level service providers are able to play various roles: fill gaps in the market;
provide services to underserved areas via relaxed regulatory hurdles, moral
suasion, quotas, or subsidies; offer additional product offerings through strategic
partnerships and product developments; and strengthen their institutional
capacity to increase institutional sustainability and sophistication. The goal is
broader outreach, better-quality products, improved customer interactions, and
sharing of national and international best practices to facilitate institutional
self-improvement.
Often, digital financial inclusion strategies stall because some of these
micro-institution types that have touchpoints with financially excluded people
are overlooked. E-wallets and mobile-phone access are two frequently neglected
channels. Micro-level service providers should be persuaded to use less cash
and paper-based instruments, and medium-term targets should be set for the
purpose.

Stakeholders in Digital Financial Inclusion 57
Customer-Level Stakeholders: Users

Customers are the people and institutions that use the DFS and payment
services. Sometimes, when financial products or solutions fail, it is because they
are supply-driven—designed to deliver industry perceptions of what customers
need rather than serving an unmet need expressed by actual customers. Focusing
on customer convenience and efficiency will guarantee a successful digital finan-
cial deployment. It is, therefore, important for stakeholders to understand their
customers’ true perceptions, needs, and beliefs.
Although the pathways to financial inclusion start with the first customer
touchpoint, which is usually based on a specific need, there is no guarantee that
just because a customer had previously used a particular financial service, he
or she will then go on to learn about or obtain access to others. Use and trust in
the reliability, convenience, and safety of the service needs to be promoted to
maximize its chances of success. It is important to engage community-level out-
reach, especially in rural communities, and to provide financial education
programs. It is also important to understand that, in many countries, first-time
users commonly prefer to use over-the-counter transactions.
Service providers must understand the needs of these populations, build-
ing trust and facilitating their familiarity with digital solutions in order to
convert them into account holders. Although customers may gradually give
up their predilection for cash- and paper-based payment instruments, effec-
tive incentives—including price incentives—may be provided to accelerate
progress toward the goal of paperless payments in the interest of financial
inclusion.
Bibliography
BIS and IOSCO (Bank for International Settlements and International Organization of
Securities Commissions). 2012. Principles for Financial Market Infrastructures. Basel:
BIS; Madrid: IOSCO.

P A R T II
Critical Enablers That Are

Game Changers in
Successful E-money
Deployments
Transitioning to digital payments will require well-supported evidence that doing so is

in the interest of all participants—businesses, governments, financial institutions,
merchants and consumers. Investment will be required to update systems to replace
paper payments and facilitate electronic processing of invoices. None of this will
happen without first presenting a tangible case for future success.
—Canadian Task Force for the Payments System Review,
“Going Digital: Transitioning to Digital Payments”
The main reasons why people lack access to formal financial systems seem
to be similar across the globe. Those reasons include poverty, lack of proximity,
cost, not having documentation or identification, lack of financial literacy, low
acceptability, risk aversion, and low levels of trust. Cultural factors also play an
important role. Banks and most formal financial institutions are unwelcoming to
the poor, whose numerous and tiny transactions would be unacceptably costly
for most formal institutions to handle. Even microfinance institutions require a
group dynamic for savings and lending to the poor.
The technology for going digital and enhancing financial inclusion is sound
and proven, the concept is appealing to both policy makers and donor com-
munities, and service providers have found it to be a viable business case.

6 0 Critical Enablers That Are Game Changers in Successful E-money Deployments
However, successful adoption and deployments are still few and far between.
To date, cash remains the preferred medium of transactions in developing
countries and even in many developed countries. So what is holding back
application of digital systems and e-money for the delivery of affordable,
accessible, and appropriate financial products, especially to people who are
excluded from or underserved by formal financial markets?
Almost all of the transformational technologies are proven and available as
off-the-shelf solutions that need little or no customization, at affordable prices.
Hence, it is reasonable to expect that successful deployments—such as the M-Pesa
mobile money platform in Kenya and social grants transferred through a biometric-
enabled debit MasterCard in South Africa—could easily be replicated. However,
such expectations have often met with disappointment when restrictions,
insufficient underlying conditions, or other challenges constrained attempted
deployments from achieving the kind of traction shown by those success stories.
Digital finance and payment services have transformed the lives of many
people across the globe. The Mobile Economy 2015—a report by the London-
based Groupe Speciale Mobile Association (GSMA)—counted 255 live mobile
money services across 89 markets as of December 2014. The number of regis-
tered mobile accounts also grew to reach 299 million, with a majority of the
accounts in Sub-Saharan Africa (figure II.1).
Nevertheless, the full potential of mobile money deployments remains
untapped in some regions, such as Latin America and South Asia, partly because
of regulatory barriers. Realizing the role that nonbank mobile money providers
can play in fostering financial inclusion and economic growth, an increasing
number of regulators are establishing new regulatory frameworks for mobile
money. In 47 out of 89 markets where mobile money is available, regulation now
allows both banks and nonbanks to provide mobile money services in a sustain-
able way, the GSMA report found.
The main purpose of Part II of this volume is to understand which factors
enable successful deployment of digital money initiatives and why so few coun-
tries have succeeded in becoming fast movers with tremendous results. The study
investigates the extent to which barriers are unique to each market, e-money
deployment mechanisms, client segments and country context, and what lessons
can be applied more generally.
Through analysis and examination of the case study countries and their
respective e-money deployments, Part II of this volume identifies a set of critical
enablers that have shaped the successes by unlocking value that allows for trans-
formational outcomes. “Critical enablers” are game changers in enhancing the
effectiveness and efficiency of e-money schemes in a transformative manner.
They could be either general social enablers or program-specific enablers that
help overcome major barriers to service proliferation. The lessons learned can
benefit countries that plan to launch or are already in the process of launching
similar initiatives, by identifying early implementation priorities.
At the macro level, such enablers include progressive policy leadership and an
enabling, nonprohibitive regulatory environment. At the meso and micro levels,

Critical Enablers That Are Game Changers in Successful E-money Deployments 61
Figure II.1 Number of Active Mobile Money Services Worldwide, by Region, 2001–14
260 255
240 232
220
200
180 174
Number of active mobile money services
160 As of December 2014, there

were 255 live mobile money
services in 89 markets.
140
120 116
100
80
66
60
38
40
20 16
10
4 5 6
1 1 1
0
2001 2002 2003 2004 2005 2006 2007 2008 2009 2010 2011 2012 2013 2014
East Asia and Pacific South Asia Latin America

Sub-Saharan Africa Middle East and North Africa Europe and Central Asia
Source: Groupe Speciale Mobile Association (GSMA), The Mobile Economy 2015 (London: GSMA, 2015). © GSMA. Reproduced, with permission,
from GSMA; further permission required for reuse.
key factors include innovative use of infrastructure; an ecosystem characterized

by interoperability; effective agent network management; mobile money add-on
applications; and biometric-enabled, card-based grant payment disbursement
systems. A basic requirement on the customer-level supply side is the ability to
uniquely identify clients.
The case studies in this volume are used to illustrate how these factors have
enabled some countries to rise above the rest in terms of ubiquity, speed, lower
costs, simplicity, efficiency, and safety of their respective e-money deployments.
In some cases, however, failure to address these key elements has hindered them
from reaching the full potential of e-money deployments.

CHAPTER 4
Policy Leadership and Enabling

Regulatory Environments
Introduction
According to World Bank 2014 Global Findex data, 2 billion largely poor people
worldwide lack access to a financial transaction account, of which 30 percent
live in three South Asian countries—Bangladesh, India, and Pakistan.1 As such,
governments and policy makers are prioritizing strategies and policies to make
poverty reduction and economic development a reality, especially for the rural
poor. Policy makers have to broaden their scope and commitment to make mean-
ingful investments in responding positively to market innovations that open up
new ways of delivering financial services. In doing so, while enabling inclusion
strategies, policy makers will have to also ensure compatibility with financial
stability and consumer protection.
Achieving financial inclusion requires greater emphasis and understanding
of the poor and rural markets to establish a suitable enabling environment.
Peake (2012) sums this up as follows:
The rural customer segment has distinct characteristics compared with its urban
counterpart. In most countries, agriculture and related activities represent a signifi-
cant percentage of rural incomes, which typically result in seasonal flows and ebbs
of income. Rural actors ... face greater constraints in terms of distance, travel times
and infrastructure development ... so trust plays a huge role in engaging with them.
Rural areas are also known to have lower literacy levels, lower mobile handset pen-
etration rates and poorer network coverage. Finally, rural consumers are typically
slower to adopt new brands and products but are also slower to give them up.
The factors cited by Peake apply broadly to people at the base of the pyramid,
regardless of their geographical location. This understanding drives the policy
leadership and regulatory efforts in certain developing countries to design and
create policy and regulatory frameworks for innovative strategies to include the
poor—or at times to allow for market developments in advance of regulatory or
policy reforms.

64 Policy Leadership and Enabling Regulatory Environments
To effectively harness the transformative potential of innovative digital

financial products, mechanisms, and transactional networks, numerous legal
and regulatory issues have to be addressed early on, including acceptable
identification and validation of customer information; consumer protection
in terms of information, funds, and dispute settlement processes; and how
to apply legal and regulatory standards and guidelines. Sensible policy mak-
ers and regulators do not discourage these interventions by boxing them-
selves into preconceived regulatory mind-sets that overemphasize risk and
returns or conform to conventional existing frameworks. Regulators in the
more successful cases are open-minded and allow markets to come up with
solutions that are workable, by allowing for pilot efforts that can be scaled
up and then ensuring that broader regulatory parameters are appropriately
adapted.
Regulatory Balance in Financial Innovation

Financial sectors are essentially a means to an end, facilitating financial inter-
mediation to serve the real economy. Regulators of financial systems are
entrusted with maintaining financial system stability, protecting consumer
rights, and ensuring orderly market conduct. Although innovative financial
systems and products have the potential to more efficiently allocate resources
and support growth and development, certain innovations can bring in negative
externalities and disrupt markets. As in the case of the global financial crisis,
there is a risk of regulators scrambling to ring-fence the systems with draconian
regulations.
An ideal regulatory balance would involve making complete information
available for regulators to decide well in advance on the prudential norms
needed to achieve safety and soundness, while market participants are allowed
to be as innovative as they want to be. In reality, innovations may appear sud-
denly, and regulators may have to make a judgment call based on limited
information.
With respect to policy leadership and an enabling regulatory environment, the
analysis of the case study countries will answer key questions, as follows, involv-
ing prime examples of leadership:
• Why the Central Bank of Kenya (CBK) allowed M-Pesa to launch in a regulatory
vacuum
• Why India’s Jan Dhan Yojana program has the potential to be the flagship
financial inclusion plan of the decade
• How Thailand’s joint policy and regulatory vision contributes to enhanced
financial inclusion in the country
• How Sri Lanka ensures that regulations keep pace with technological advance-
ments that drive market developments
• How proactive policy leadership could enable two early movers—the
Philippines and Maldives—to reach their full potential

Policy Leadership and Enabling Regulatory Environments 65
Kenya: Leadership Lesson from the Central Bank of Kenya

The best example of an open-minded regulatory approach that led to transfor-
mative changes in poor people’s lives is Kenya’s M-Pesa mobile money platform.
While much of the literature tries to explain why M-Pesa is hugely successful in
Kenya and less so elsewhere—a one-of-a-kind success story that cannot readily
be replicated—it is important to understand the key concepts that made M-Pesa
a success.
Launch and Early Years of M-Pesa

The regulator’s initial decision to allow the scheme to proceed on an experimen-
tal basis, without formal approval, was critical. Before the launch of M-Pesa in
2007, the CBK was aware of the woeful status of formal financial outreach in
Kenya, which, at 19 percent, was highlighted by the FinAccess National Survey
in 2006 (figure 4.1).
Soon after, when approached by the mobile network operator Safaricom,
CBK realized the potential of leveraging mobile-based payments to enhance
financial inclusion. CBK diligently reviewed all aspects of allowing mobile
money in Kenya, while being mindful of the risks that this yet-unknown model
might bring. Based on the details of M-Pesa’s risk assessment and mitigation
structure as well as opinions on the legality of allowing M-Pesa to function, CBK
satisfied itself that
• M-Pesa could legally operate mobile-money business, and in doing so, it would
not be conducting banking business;
Figure 4.1 Financial Access Strand in Kenya, 2006

Formal other
Formal Informal Excluded

7.5
18.9 35.2 38.4
0 20 40 60 80 100
Percent
Source: FSD Kenya 2007.

Note: The figure reflects FinAccess 2006 Survey respondents who were ages 18 and older. The “Access Strand”
is a graphical method (routinely used in FinScope Surveys in Africa) of placing each survey respondent along
a continuum of access, depending on use of services by category. “Formal” refers to the share of the
population using a bank, banklike institution, Postbank, or an insurance product. “Formal other” refers to the
share using semiformal services from nonbank financial institutions (such as microfinance institutions) not
bank services. “Informal” refers to those using only informal financial service providers such as rotating
savings and credit associations (ROSCAs) and groups or individuals other than family and friends. “Excluded”
refers to those using no institutionalized financial services.

• The risk management structure was adequate for consumer protection; and
• The pooled trust account in a reputable commercial bank, where money
collected by Safaricom’s agents is deposited, ensured that there would be no
intermediation and also satisfactorily addressed the consumer credit risks.
CBK realized that, under the existing laws such as the Banking Act, they
could not formally license or directly regulate the nonbanking institution on
money transfer. However, it had full supervisory oversight of the pooled trust
accounts that M-Pesa would hold with the commercial banks. Furthermore,
the CBK Act (which established CBK in 1966) granted CBK broad powers
to establish, regulate, and supervise payment and settlement systems. At the
time CBK was considering the M-Pesa proposal, the National Payment
Systems bill was still in draft mode. Instead of blocking the launch of M-Pesa
until the National Payment Systems bill was passed, CBK issued a letter of
no objection to Safaricom with conditions for consumer protection, preven-
tion of money laundering, and regulatory reporting requirements.
M-Pesa was launched in March 2007 (see box 4.1). To its credit, CBK asked
Safaricom to undertake two comprehensive technical assessments by Consult
Hyperion2 to evaluate the operational risk and efficiency of the M-Pesa plat-
form; cleared the legal issues; and, once M-Pesa was launched, got a demand-
side survey done through the Financial Sector Deepening (FSD) Kenya Trust in
2008. Although Kenya was not yet compliant with the Financial Action Task
Force’s (FATF) Anti-Money Laundering and Combatting Funding of Terrorism
(AML/CFT) guidelines, Vodafone (the majority shareholder of Safaricom,
which developed M-Pesa) ensured that the platform complied with its own
international standards as well as with Kenyan legislation.
CBK came under tremendous pressure—from a disgruntled banking
community, the political leaders, and the media—for allowing a nonbank to enter
the payment space. The commercial banks were hostile to what they perceived as
Safaricom’s entrance into their field of financial service delivery. This hostility was
exacerbated by the fact that the banks were not permitted to commence agency
banking until 2010. However, having done its due diligence, CBK was able to
convince the political leaders of the merits of using this unconventional route to
enhance financial inclusion, and also used the opportunity to highlight the gaps
in the regulatory system due to not yet having payments laws in place.
Thereafter, CBK and the Ministry of Finance issued joint statements
informing the public of the due diligence process conducted by CBK and also
gave assurance on the operational safety of M-Pesa. CBK relied on moral sua-
sion and mutual cooperation with Safaricom. The CBK’s National Payment
System Department deliberately focused its oversight of M-Pesa—and of all
subsequent mobile money services—on the integrity of the information technol-
ogy (IT) platform and the service delivery system, and it continually monitors
transaction flows and operations. Soon after M-Pesa’s 2007 launch, CBK also
conducted an audit of M-Pesa to confirm that M-Pesa is not a savings instrument.

Box 4.1 M-Pesa: A Backstory and an Alternative Perspective

Mobile network operator Safaricom was formed in 1997 as a fully owned subsidiary of
Telkom Kenya—Kenya’s sole provider of landline phone services. In May 2000, Vodafone Group
PLC of the United Kingdom acquired a 40 percent stake and management responsibility
for the company. In 2002, Safaricom was converted to a public company while the govern-
ment held 60 percent of the shares, 25 percent of which would be auctioned off in 2008 on
the Nairobi Securities Exchange.
The M-Pesa story begins with the U.K. Department for International Development’s
(DFID) formation of the FSD Trust in 2000. FSD awarded funds to Vodafone,
which partnered with its affiliate Safaricom in Kenya to conduct workshops with
financial institutions to identify the barriers to increasing access to financial services.
A partnership was formed between a microfinance institution (MFI), a bank, and
Safaricom to develop a pilot to enable microfinance loans to be paid with the help of
mobile phones. (Cook 2015)
Funding from DFID through a competitively awarded challenge grant allowed a pilot to
be launched taking a “test and learn” approach. In 2007, there were no regulations applicable
to a mobile money service. The Central Bank of Kenya (CBK) took the brave step of allowing the
innovation to move ahead, taking a risk-based approach. M-Pesa was launched in March 2007
focusing on its core money transfer function, marketed as “Send Money Home.”
It is suggested that the government’s bold regulatory decision to allow the launch of
M-Pesa without the tight regulatory restrictions found in many other countries was driven by
the following key factors:
First, the business model had been thoroughly piloted and tested as a project under the
regulatory radar with flexible funding from FSD Trust.
Second, the government was the majority shareholder in the company that stood to ben-
efit and had a dominant market position, meaning that
• Risk to the company from failure of the program was relatively small;
• Risk to the financial system likewise was relatively small, since the government was a
backer; and
• Competitors were not in a strong position to lobby against the dominant, government-
owned company—and they probably had no idea that M-Pesa would be so successful.
That CBK was willing to take a risk was also quite likely a legacy of the success of K-Rep
Bank as a microfinance commercial bank, which had helped change attitudes in CBK as it
supported legislation enabling MFIs to be licensed separately from banks.
Sources: Cook 2015; Safaricom information from Wikipedia, https://en.wikipedia.org/wiki/Safaricom.

All these good practices have enabled CBK to develop the necessary robust regu-
latory framework subsequent to commencement of M-Pesa’s actual operation.
M-Pesa’s Impact on Financial Inclusion

CBK’s willingness to step outside of its comfort zone in the interest of a worthy
public cause has unlocked great opportunities for poor people to better manage
their money. Today, the financial inclusion rate in Kenya has risen to a remarkable
75 percent,3 and M-Pesa is not the only operator active in the market. However,
there are many things Kenya can do even now to ensure that the system func-
tions smoothly, more affordably, and with a more level playing field.
According to the 2013 FinAccess Survey (FSD Kenya 2013), financial access
is moving away from reliance on the informal sector, whose net addition to
financial inclusion over formal financial institutions fell from 33 percent in 2006
to less than 8 percent in 2013 (figure 4.2).
Furthermore, the FinAccess Survey shows that mobile service provider use
has achieved astoundingly rapid growth in penetration, from 0 percent of the
population in 2006 to around 62 percent in 2013 (figure 4.3).
Figure 4.2 Financial Access Trends in Kenya, 2006–13
0.8
2013 32.7 33.2 7.8 25.4
2009 22.1 15.0 4.2 27.2 31.4
2006 15.0 4.3 8.1 33.3 39.3
0 20 40 60 80 100
Percent
Formal prudential Formal registered Excluded
Formal nonprudential Informal
(including mobile money)

Note: “Formal prudential” access refers to individuals whose highest reported financial services use is through
providers that are prudentially regulated and supervised by independent statutory regulatory agencies.
“Formal nonprudential (including mobile money)” access refers to those whose highest reported financial
services use is through providers subject to nonprudential oversight by regulatory agencies or government
departments or ministries with focused legislation. “Formal registered” access refers to individuals whose
highest level of financial services use is through providers registered under a law or government direct
interventions. “Informal” access refers to individuals whose highest reported financial services use is through
unregulated forms of structured provision (FSD Kenya 2013).

Figure 4.3 Use of Financial Services in Kenya, by Type, 2006–13
80
70
Percentage of population
61.6
60
50
39.1
40
29.2 29.5 27.7 28.4
30
20 17.1
13.5 13.5
9.3 9.1
10
1.8 3.5 3.5
0 0.0
Bank usage SACCO usage MFI usage Informal group MFSP usage
usage
2006 2009 2013

Note: MFI = microfinance institution; MFSP = mobile-phone financial service provider; SACCO = savings and credit cooperative.
The Regulator’s Journey since M-Pesa’s Launch

The National Payment System Act came into effect in 2011. The focus of the
Act’s regulations was, however, on the large-value, high-systemic-risk payments
through the CBK’s Kenya Electronic Payment and Settlement System. CBK
pretty much left the retail payments system to self-regulate.4 Under the 2011
Act, CBK recognized and established a payment system management body with
delegated powers to manage risks and governance issues and to support develop-
ment of the national payment system.
In August 2014, a formal legal framework for mobile money was finally issued
as the “National Payment System Regulations, 2014”5 more than seven years after
CBK’s no-objection letter that facilitated the launch of M-Pesa. To help put
things in perspective, during the 2014/15 fiscal year, M-Pesa had over 15 million
active users transacting K Sh 4.2 trillion (US$4.32 billion) through the mobile
money platform, equivalent to 42 percent of Kenya’s gross domestic product
(GDP). There is no question that if CBK had decided to uphold the status quo
in 2006, most average Kenyan people would still be without access to the main-
stream financial system.
India: Jan Dhan Yojana Flagship Financial Inclusion Plan
If crores of Indians are outside the ambit of organized financial services because
they do not have a bank account even after 68 years of independence, I call it
financial untouchability. Gandhiji ended social untouchability, it is our mission
to eradicate this kind of untouchability now to fight poverty.
—Narendra Modi, prime minister of India, at the launch of
Jan Dhan Yojana, August 28, 2014

Financial Inclusion Efforts in India

Financial inclusion is not a new concept to India. With over 1.25 billion peo-
ple, financial inclusion has a special meaning, as over one-third of the world’s
poor live in India. Both the government and the Reserve Bank of India (RBI)
have been pursuing this goal over the past several decades through building the
rural cooperative structure in the 1950s, the nationalization of the banks in the
1960s, and the expansion of bank branch networks in the 1970s and 1980s.
These initiatives have paid off in terms of a network of branches across the
country: by March 2013, there were also 93,488 Primary Agricultural Credit
Societies in the country, 31 State Cooperative Banks, and 372 District Central
Cooperative Banks (Sivaiah and Naidu 2015). Scheduled commercial banks also
reached out into rural areas, with 49,571 branches and 504,142 Banking
Correspondents in villages by 2015 (Patel 2016).6 The major institutional inno-
vation in India for expanding financial system access and use for the poor and
marginalized sections of the population is the program that links banks with
self-help groups.7
Yet, the extent of financial exclusion has remained staggering. Out of the
1.7 million total habitations (distinct clusters of houses at the subvillage level) in
the country, only about 30,000 had a commercial bank branch as of 2012
(Chakrabarty 2012). Only about 40 percent of the population across the country
had bank accounts. The proportion of people having any kind of life insurance
coverage was as low as 10 percent, and the proportion having non-life insurance
was an abysmally low 0.6 percent. People having debit cards comprised only
13 percent and those having credit cards only a marginal 2 percent.
As of 2011, only 46 percent of India’s small and marginal farmers were able
to obtain credit from either institutional or noninstitutional sources (Patel 2016).
Even though RBI has mandated agriculture credit to be around 18 percent of the
adjusted net bank credit, commercial bank data show that it was around 10.5
percent in 2013. Out of this, only about 4.5 percent reached the rural farmers,
while the rest went to urban and suburban agriculture projects (Rao 2015).
The rating agency CRISIL, a Standard & Poor’s company, has a financial
inclusion index called the Inclusix. The all-India Inclusix score is 40.1
(which means that about 40 percent of the country has access to formal
banking services). There are wide variations, from 62.2 percent in the
southern region to 28.6 percent in the eastern region (Wharton School
2014). The 50 bottom-scoring districts have just 2 percent of the country’s
bank branches (CRISIL 2013).
The high-powered Nachiket Mor Committee on Comprehensive Financial
Services for Small Businesses and Low-Income Households, set up by the RBI,
found that 60 percent of the rural and urban population did not have a func-
tional bank account (RBI 2014). One of the committee’s recommendations was
to set up a vertically differentiated banking system.
Accordingly, guidelines were issued by RBI and licensing effected for two new
types of finance institutions in unbanked and underbanked regions: (a) “payments
banks,” which focus on remittance and payment services and accept demand

deposits (current and savings) but cannot provide credit facilities; and (b) “small
finance banks,” which can offer a wide range of deposit (current, savings, and
time deposits) and credit products, primarily microcredit, and also provide pay-
ment and remittance services.
The importance of this yet-to-be-proven payments bank concept is that it
enables institutions with wide-reaching agent networks such as mobile net-
work operators (MNOs) to offer payment transactions in a scaled-up fashion.
Their challenge would be to match the already low-cost alternative transmis-
sion mechanisms that thrive in India and to attract customers to deposit with
them. At some point in time, regulators will have to rethink the prohibition
on payment banks offering credit products. The basic premise is that there
has to be a business use case for them to proliferate.
Pradhan Mantri Jan Dhan Yojana: A Big Bang Approach to

Financial Inclusion
Two weeks after his Independence Day address to the nation on August 15,
2014, Prime Minister Narendra Modi formally launched a mammoth financial
inclusion program: “Pradhan Mantri Jan Dhan Yojana” (PMJDY), also known as
Jan Dhan Yojana (JDY), which translates as “Prime Minister’s People’s Wealth
Program.” Touted as the biggest financial inclusion initiative in the world, the
scheme aimed to take banking facilities to 75 million households within a period
of five months, that is, by January 26, 2015.
By May 2015, banks had reportedly far exceeded the target set by the prime
minister and opened approximately 159 million accounts, according to a survey
of 210 million households in the country (table 4.1). In the first week of the
scheme’s launch—August 23–29, 2014—18.1 million accounts were opened,
and the event entered the Guinness Book of World Records. Of the accounts
opened, 60 percent are in rural areas and 40 percent in urban areas. The share of
female account holders is about 51 percent.
The success of account openings was partly due to people getting a package
deal when opening an account. Every account holder received a RuPay debit card,
launched by the RBI-promoted National Payments Corporation of India (NPCI),
with an inbuilt accident insurance coverage of Rs 100,000 (approximately US$1,650)
Table 4.1 Jan Dhan Yojana Account Status, by Bank Type, May 2015
No. of RuPay Balance in
No. of accounts (millions)
debit cards accounts Share of accounts
Bank type Rural Urban Total (millions) (Rs, billions) with zero balance (%)
Public sector banks 67.48 56.44 123.92 115.92 134.80 53.70
Regional rural banks 23.98 4.20 28.18 20.58 30.48 54.09
Private banks 3.85 2.68 6.53 5.88 9.92 49.65
Total 95.31 63.31 158.62 142.38 175.20 53.60
Source: PMJDY 2015.
Note: “RuPay” refers to a domestic debit card scheme launched in 2012 (initially called IndiaPay) by the National Payments Corporation of India as
an alternative to foreign gateways with high transaction costs such as MasterCard and Visa and to consolidate various payment systems in India.
Rs = Indian rupees.

and a RuPay Kisan credit card; and an overdraft facility of Rs 5,000 activated
after six months of operation of the account. An incentive of life insurance cover-
age of Rs 30,000 was offered for those opening accounts before January 26, 2015
(celebrated as Republic Day in India) (Economic Times 2014).
Phase I of the scheme targeted three goals in the first year of implementation:
universal access to banking facilities, provision of financial literacy, and provision
of basic banking services. Phase II (August 15, 2015, to August 15, 2018) included
the creation and development of a Credit Guarantee Fund to cover defaults in
overdraft accounts and to provide microinsurance8 and unorganized sector pen-
sion schemes. Coverage of households in hilly, tribal, and difficult areas and
including every adult or student in all households is also planned.
The second phase is important because recent (2013) National Sample
Survey Office (NSSO) data show that there are close to 57.7 million small-scale
business units, mostly sole proprietorships, that undertake trading, manufacturing,
retail, and other small-scale activities (Debu C 2015). Comparatively, organized
sector and larger companies employ 12.5 million individuals. Today, the
micro- and small-business segment is unregulated and without financial support
from the formal banking system.
The promised Credit Guarantee Fund (Phase II activity) was launched in April
2015 as the Micro Units Development and Refinance Agency Ltd. (MUDRA)
Bank, with capital of Rs 200 billion (US$3.13 billion) and a credit guarantee fund
of Rs 30 billion to address the issue of lack of access to funds faced by small entre-
preneurs. Although the government had considered evolving the MUDRA Bank to
be the regulatory body for MFIs, this plan did not proceed. Nevertheless, MUDRA
provides its services to small entrepreneurs outside the service area of regular
banks, by using “last mile” agents. About 5.77 crore (57.7 million) small businesses
have been identified as target clients using the NSSO survey of 2013. Only 4 percent
of these businesses get finance from regular banks.
Challenges to Jan Dhan Yojana

One of the major concerns that haunts the Ministry of Finance is that about
54 percent of the accounts opened have zero balances (table 4.1). Criticisms also
include that JDY was a public-bank-driven exercise. However, both of these
trends seem to be waning (figure 4.4).
The banking sector is realizing that the JDY scheme can bring in huge oppor-
tunities in the years to come. Banks will be able to offer microfinance and related
products to people across the country. The question is whether the scheme is
likely to make rural operations more profitable for banks. As stated earlier, rural
accounts make up 60 percent, and regional rural banks 18 percent, of the total
JDY accounts opened to date (PMJDY 2015). The government has successfully
addressed the challenge of getting accounts opened.
Through this initiative, savings from these typically low-income households
are now brought within mainstream banking. However, getting customers to
use these accounts is the second challenge. Because some of the offers become
validated only once the account is operational, this is a matter for concern.

Figure 4.4 Zero-Balance Trends in Jan Dhan Yojana Accounts, India, 2014–15
90
81.5
79.4
80 76.8 76.9 76.3
75.9 73.1
76.0 74.3
75.5 73.3
73.9 72.7 68.5
70 72.4 67.3
70.5 70.2
67.8 62.8
66.6 61.0
60 61.9 57.9
57.3
57.2 56.8 55.9
50
Percent
40
30
20
10
0
Sept. 30, Oct. 31, Nov. 29, Dec. 31, Jan. 31, Feb. 28, March 31,
2014 2014 2014 2014 2015 2015 2015
Regional rural banks Overall Public sector banks Private banks
Source: PMJDY 2015.
The accident insurance will come into effect only if at least one transaction
takes place within a 45-day period. The overdraft facility will depend on the
balance in the account. Given the poverty and illiteracy among the target
groups, a comprehensive awareness campaign is a must. The trend in zero-
balance accounts is downward-sloping, which is encouraging (figure 4.4).
Hence, it looks as if the government’s awareness campaign is working.
Direct Benefit Transfers: Key Enabler for Jan Dhan Yojana

The potential game changer for financial inclusion could be the direct benefit
transfers (DBTs) channeled through JDY bank accounts. The government is
hastening this process by linking all accounts to India’s Aadhaar unique identifi-
cation (ID) program. Once this is completed, the flow of money from govern-
ment schemes to the beneficiaries will become seamless.9 The bank will also
enjoy the benefit of the float if all government payments to beneficiaries are
transferred to these accounts. In addition, there is a proposal that the government
pay the banks a 2 percent commission on the total DBT payments handled.
However, the banks are negotiating for 3 percent plus a tax adjustment. Whatever
the negotiated amount finally agreed, it will have to make business sense for the
banks if efficiency is to prevail.

The saving on leakages that occur in various subsidy schemes will more than
compensate for the cost of this massive exercise of financial inclusion. Leakages
are estimated to be between Rs 500 billion and Rs 750 billion (around 5 percent
of GDP).
Realizing that incentives are needed to keep these accounts from remaining
or turning dormant, the government is inclined to channel all benefits, including
state and local government benefits, through these accounts. Though DBTs and
the mandate for continued eligibility for accident insurance coverage are incen-
tives to operate the bank account, there is nevertheless the risk that many
accounts not covered under DBTs may fall into dormancy. Even for accounts
covered by DBTs, operations may be confined to receiving the DBT remittances
and withdrawal. However, notwithstanding the realities of how poor people
operate basic no-frills accounts, the potential for a program to bring millions of
unserved people into the formal financial system is a remarkable feat.
Digitizing the Last Mile Connectivity

The biggest challenge for the JDY program is to deliver financial services using a
sustainable and scalable model. Even though the government and RBI have taken
measures to expand the access channels, a scaled-up digital payment system is
not yet widely available in India. Hence, the full potential of digital financial
services in India has not yet been realized.
However, since 2006 in Andhra Pradesh, social welfare payments have been
disbursed electronically, through around 26,000 female self-help group mem-
bers, to 16 million accounts. In fiscal year 2012/13 alone, the government of
Andhra Pradesh channeled US$1.2 billion worth of social welfare payments
through electronic channels, and this is expected to increase. Andhra Pradesh was
the first state in India to implement an electronic payment channel at scale
(CGAP 2013). With the DBT scheme rolling out countrywide, there are lessons
to be learned from the initial efforts in Andhra Pradesh.
Given the inadequacies in banking infrastructure as access points to the
general public, digital payments and the payment banks can play a significant role
in making financial access a reality. In addition, using India Post—with 155,000
post offices, of which nearly 90 percent are in rural areas—is also considered an
effective way to provide service touchpoints.
One significant shortcoming that is also a huge opportunity is that India
lags significantly behind in mobile payments. The Consultative Group to
Assist the Poor (CGAP) reported that control by the banks of not only credit
and savings but also the payments market has restricted the use of mobile
money to only 0.3 percent of adults in India (Kumar and Radcliffe 2015).
With 900 million mobile connections in 2013 across India—expected to rise
to 1.16 billion by 2017—mobile connectivity presents the perfect opportu-
nity to increase the use of e-money (figure 4.5). According to the Telecom
Regulatory Authority of India (TRAI), there were 350.37 million rural sub-
scribers by 2013 (TRAI 2013). The MNOs already manage a distribution
infrastructure and large agent network of 2–2.5 million touchpoints, and they

Figure 4.5 Number of 2G and 3G/4G Connections in India, 2008–17
+31%
1,200 3/4G 1,159
1,103
1,043
982
1,000 919
894 327 409
Mobile connections, millions
865 171 252

39 107
752 67
800
11
600 526
2
400 347 855 798 812 811

741 791 776 750
524
200 347
0
2008 2009 2010 2011 2012 2013 2014 2015 2016 2017
3G and 4G 2G
Source: MMAI and GSMA 2013.

Note: 2G, 3G, and 4G refer to the “generation” of the mobile-phone network; the higher the number, the faster the download speed as a measure
of how quickly information can be transferred from the Internet to a phone. 2G mobile networks are handled by simple cell phones for basic
e-mails and texts. These second-generation or 2G phones, which are also low-cost and suitable for poor people worldwide, are quite adequate for
mobile money applications that operate by sending short message service (SMS) or texts.
already address the needs of low-income consumers by designing products

such as Rs 10 (US$0.16) airtime reload vouchers (MMAI and GSMA 2013).
Realizing this potential, in 2014 RBI brought in transformative regulatory
reforms that enable the use of this untapped network of agents to expand the
transaction points across India so that people can readily access basic banking
services and potentially cash out their subsidy payments without incurring addi-
tional cost in terms of time as well as money (box 4.2).
In addition to RBI regulations, TRAI issued guidelines that require mobile
operators to provide banks with unstructured supplementary service data
(USSD) channel access for mobile banking. This will ensure that banks can lever-
age mobile operators’ communications channels when offering mobile banking
(Kumar and Radcliffe 2015). To facilitate greater adoption of mobile banking,
RBI recommends that all MNOs preload a standard single mobile-banking appli-
cation in the form of a short message service (SMS), and the government has
mandated this addition to all new phones.
The NPCI also plays its part in this important initiative by setting up a next-
generation USSD-based mobile banking service: the National Unified USSD
Platform (NUUP). Accessible through a common code (*99#) dialed from a
mobile phone, NUUP allows every customer to access banking services with a
single number across all banks—irrespective of the telecom service provider,
mobile handset make, or the region. However, NUUP is only available on Global

Box 4.2 Reserve Bank of India Regulatory Reforms, 2014

• Payments bank guidelines are to allow companies with significant distribution expertise
(including mobile operators, retail chains, and existing agent managers) to offer deposit
accounts and payments as a stand-alone business.
• Reserve Bank of India (RBI) lifted its prohibition against banks establishing agents more
than 30 kilometers from the nearest bank branch. The 30-kilometer rule has befuddled the
financial inclusion sector for years by preventing smaller banks with limited branch networks
from building national agent networks. By lifting this restriction, the RBI effectively leveled
the playing field between large and small banks, at least when it comes to agent banking.
And once payments banks come online, they will be able to establish agents without
worrying about building brick-and-mortar branches to comply with the 30-kilometer rule.
• RBI removed the requirement that customers provide proof of current and permanent
address for opening a bank account. This requirement was particularly tricky for migrant
laborers who have trouble securing documents that prove their current address.
• Nonbanking finance companies can now act as business correspondents. This will allow
India’s microfinance institutions—many of which already serve millions of poor customers—
to build agent networks on behalf of banks.
• RBI concluded its pilot to determine whether licensed prepaid issuers, such as Airtel Money
and Vodafone M-Pesa, could allow their customers to cash out. RBI has removed that restric-
tion, creating more options for nonbank providers to offer payment services.
Source: Kumar and Radcliffe 2015.
System for Mobiles (GSM) mobiles and not on Code Division Multiple Access
(CDMA) mobiles.10 A platform common to all banks—instead of each bank hav-
ing to develop its own platform—is a strategic move by NPCI to help banks focus
on customers while NPCI manages the technology behind the platform. NUUP
is currently available in 11 languages. NPCI and the regulators successfully
brought in all 12 MNOs.
NUUP is using the Immediate Payment Service (IMPS) platform, which is a
real-time interoperable payment mechanism by NPCI. IMPS offers an instant,
24-hour, 7-days-a-week interbank electronic funds transfer service through mobile
phones. IMPS transfers money instantly within banks across India through mobile,
Internet, and automated teller machines (ATMs), which is not only safe but also
economical both in financial and nonfinancial terms. There are no charges on
NUUP transactions. However, IMPS fund transfer charges would be applicable.
Sri Lanka: Regulations Keeping Pace with Technological Advancements

The dawn of the Mobile Money era in Sri Lanka has been made possible by
the progressive, and financial inclusion focused, regulatory ethos of the Central
Bank of Sri Lanka. In this respect Sri Lanka’s Payments and Settlement
Legislation and Mobile Payment regulations stand among the most progressive

in the world. Emboldened by the support and facilitation received from the
Central Bank, Telecommunication Regulatory Commission and our custodian
bank [Hatton National Bank], we are confident that this pioneering initiative
to deliver a nationwide Mobile Money will deliver an unprecedented level of
financial inclusion through the empowerment of millions of Sri Lankan citizens
with electronic money transfer and payment facilities.
—Hans Wijayasuriya, group chief executive, Dialog Axiata PLC,
at the launch of eZ Cash, June 2012
A good financial sector regulatory framework should be simple and

effective, protect consumers, and reward innovation by being flexible enough
to adapt to changes in the markets, while combatting money laundering and
fraud. More often than not, frustrated innovators claim that regulators cannot
keep pace with the rapid changes and technological developments in the
industry, while skeptical regulators maintain that such innovations may do
more harm than good. Often it is a balance between these two extreme view-
points that would make a good enabling regulatory system that fosters respon-
sible innovation. Risk management systems should keep pace with the
complexity of new financial products to ensure that there are no pervasive
failures in consumer protection; transparency and standards should be main-
tained to allow for fair market conduct and competition; and gaps and weak-
nesses in the supervision and regulation of these newcomers to the market
may have to be addressed in innovative ways.
Mobile money systems thrive on markets where banking density is very low
or people are geographically widely dispersed, thus making financial access a dif-
ficult task. Sri Lanka has no serious issues in either category. Nearly 70 percent
of the adults in Sri Lanka have accounts in formal financial institutions,11 and in
their report “Deposit Assessment in Sri Lanka,” Leonard et al. (2011) noted that
outreach of financial services in Sri Lanka can be considered fairly extensive, with
a reported 82.5 percent of households having access to financial institutions for
their savings and credit needs.
Since the 26-year civil war ended in 2009, the government and the Central
Bank of Sri Lanka (CBSL) have spearheaded financial inclusion activities focus-
ing on the war-torn areas of the North and East emerging from the conflict. For
example, banks were required to open two branches outside of the Western
Province for every branch opened within the Western Province. By 2014, the
Northern Province had the highest banking density (21.7 branches per 10,000
people), and the Eastern Province the third highest (16.8 per 10,000) (Daily FT
2015a). At the same time, the CBSL authorized testing of a mobile banking
service, leading to the launch in 2012 of eZ Cash, which gained over a million
customers within a year (di Castri 2013). Hence, in Sri Lanka, mobile money
solutions offered by MNOs will always be one of many options available to
access financial services, and will proliferate only if there is a simple and clear
value proposition to the users.

CBSL decided to allow mobile money services through MNOs after making
sure that necessary safeguards are in place. It is a trailblazer in enabling tech-
nological innovations by setting up benchmark regulatory practices that are
both progressive and nonprohibitive. CBSL enacted necessary laws early on.
It created a level playing field where both banks and nonbanks including
MNOs can offer digital money; established enabling regulatory and oversight
functions that are not overtly restrictive; ensured that customer rights and
information are well protected; and worked with stakeholders across the board
to understand market needs and innovations. These positive reforms did not
happen overnight.
Legislative Background
Being a pioneer in the South Asia region to adopt technology-based financial
services, Sri Lanka has broader legislation than its regional neighbors for payment
systems and electronic transactions—and a wide range of payment instruments
and payment services to support the country’s banking and finance industry.
CBSL has always been at the helm, providing leadership, guidance, and a legisla-
tive framework to enable such developments.
The most significant decade in terms of regulatory enactments relating to
payment reforms and e-money in Sri Lanka has been the 2001–10 period.
Under the central bank’s modernization project that commenced in 2001,
CBSL’s objectives have been redefined by an amendment to the Monetary Law
Act in 2002 to recognize financial system stability as a statutory objective in
addition to the price and economic stability objective. Starting with this
momentous amendment, a series of other important financial regulatory laws
were enacted during this period.12 Additionally, several amendments were
introduced to the existing laws to facilitate new payment and settlement sys-
tems and processes (Jayamaha 2014).13
The rapid pace of the passage of these laws indicates the proactive leadership
of CBSL in establishing the core legal infrastructure required to facilitate the
developments of electronic transactions and mobile payments. As part of the
payment systems modernization undertaken in 2001, to improve efficiency and
enhance the level of integrity, the Payment and Settlements Systems Act (PSSA)
was enacted as the comprehensive legislation governing payment, clearing, and
settlement systems. The Act provided CBSL with oversight and regulatory pow-
ers over the national payment system as well as payment systems and money
transfer service operators. PSSA was the key legislation that enabled nonbanks to
offer mobile money services.
The Electronic Transactions Act of 2006 provided the underlying framework
for electronic and mobile transactions, based on the model laws developed by the
United Nations (UN) Commission on International Trade Law, which recognizes
and enables enforceability of electronic transactions, and the UN Electronic
Communications Convention. Three fundamental policy-related principles form
the basis of the Act: (a) technology neutrality, (b) functional equivalence, and (c)
party autonomy. Technology neutrality is ensured by not dictating the technology

to be given legal preference. Hence, unlike statutes in some countries, the

Electronic Transactions Act in Sri Lanka does not specify any technology that
should be used, allowing businesses and consumers to determine technology
options based on types of use.
Sri Lanka became the first country in South Asia (and one of the first three in
the Asian region, along with China and Singapore) to sign the UN Electronic
Communications Convention in July 2006 (Fernando 2013). In terms of the
provisions of this Act, all transactions and business done in electronic form would
be recognized and valid, with the exception of excluded items (under section 23
of the Act) such as last wills, powers of attorney, and transfers of immovable
properties, to name a few. This Act also facilitated Sri Lanka’s e-government
services available through the Lanka Gate web portal.
In July 2015, Sri Lanka ratified the UN Electronic Communications
Convention, another first for South Asia and the second country after
Singapore to become a State Party to the Convention. Countries such as
Australia, China, Thailand, and Vietnam are already preparing domestic legis
lation to ratify this Convention. Jayantha Fernando, legal adviser to Sri Lanka’s
Information and Communication Technology Agency (ICTA), said this of the
action: “Sri Lanka’s ratification of this Convention will ensure greater legal
certainty for e-commerce and e-business providers who wish to use Sri Lankan
law as the applicable law and ensure international validity for other interna-
tional legal instruments as well as cross-border fund transfers, enhancing the
ability of Sri Lanka to fast-track its move towards paperless trade facilitation”
(Daily FT 2015b).
Sri Lanka has also adopted the recommendations of FATF and enacted sev-
eral laws enabling CBSL to issue AML/CFT guidelines and regulations to all
financial sector players and payment systems providers.14 Furthermore, realiz-
ing the need for greater information security, the Payments Devices Frauds Act
(No. 30 of 2006) and the Computer Crimes Act (No. 24 of 2007) provided a
unique investigation and enforcement regime. More recently, Sri Lanka became
the first country in South Asia to be invited to join the Budapest Convention
on Cybercrime.15 Although the much-needed Secured Transactions Act
(No. 49 of 2009) was enacted with the intention of establishing an online reg-
istry for movable assets, amendments are needed to include new provisions to
enable movable and mobile collateral to be accepted as sureties.
Institutional Infrastructure
The ICTA of Sri Lanka, the government’s apex information and communication
technology (ICT) institution, ably supported CBSL in establishing key legislation
and a comprehensive information security framework for the financial sector to
ensure greater consumer confidence as the financial sector transitions toward a
cash-lite electronic mode. ICTA addressed the legal validity and enforceability of
electronic transactions—the main concerns for the financial community in tran-
sitioning to electronic mode—by spearheading the enactment of the Electronic
Transactions Act in 2006.

CBSL has empowered LankaClear to be the national payment infrastructure

provider for retail payments.16 Driving Sri Lanka toward an efficient, green, and
paperless nation, LankaClear provides the necessary technological platforms and
gateways that are cutting-edge and cost-efficient and allow for seamless connec-
tivity. Some of these are groundbreaking and the first in South Asia. These solu-
tions are both efficient and secure.
Among them, the LankaSIGN certification service provider (CSP) imple-
mented by LankaClear in 2009 provides the much-needed security for the
electronic payment systems and is currently the only commercially operated CSP
in the country. Development of the Common Card & Payment Switch (CCAPS)
by LankaClear under the guidance of CBSL is an important ongoing initiative in
the retail payment arena.
LankaClear also hosts the Bank Computer Security Incident Response Team
(Bank CSIRT). Bank CSIRT, a joint initiative of CBSL and the Sri Lanka
Computer Emergency Response Team (SLCERT), is a specialized service unit
that is responsible for receiving, reviewing, processing, and responding to com-
puter security alerts and incidents affecting the banks and other licensed financial
institutions in the country. Commercial banks provide guidance and funding for
Bank CSIRT. Through LankaClear, Bank CSIRT will have the prime responsibil-
ity to coordinate security efforts within the banking and financial sector.
In addition, a special unit called the Cyber Crime Investigations Unit is estab-
lished in the Criminal Investigations Department of the Sri Lanka Police Service.
It is reported that CBSL and SLCERT are jointly taking the initiative to prepare
legislation and regulations necessary to deal with cybercrimes.
As a result of this legislative framework, Sri Lanka has an excellent payment
systems infrastructure and possibly the best financial regulatory framework in the
region to govern e-money for e-commerce and e-government programs. In the
World Bank’s 2008 Global Payment Systems Survey, the legal and regulatory
framework of Sri Lanka’s payments system was rated at the “High Level of
Development” (Cirasino and Garcia 2008; World Bank 2008). The highest rat-
ings were given for system design and key policy decisions that affect the safety,
soundness, and efficiency of the system.
Notwithstanding the excellent institutional infrastructure that enables innova-
tive solutions, the most important institutional arrangement from the mobile
money perspective is the coordinated regulatory collaboration between CBSL
and the Telecommunications Regulatory Commission of Sri Lanka (TRCSL).
The expansion of digital technologies has altered the ways in which financial
services are delivered and accessed. Thus, regulators are presented with a number
of challenges, specifically regarding consumer protection and due diligence.
The uniqueness of e-money is that it overlaps different regulatory domains,
thus risking a mismatch of regulations and potential coordination failures.
By coordinating proactively and by converging the service delivery and customer
protection paradigms of the telecommunications and banking sectors, the two
regulatory authorities in Sri Lanka were able to provide a comprehensive yet
flexible mobile money regulatory and oversight framework where CBSL would

take the lead. TRCSL is agreeable and pledges support to cooperative efforts to
ensure smooth implementation of regulatory initiatives.
Leveling the Playing Field

CBSL realized early on that an effective, inclusive digital financial system
requires a level playing field so that private sector players such as MNOs can
offer competitive products and services efficiently and at a lower cost, using their
ready-made network of reload agents as touchpoints. While not creating unneces-
sary hurdles for the MNOs, and ensuring that safeguards are met, CBSL decided
on an iterative approach.
Unlike in most other countries, the already-enacted PSSA in 2005 gave CBSL
the necessary powers to authorize MNOs to offer mobile money. In 2007, CBSL
authorized the National Development Bank (NDB), a smaller commercial bank,
to issue a mobile money service jointly with Dialog Axiata, the leading MNO in
the country,17 which wished to pilot a bank account–based mobile money system.
The regulatory framework required the customers to have a bank account to be
able to sign up for this mobile money service called “eZ Pay” (subsequently
upgraded to “eZ Cash”). Although two more banks and a registered finance com-
pany also joined, the system did not scale up easily, and it ended up having only
around 15,000 customers.
In this case, even though Dialog Axiata operated under NDB to offer the
mobile money service, NDB required the same level of identity verification
from mobile money clients as from bank customers. The success of mobile
money and scaling-up depends on the ability to speed up the wallet account
opening process and to minimize steps in transacting. Realizing that customers
were not interested in signing a plethora of documents to verify their identity
in signing up for bank accounts, Dialog Axiata asked CBSL to consider an
MNO-led mobile banking solution without requiring a bank account to be
opened by customers. CBSL reexamined the guidelines and reviewed the sub-
missions by Dialog Axiata to operate an MNO-led mobile money solution
using the customer information already available in their mobile-phone
contracts. Even though the yet-unfolding global financial crisis and the collapse
of a local credit card company were, at the time, putting pressure on the regula-
tor, CBSL was aware that limiting innovation and competition would result in
suboptimal noncompetitive solutions that would affect financial inclusion as
well as financial system stability in the long run.
At the same time, consumer protection and information safeguards were pri-
mary considerations. Addressing all these concerns, in 2011 CBSL issued two
distinct mobile money guidelines, for the bank-led model and the MNO-led
model under PSSA.18 Accordingly, mobile money or payment cards service pro-
vider licenses could be granted to
• A licensed commercial bank;

• A licensed specialized bank;
• A finance company;

• An operator that provides cellular mobile telephone services under the author-
ity of a license issued under the Sri Lanka Telecommunications Act (No. 25 of
1991) as amended; or
• A company registered under the Companies Act (No. 7 of 2007) having an
unimpaired capital of at least Rs 150 million or such other amount deter-
mined by the Central Bank, other than a company limited by guarantee, an
offshore company, or an overseas company, within the meaning of the
Companies Act.
By issuing these comprehensive and broad guidelines under PSSA, CBSL

opened up the horizon for a broad and growing range of providers with different
value propositions to participate in the payment services industry.
Proportional, Risk-Based Know-Your-Customer Requirements

Unlike banks and traditional payment methods, mobile payments pose regula-
tory challenges in addressing AML/CFT risks. Such risks stem from the lack of
face time with customers, leading to difficulties in identification and verifying
income sources. Dealing with MNOs and transacting across a vast number of
agents who traditionally are not from the financial sector also pose challenges for
financial institutions and regulators.
On the other hand, overly strict requirements regarding the identification
and verification of customers risk exacerbating financial exclusion. FATF rec-
ommendations encourage the use of (a) differentiated customer due diligence
(CDD) measures according to the profile of the (future) customer for cus-
tomer identification; and (b) “progressive” or “tiered” CDD as a risk-based
“know-your-customer” (KYC) method. This would mean that people lacking a
government-issued ID or formal proof of address can be allowed basic access
with limited functionalities using alternative identification methods. Access to
a wider range of services and higher transaction limits may be allowed when
additional CDD requirements are met. Hence, transaction and payment limits
or wallet sizes vary based on the KYC or CDD requirements met.
Sri Lankan citizens who are 16 years and older and reside in Sri Lanka are
required to apply for the national identity card (NIC) issued by the
Registration of Persons Department. The NIC is regarded as the key ID docu-
ment for identification and authentication of persons. Also in Sri Lanka, sub-
scriber identification module (SIM) registration is mandatory, hence MNOs
already have copies of national ID cards and photographs as well as digitized
versions in their databases.
Considering these facts, CBSL applied the proportional risk principle that
allows low-value mobile wallets to be automatically enabled via the customer
dialing in using the customer information already available to the MNOs in the
mobile contract. Higher-limit mobile wallets would require customers to visit an
MNO kiosk and provide additional CDD-related paperwork. This means that
almost all mobile subscribers (22.12 million subscribers, or 107 percent of the
population in Sri Lanka) are able to operate a basic e-wallet if they so wish,

just by dialing in. A low initial registration burden for basic wallet size reduces
customer resistance to registration and hence enables faster growth in the use of
mobile money.
Regulatory Oversight
Due to the very nature of mobile transactions, mobile money initiatives are
deemed to be low-value, low-risk systems. Hence, oversight and monitoring of
service providers is not expected to be as extensive as supervision conducted for
banks and other financial institutions that are also subject to prudential norms
such as the Basel Core Principles (BIS 2012). However, the magnitude of mobile
money proliferation in Kenya suggests that such initiatives have the potential to
become systemically important payment systems.
Because of the innovative nature of these initiatives, often the laws and regula-
tions have gaps and gray areas that create oversight challenges and may lead to
negative reactions by the regulatory authorities. For example, in 2014, China’s
central bank suspended mobile payments initiated through Quick Response
(QR) codes amid security concerns regarding the identification process involved
with those transactions. The bank’s decision immediately affected China’s two
largest third-party mobile payments providers: Alibaba Group Holding Ltd.
(which operates Alipay) and Tencent Holdings Ltd.19 In Kenya, M-Pesa func-
tioned for more than seven years without a regulatory framework before CBK
was able to pass the National Payment System Regulations in 2014.
In Sri Lanka, having the PSSA enacted in 2005 afforded greater clarity and
transparency to the oversight role of CBSL, and the Act legally empowered the
CBSL to regulate, supervise, and monitor the payment systems and service pro-
viders. Thus, understanding the need for legal certainty,20 CBSL issued regula-
tions under PSSA to license the mobile payment service providers.21 Thereafter,
mindful of the innovative nature of mobile money services and lessons learned
from previous mobile money deployments that failed to gain traction, CBSL
issued the Mobile Payments Guidelines (No. 2 of 2011) for Custodian Account
Based Mobile Payment Services, which provides the monitoring framework for
nonbank service providers to operate. Issued under the PSSA, these regulations
and guidelines ensure that the regulation and oversight function supports pay-
ment system stability and also instills public confidence in mobile money ser-
vices. The reporting requirements and regulatory and oversight provisions are
clearly set out in the guidelines. Moreover, CBSL has also entrusted the custodian
bank of the licensed service provider with the additional responsibilities of for-
mulating KYC and CDD procedures for the service provider, monitoring and
supervision of the service provider for compliance with regulations and guide-
lines, and auditing of all e-money accounts with the service provider (an MNO
in this case).
Customer Protection
In line with good-practice prudential requirements, CBSL requires the MNOs to
“ring-fence” the customers’ funds in custodian accounts at licensed commercial banks.

According to the guidelines issued, it is mandatory that the e-money accounts be

updated by the service providers on a real-time basis and that the cumulative
sum collected from all e-money account holders be maintained in the custodian
accounts at all times.
Additionally, a trust is established by execution of a trust instrument admin-
istered by Deutsche Bank AG over the funds held in the custodian account.
Hence, in the event that either the service provider (the MNO) or the custo-
dian bank becomes insolvent, customer funds in the pooled account will be
protected.
Customer Education and Grievance and Redress Mechanisms

The regulators should ensure that service providers educate customers about
using security features and the importance of protecting their personal infor-
mation. Hence, there should be transparent, effective, and straightforward
complaint mechanisms and recourse. To this end, CBSL has directed the
service providers to develop an appropriate dispute resolution mechanism
based on guidelines that will be issued by them to handle disputed payments,
transactions, and loss of mobile phones. Service providers are required to
establish a call center to respond to customer inquiries and complaints and to
be responsible for addressing customer grievances in the event a customer
files a complaint about a disputed transaction. Charge-back procedures for
addressing such customer grievances are to be formulated by the service
providers.
The early enactment of PSSA allowed CBSL to establish focused yet flex-
ible regulatory mechanisms to regulate e-money. The cornerstones of this
successful regulatory framework were a nondiscriminatory licensing regime;
consumer protection and safeguarding of funds; reduction of operational risks
and establishment of tiered KYC and CDD measures; and appropriate over-
sight mechanisms augmented by use of prudentially regulated custodian
banks to monitor and assist with e-money operations of the nonbank service
provider. Ably supported by an enabling regulatory framework, eZ Cash has
the distinction of being the first mobile money system in the world to be
end-to-end interoperable across multiple service providers, thus bringing for-
ward a combined subscriber base of over 14 million Sri Lankans who could
transact electronically via eZ Cash.
Thailand: A Government’s Vision and Policy to Bring Cash

to the Doorstep
According to the 2013 FinScope Survey, in Thailand 97 percent of the adult
population have accessed formal financial services: 74 percent of the adult
population have bank accounts, while an additional 23 percent have used for-
mal nonbank financial services (FinScope 2016). With another 2 percent of the
population using informal financial services, the financially excluded popula-
tion in Thailand is only 1 percent (figure 4.6).22 These ratios are similar in all

Figure 4.6 Financial Access Strand in Thailand, 2013
Formally included (97%)
74 23 2 1
0 20 40 60 80 100
Percent
Banked Formal other Informally served Excluded
Source: FinScope 2016.

Note: The figure reflects FinScope 2013 Survey respondents who were ages 18 and older. The “Access
Strand” is a graphical method (routinely used in FinScope Surveys) of placing each survey
respondent along a continuum of access, depending on use of services by category. “Banked” refers
to those who reported using traditional financial products supplied by commercial banks. “Formal
other” refers to those who reported using financial products of formal financial institutions that are
not commercial banks. “Informally served” refers to those who reported using “informal” products
without recognized legal governance, such as savings with an employer or savings group. “Excluded”
refers to those who reported using no financial products.
Figure 4.7 Financial Access Strand in Thailand, by Region, 2013
1
Bangkok 86 12 1
Central 75 20 4 1
1
North 76 22 1
Northeast 70 27 2 1
South 70 26 3 1
0 20 40 60 80 100
Percent
Banked Formal other Informally served Excluded

Note: The figure reflects FinScope 2013 Survey respondents who were ages 18 and older. The “Access Strand” is
a graphical method (routinely used in FinScope Surveys) of placing each survey respondent along a continuum
of access, depending on use of services by category. “Banked” refers to those who reported using traditional
financial products supplied by commercial banks. “Formal other” refers to those who reported using financial
products of formal financial institutions that are not commercial banks. “Informally served” refers to those who
reported using “informal” products without recognized legal governance, such as savings with an employer or
savings group. “Excluded” refers to those who reported using no financial products.
four regions of the country, with the Bangkok area showing higher access
through banks at 86 percent (figure 4.7).
The high level of access can be attributed to the deliberate policies pursued
by the Royal Thai government (RTG) over the years to extend financial services
to the underserved and unserved population. These policies have been largely

government-led and government-financed. The commercial sector has played a

relatively minor role in providing access to credit and insurance, while taking the
lead in savings and remittances (ADB 2013a).
One government strategy was to involve state-owned financial institutions,
such as agricultural cooperatives and the Village and Urban Revolving Fund
(Village Fund). The Village Fund is a semiformal institution established in 2001
by the RTG after the 1997 financial crisis to make credit available to the villages.
The Thailand Village Fund is the second largest microcredit scheme in the world.
RTG provided initial seed money of B 1 million (US$28,700) to each of
Thailand’s 74,000 villages and 4,500 urban communities. Hence, nearly 80,000
elected local Village Fund committees administer loans that reach 30 percent of
all households (Boonperm et al. 2012).
In addition, the good leadership role played by the Bank of Thailand (BOT)
in enhancing financial inclusion and actively implementing strategies, policies,
and regulations to ensure an enabling environment was also instrumental in
increasing access to finance. BOT emphasized its commitment to financial inclu-
sion in its recent Financial Sector Master Plan (Phase II, for the period 2010–14),
with the aim of increasing efficiency, promoting inclusion, and providing con-
sumer protection, and it has entered into discussions with commercial banks
concerning business models that might help reach the rural poor (BOT 2009).
BOT also is looking into extending services tailored to the needs of unbanked
and underserved populations, while maintaining stability in the system. According
to BOT’s financial access survey for 2010, of the 878 districts in Thailand, 302
(34.4 percent) do not have commercial bank branches. However, when branches
of specialized financial institutions (SFIs) are included, the number of districts
with no branch service drops to 92 (10.5 percent). This is largely due to the
strong rural presence of the Bank for Agriculture and Agricultural Cooperatives
and the Government Savings Bank’s primarily urban footprint. When Village
Funds are included, the financial services footprint extends to virtually 100 percent
of the country (ADB 2013a). Hence, the recent decision by BOT to extend its
supervisory and regulatory mandate to SFIs is an important regulatory develop-
ment because of their extensive coverage of rural and poor communities in
providing a much-needed source of funds. Proper regulatory guidelines are
needed to manage risks as well as to protect consumers.
A proactive and respected Thai Bankers’ Association (TBA) ably supports
BOT. TBA is a founding member of the Association of Southeast Asian Nations
(ASEAN) Bankers Association and plays a key role in representing the banking
community in discussions with BOT, the Ministry of Finance, and other govern-
ment bodies in formulating and implementing key economic and financial poli-
cies. TBA also works closely with the Foreign Banks’ Association on various
banking issues, including improvements to the payment and settlement systems.
TBA has been a valuable partner to BOT and its Payment Systems Committee
in fostering efficient, safe, and sound infrastructure to enable access to financial
and payment services by the Thai people and in supporting economic
development.

Cash Access within Eight Minutes

The development of financial infrastructure that enhances outreach to a wider
customer base is an integral part of Thailand’s success story. Under guidance from
BOT, banks in Thailand are expanding their infrastructure covering all four
regions of the country (map 4.1).
Map 4.1 Distribution of Financial Institution Branches, Automated Machines, and EFTPOS
Terminals in Thailand, by Region, 2013
North
Central Northeast
Thai commercial banks

SFIs
Foreign banks
Thai commercial banks’ automated machines
SFIs’ automated machines
Foreign banks’ automated machines
South EFTPOS
Source: BOT 2013. © Bank of Thailand. Reproduced, with permission, from Bank of Thailand; further permission
required for reuse.
Note: EFTPOS = electronic funds transfer at point of sale; SFIs = specialized financial institutions.

Despite the economic contraction in 2013 that led to reductions in transac-

tion volumes, mobile banking and Internet banking showed significant growth.
The key payment infrastructure in the country comprises bank and nonbank
branches, the Internet, mobile phones, ATMs, cash deposit machines (CDMs),
and electronic funds transfer at point of sale (EFTPOS) terminals. This wide
array of payment infrastructure ensures payment services to customers that are
not restricted to bank and nonbank branch working hours.
In both 2012 and 2013, Thailand recorded significantly higher numbers of
ATMs per 1 million persons (810 and 877 ATMs, respectively) than the average
of Committee on Payments and Market Infrastructures (CPMI) countries (437
and 488 per 1 million persons, respectively).23 Among Thailand’s regions, ATM
penetration indicates that, except for the Northeastern region (383 machines),
the other three regions have higher ATM penetration per 1 million persons
than the average for CPMI countries: Northern (524 machines), Southern
(849 machines), and Central (1,977 machines).
However, the number of EFTPOS terminals per 1 million people (4,099 in
2013) was around half of the CPMI country average of 8,788 terminals (BOT
2013). In addition, although mobile-phone penetration was 142.7 percent, the
number of mobile agreements was only around 1.16 million (1.8 percent of the
population), indicating further opportunities for improvement (BOT 2013).
In addition, Thailand’s MNOs are already providing payment services and
focusing on capturing the untapped market segments. The downside is that the
proprietary mobile payment services and stand-alone systems used by each
operator do not allow interoperability among MNOs, thus limiting uptake
among users.
BOT is well aware that consumers in rural areas still face access as well as
knowledge issues in terms of using e-money, and as a result, use the services
of community financial institutions and informal sources at a higher cost.24
The assessment on potential touchpoints by the 2013 FinScope Survey reveals
that, while it takes an average of close to 36 minutes to reach a bank branch or
ATM for the rural population, it takes only an average of 8 minutes to reach a
grocery store (figure 4.8).
Hence, there is opportunity to provide financial services at a more affordable
cost. BOT has issued agent banking regulations that allow for retailers to act as
banking agents as well.25 Already, Counter Service Co. Ltd. delivers payment
services through more than 700 franchise holders. It has recently partnered with
7-Eleven stores and has access to their more than 8,300 outlets to deliver pay-
ment services.26 7-Eleven is now the most popular provider of utility and other
payments in the country. Other providers include Jay Mart and Tesco Lotus. All
these stores also offer point-of-sale (POS) devices and prepaid phone airtime
replenishment (“top-up” services). Payment services are competitively priced and
range from B 10 (around US$0.30) for utility bills to B 15 (around US$0.45) for
payments due to some commercial banks and insurance companies (ADB
2013a). It is important to expand these services further to cover underserved
areas and communities. The use of banking agents such as retail stores, as well as

Figure 4.8 Average Time to Financial Service Touchpoints in Thailand, 2013
37
Bank branch
21
36
Post office
26
35
ATM
19
29
Market
20
8
Grocery store
7
0 5 10 15 20 25 30 35 40
Average time to touchpoint, minutes
Rural Urban
Source: ADB 2013a, based on FinScope Thailand 2013 Survey. © Asian Development Bank (ADB).
Reproduced, with permission, from ADB; further permission required for reuse.
Note: ATM = automated teller machine.
mobile money solutions, would be the most cost-effective way to improve access
to finance and payment services in these areas.
Banks also offer fund transfers competitively through their ATM networks
(56,851 ATMs throughout Thailand in 2013 [BOT 2013]). ATM transfers are
done free of charge within the same bank, while charges between two different
banks cost around B 30 (about US$0.90). If the ATM of a different bank is used
for withdrawals, up to four transactions per month are free of charge, while trans-
actions beyond the fourth will have a B 10 fee. Moreover, Thailand Postal
Company also acts as a banking agent to commercial banks and uses its 1,295
post offices to perform banking services. (Unlike retail shop payment agents, post
offices are allowed to accept deposits.) The above analysis indicates that banks
dominate the funds transfer and remittance markets.
An Interoperable, Multifunctional, Efficient ATM Network

Thailand is one of only three ASEAN member countries (along with Indonesia
and the Philippines) that have full ATM interoperability, meaning that infor-
mation can be exchanged across different technology systems and software
applications (World Bank 2011). The fully interoperable ATM networks have
expanded payment services such as bill and other payments as well as remit-
tance transfers, and even airline e-ticketing and tax payments can be carried
out at these stations. In addition, automated deposit machines (ADMs, also
called CDMs) offer a cash deposit service, while passbook update machines
(PUMs) provide convenience to customers without visiting bank branches.
Some banks have unique three-in-one compact terminals featuring integrated

note acceptance, dispensing, and self-service passbook update. The terminals’

cash recycling capabilities also reduce operational costs for the banks.
The efficiency of the ATM network is also attributable to the National
Interbank Transaction Management and Exchange (ITMX) Company, the
interbank payment infrastructure provider.27 ITMX supports all types of
electronic payments and funds transfers from various channels, including
ATMs, counters, Internet, phone, and mobile channels, and it fosters interop-
erability among banks by using a secure and efficient open platform.
This eliminates the need for individual financial institutions to upgrade and
maintain their own payment infrastructure systems. From the clients’ per-
spective, interoperability has allowed them increased access through more
bank-neutral touchpoints.
Another important element in Thailand’s extensive ATM network is efficient
cash management. With more and more banks focusing on providing ATM ser-
vices to customers farther away from their head offices or even branches, it is
important to manage timely cash replenishment and 24/7 service. In Thailand,
specialized cash management companies such as G4S (a global integrated secu-
rity company) manage ATMs on behalf of banks, including cash forecasting, cash
transportation, reconciliation services, first-line maintenance, and ATM engineer-
ing services. All of these activities significantly contribute to the efficiency with
which banks provide payment services to their clients.
In reviewing Thailand’s financial inclusion strategy, it is apparent that
although digital finance plays a significant role in the payment space, cash is
still the dominant medium and seen as a free service by banking sector clients
because of low transaction costs. Use of service providers by different customer
groups shows the dominance of banks in the remittance and fund-transfer
space (table 4.2). Efficiently managed ATM proliferation has given banks the
leading edge in these areas.
Table 4.2 Financial Service Providers in Thailand, by Customer and Transaction Type, 2013
Customer type Loans Savings Utility payments Remittances
Farmer BAAC BAAC 7–11, door-to-door ATM, postal orders
Poor villager Village Fund, BAAC, banks, 7–11, door-to- ATM, postal orders
BAAC, informal or door, utilities
moneylenders CDD savings group office
Poor urban NBFI, Banks 7–11, trade outlets ATM
dweller moneylenders,
pawnshops
Middle class Banks, NBFI, Banks 7–11, trade ATM, cashiers’
credit union outlets, banks checks
Businessman Banks, NBFI Banks Banks ATM, cashiers’ checks
Source: ADB 2013b.
Note: ATM = automated teller machine; BAAC = Bank for Agriculture and Agricultural Cooperatives; CDD = Community
Development Department; NBFI = nonbank financial institution; “Village Fund” refers to the Village and Urban Revolving
Fund, a semiformal microcredit institution established by the government to make credit available to the villages.

The importance of proximity to touchpoints in utility payments is evident in

the fact that retail chains such as 7-Eleven play a major role in this payment area.
By regulation, savings and deposit markets are served only by banks and nonbank
financial institutions such as SFIs. Looking at the market structure and the type
of customers, it is evident that poor and underserved customers have limited
access to digital money and payments, given that Village Funds, other community-
based organizations, and cooperatives are cash-based. Hence, there is a huge
opportunity for digital finance to reach the poor and the underserved, who
are primarily being served by these institutions.
The Thailand case study reveals the impact of efficient coordination of
policies and strategies toward payment services and access to finance through
reduction of infrastructure costs by having single or near-single interoperable
platforms. It also brings to light the government’s and BOT’s strategic involve-
ment in these efforts.
Going forward, even though cash-based payments through ATMs and
EFTPOS terminals are well coordinated in Thailand, cash is not the most effi-
cient method of payments. Cash management imposes a high cost on govern-
ments, banks, and even businesses. There are many other payment modes that are
more efficient and safer than cash, and moving toward e-money and digital
finance should be Thailand’s next goal. Cash has to be provided by BOT at a cost,
and that does not help financial deepening. Cash-led financial systems find it
difficult to graduate to the next level because of the retail focus of cash-based
transactions.
From a macroeconomic point of view, Thailand has to come out of its
middle-income trap by elevating small and medium enterprises (SMEs), micro-
enterprises, and retailers to middle-income groups. E-money and e-commerce are
the needs of the day. There is an opportunity for BOT to introduce new regula-
tions and best practices for MNOs and other payment service providers to enter
into the trade.
From a financial inclusion perspective, if mobile money services become
interoperable and connect with the SFIs and also link with retail chains, the
opportunity to reach the poorest by digital means will be limitless. These systems
should encourage and incentivize the use of alternatives to cash. Furthermore,
cost efficiencies would be significant in terms of reducing the high cost of cash
management to the government as well as to other stakeholders. BOT appears
to be aware of these benefits and plans to address these issues through its pay-
ment systems development strategy as well as the financial inclusion strategy.
The Philippines: The World’s Oldest Mobile Money Initiative

Has Yet to Reach Potential
The Philippines was one of the pioneers and earliest adopters of mobile money
services, even before Kenya’s M-Pesa became a household name. Launched in
2001, Smart Communication’s SMART Money service was the first to market;
Globe Telecom’s GCash service followed in 2004. Despite being early movers in

the game, mobile money hasn’t scaled up to the levels initially predicted.
By 2014, active mobile money users were still fewer than 7 million on a com-
bined subscriber base of over 105 million mobile subscribers. In 2014, 69 percent
of the population had neither an account in a formal financial institution nor a
mobile money account—hence were excluded from the formal financial
sector.28
The archipelagic structure of around 7,100 islands in the Philippines poses a
big challenge to financial access, with most people living a great distance from
financial services. Transporting money also has serious security concerns in the
islands. As of 2014, more than 605 of 1,634 cities and municipalities did not have
banks, and around 8 million people were living in these unserved areas (BSP
2015).29 Conversely, almost 43 percent of all deposit accounts in the Philippines,
amounting to 71 percent in value terms, were in the National Capital Region,
commonly known as Metro Manila, with a population of just over 12 million of
the Philippines’ 100 million population (Tayag 2014).
At a glance, therefore, the Philippines seems to be the ideal place for mobile
money to proliferate. Mobile-phone penetration is over 110 percent, and the
country is called the texting capital of the world, with over a billion texts sent
every day (GSMA 2014).30 The Philippines has the eighth largest number of
Facebook users in the world, and 36 percent of the population use the Internet.
Furthermore, the average monthly remittances from overseas Filipinos to their
beneficiaries in the Philippines have exceeded US$2 billion since 2013 (Martin
2017).31 Moreover, the policy makers and regulators are flexible in enabling
innovative money services to function. Hence the low mobile money user num-
bers continue to baffle the mobile money experts. While there can be many
constraints for mobile money adoption and digital inclusion in the Philippines,
this study examines the policy and regulatory aspects that help or hinder this
process.
Regulators Creating an Enabling Environment

The Ministry of Finance and Bangko Sentral ng Pilipinas (BSP) have played an
active role in creating an enabling environment to extend financial services to
the poor and rural regions of the country. BSP adopted the “test-learn-regulate”
model by allowing two nonbank institutions to offer e-money, and it issued
progressive regulations and guidelines. In doing so, BSP aimed to increase
financial outreach as well as to provide more options for people to receive
international remittances32 with the intention of reducing the cost of remit-
tances through increased competition. By issuing Circulars Nos. 240 and 269
in 2000, BSP enabled e-money issuance.33
Consequently, SMART Money piloted and launched a bank-led model in
partnership with Banco De Oro (BDO). Although Smart Communications
manages the product and branding, the underlying prepaid “e-wallet,” which
is not considered to be a deposit, is held with BDO and is also linked to a
SMART Money MasterCard debit card that can be used at ATM and POS
terminals.34

In 2004, Globe Telecom launched a nonbank-led model, GCash, through

a fully-owned subsidiary called G-Xchange Inc. by obtaining a license as a
remittance service provider. The acceptance of money by a nonbank was
deemed not to fall under the definition of banking, because no intermediary
function was completed by the on-lending funds so received. GCash funds
received by G-Xchange are held in partner commercial banks as wholesale
deposits. These flexible but ad hoc arrangements that enabled operation of
both types of e-money models were largely formalized under one regulation
with the issuance of Circular No. 649 in 2009. This circular regulates both
bank-led and nonbank-led models under one license for e-money issuers
(EMIs).
To better understand the technological developments and innovative
solutions offered by the service providers and the associated risks, in 2005
BSP established a specialized team of former bank examiners and informa-
tion systems experts, the Core Information Technology Support Group
(CITSG). CITSG on-site inspections follow COSO5335 guidelines on inter-
nal controls and, among other aspects, examine logical access controls, record
keeping, audit trail, disaster recovery, and business continuity planning. This
group studies mobile financial services and other electronic financial ser-
vices, their risks, and effective supervision methods. All specialists are certi-
fied in information systems auditing (Chatain et al. 2008). In 2006, guidelines
were issued on technology risk management to ensure that banks have the
knowledge and skills necessary to understand and effectively manage their
technology-related risks.36 In addition, guidelines for consumer protection
for e-banking were issued in 2006.37
Following the 2001 placement of the Philippines on the FATF list of non-
compliant countries and territories, both BSP and the Ministry of Finance
worked diligently to make progress toward implementing plans to fight ter-
rorism finance and money laundering. As a result, the Philippines was subse-
quently removed from the FATF watch list in 2005. The country demonstrated
a strong commitment to implementing an AML/CFT regime in the context
of its financial inclusion strategy. The AML regulation issued for mobile
money includes the conduct of KYC and CDD procedures, record keeping,
and reporting of suspicious transactions to the Anti-Money Laundering
Council.
Regulatory Barriers that Hinder Scaling-Up

Although progressive policies adopted by BSP in finding innovative solutions to
enable e-money operations by bank as well as nonbank EMIs resulted in success-
ful e-money deployments of both types of models, scaling-up of these operations
remains below expectations to date. In the absence of the Payment and
Settlement law,38 BSP proactively issued e-money regulations and operational
guidelines under BSP’s charter. Passage of the Payment and Settlement law will
provide greater clarity on the regulatory mandate and enhance BSP’s legal and
enforcement authority.

In the absence of such broader powers, it appears that some of the regulations
issued by BSP have had unintended consequences. Given the earlier blacklisting
by FATF, BSP had issued detailed AML/CFT guidelines, which were very restric-
tive on the use of agents. According to Circular No. 471 of 2005, all agents have
to be registered with the BSP as remittance agents by providing appropriate
documentation and are subjected to the AML Act. Such agents also have to
attend mandatory AML training seminars typically held in Manila.39 Additionally,
according to the guidelines, every time funds are transmitted or received
(cash-in/cash-out), the agents are mandated to maintain originator information
by requiring the sender to fill out personal information, recipient, and source of
funds, among other things. Transaction records are supposed to be kept for five
years. The ID check is carried out once, using one of the 20-plus ID types
approved by the BSP.40
Furthermore, the agents cannot perform opening of new accounts. Such oner-
ous rules are deterrents to the scaling-up of agent networks. As a result, the
outreach of the MNOs has been limited, and people who want to use these
services are discouraged. Authorities could consider allowing nonbank agents to
open customer accounts, allowing remote registrations with lower thresholds,
and allowing for tiered KYC procedures to encourage more agents and customers
to participate in the mobile money schemes.
Mobile money services are trying to gain traction in the payment and
funds transfer space against stronger and more established alternative chan-
nels, such as pawnshops for money transfer and banks or payment centers for
bill payment. It is, therefore, crucial that mobile money providers offer a
cheaper, less complicated solution to attract the lower-value segments.
Hence, simpler regulatory guidelines would enable mobile money providers
to compete in the low-income market by providing consumers with a low-cost and
effective option, thereby addressing many of the Philippines’ financial access
issues.
Maldives: Mobile Money Opportunity Still Knocking at the Door

The Maldives case study41 highlights why a unique solution developed to
address a distinct financial access problem was not successful because of coor-
dination issues at the macro level between the policy maker and the regulator.
Today, however, changed dynamics may provide a much-needed solution, as
forward-thinking policy makers and the regulators are trying to resolve the
persistent problem through a coordinated approach that would allow for a
low-cost, innovative digital solution.
The Special Financial Inclusion Challenge in Maldives

Maldives is a challenging environment to deliver access to financial services
through traditional bank branch networks. The country spans 1,190 low-lying
coral islands that stretch over 90,000 square kilometers of Indian Ocean,
99.5 percent of which is water. Nearly 338,400 people live on 200 scattered

inhabited islands in 26 atolls, and one-third of the inhabited islands have a popu-
lation of less than 500, while 71 percent of the inhabited islands have fewer than
1,000 people (MMA 2015). Although the number of bank accounts exceeded
the population by 2014, people living in the outer islands and atolls experience
difficulties in accessing financial products and services through traditional
banking outlets and existing financial infrastructure such as bank branches,
Internet banking, ATMs, and POS terminals.
The wide geographical dispersion and lack of financial institutions and
infrastructure translates into high transaction costs, decreased financial acces-
sibility, and greater security risks for people living and working in the atolls.
For example, people reportedly often send their ATM cards along with their
Social Security and personal identification numbers (PINs) through their
friends or relatives to withdraw cash (pension money, remittances, and other
receivables) from ATMs located in Malé or other islands where ATM services
are available. Thus, cash remains the dominant payment instrument in the
islands and outer atolls. Table 4.3 illustrates the increase in cash in circulation
from 2007 to 2014.
Bank of Maldives (BML) is the largest commercial bank, with 27 branches (of
which 20 are in atolls), 8 mobile Dhoni units,42 and 68 active ATMs (of which
27 are located in atolls). As of April 2014, the government of Maldives owned
62 percent of the shares of BML. The Bank recently launched self-service bank-
ing through 22 multifunctional ATMs installed across Malé and introduced its
first U.S. dollar ATM at BML headquarters in Malé. To facilitate payment
requirements of outer islands and atolls, BML operates an agent-based banking
solution backed by BML banking agents in 70 islands through Internet banking
and 3,610 POS card terminals (of which 1,087 POS merchants are in atolls
including resorts). BML provides clearing and settlements through its own
switch. According to BML, there is now a branch presence in every atoll in the
country except one.
From BML’s point of view, it is neither economical nor scalable to provide
agent-based banking services to all islands and atolls. In a rudimentary form,
BML operates cash-back POS facilities as part of its agent-based banking services.
By 2016, BML had announced plans to facilitate full person-to-person (P2P)
transactions through app-based mobile-phone banking facilities (already started)
and real-time POS transactions. This commitment was not fully realized.
Table 4.3 Cash in Circulation in Maldives, 2007–14

Year end Rf (millions)
December 2007 1,049.0
December 2012 2,475.5
December 2013 3,252.4
December 2014 3,099.4
Source: MMA 2015, table 7.1.
Note: Rf = Maldivian rufiyaa.

Meanwhile, many of the islands are still being served by BML’s Dhoni cash
distribution system and limited agent-based banking facilities. However, anec-
dotal evidence suggests that Dhoni banking is unreliable in some atolls, and the
payment services offered by BML are unaffordable, even for those who live in
Malé, because of relatively high transaction costs—a consequence of BML’s
dominant position. For example, BML’s own card customers are required to pay
2.5 percent of the total value of a transaction for using BML’s own POS machines,
which is relatively high compared with other countries in the South Asia region.
Hence, BML’s branch network, agent network, and infrastructure, although
expanding, still leave many smaller outlying islands unserved.
On the other hand, operations of the other commercial banks (established as
branches of foreign banks), with the exception of Maldives Islamic Bank Pvt.
Ltd., are largely confined to Malé and mostly serve the corporate clients.
Although Maldives Islamic Bank shows interest in community banking, other
commercial banks have little interest in developing banking services in the outer
atolls. A few nonbank institutions also operate POS acquisition services in resorts.
Hence, in terms of availability and affordability of financial products and services,
the solutions to date seem to have fallen short in providing adequate financial
and payment services.
Seeking a Unique Solution to a Distinct Problem

To enhance access to finance and provide convenient payment facilities to
people in the outer islands and atolls, in 2001, CGAP and the World Bank
together designed and funded the Mobile Phone Banking Project (World Bank
2015). The objective of the project was to build an integrated gross and retail
national payment system with a first-of-its-kind interoperable payment
switch that connects an interoperable mobile payment system (MPS, also
named Keesa)43 that would allow all cooperating Maldives-based banks and
all mobile telephone operators to share the payment infrastructure of the
country and take advantage of the extensive infrastructure of small shops on
all inhabited islands, which could serve as cash-handling points on behalf of
banks and MNOs. The Keesa system would have allowed subscribers to make
payments from and receive payments to these accounts via mobile handsets
and the Internet very conveniently. The system was installed at the Maldives
Monetary Authority (MMA), which completed the initial user acceptance
testing of the system in August 2011. The design and commencement of the
MPS was based on the memorandum of understanding (MOU) signed
between the banks and MMA.
Despite the technical completion of the system and willingness of most banks
to serve their customers through Keesa, the project could not be operationalized
because BML pulled out of the project during the last stages, citing business
reasons. Given that BML accounts for more than 60 percent of the market share
of customers and has 27 branches, its participation was crucial for the success of
Keesa. Many attempts were made by MMA to reassure BML and accommodate
its requests. MMA brought in added functionalities at the technical level to

minimize the cost of interfacing for the participating banks, such as various
reporting systems and a “Converter Gateway” to facilitate payments. However,
BML refused to participate despite the MOU.
Unfortunately, the regulator (MMA) was unable to persuade BML to par-
ticipate in a national system that was designed to help provide access to a
large segment of the society, and the major shareholder (Ministry of Finance
and Treasury) was unwilling to interfere in BML’s business decision. The project,
therefore, was closed in 2013, having only operationalized the real-time gross
settlement (RTGS) system and part of the automated clearinghouse (ACH)
and unable to operationalize the mobile banking and the interoperable pay-
ment switch. As a result, the outer islands and atolls still have limited finan-
cial access.
Positive Macro Dynamics: Collaboration between Policy Makers and

the Regulators
Having realized the practical difficulties in moving toward a national payments
switch in the short term given the market dynamics, MMA has now decided to
establish a nonbank-led mobile money solution to facilitate financial access in the
short term. Since MNOs are nonbank institutions that are not under the direct
supervision of MMA, it is necessary for MMA to legally allow them to enter the
payment space by issuing regulations governing the nonbank-led mobile solution
to manage any operational risks as well as to establish public confidence in the
proposed system.
MMA is keen to avoid overregulation and desires an interoperable, simple, and
moderately regulated solution with low maintenance costs. This idea was strongly
endorsed by the Ministry of Finance and Treasury. The Communications
Authority of Maldives also strongly endorsed an interoperable nonbank-led
mobile-money solution where both MNOs participate to maximize the value
proposition to the customers.44
This uniquely collaborative policy-regulatory drive had resulted in both
MNOs showing a strong interest in launching mobile money solutions.
Therefore, the government and MMA once again sought technical support
from the World Bank in their efforts to establish an enabling environment for
a nonbank-led mobile money solution aimed at enhancing access to financial
and payment services in the Maldives, especially in the outer islands and
atolls, and to ground this in a well-designed legal and regulatory framework.
The World Bank advised the MMA and the government on this process by
way of a Policy Note, and provided the technical support for this important
initiative.
Through two advisory engagements, the World Bank supported MMA and
the government. The first effort produced a May 2015 Policy Note entitled
“Maldives: A Mobile Money Operator-Based Mobile Money Solution,” which
provided a road map for implementing an MNO-led mobile money solution
(M-Wallet). On September 25, 2015, the World Bank’s FIRST Initiative
approved a three-year grant-funded technical assistance project entitled

“Maldives: Enabling a Non-Bank Mobile Money Solution.” The grant has pro-
vided the source of funds for expert advisory assistance to MMA, the govern-
ment, and Maldives’ MNOs to help implement (according to international best
practice) custodian and trustee arrangements, risk mitigation and consumer
protection, legal and regulatory amendments, and payment system oversight and
coordination mechanisms.
Progress is slowly but surely being made. The enabling regulation for MNO-
led mobile money solutions has been provided for under the Maldives Monetary
Authority Act while Maldives’ Payment Law still awaits enactment in Parliament.
With enabling regulation in place, both MNOs have activated e-wallets. While
interoperability and other synergies are still to come, the country is committed
to learning from the lessons of international good practice and to providing
greater levels of financial access to its citizens.
Notes
1. Global Findex Survey 2014 data, http://datatopics.worldbank.org/financialinclusion/.
2. Consult Hyperion was the lead information technology (IT) consultancy company
that developed the M-Pesa software.
3. Kenya financial inclusion data from Global Findex Survey 2014, http://datatopics
.worldbank.org/financialinclusion/.
4. The retail payments system includes automated clearinghouse (ACH) transactions,
automated teller machine (ATM) switches (Kenswitch and PesaPoint), over-the-counter
remittances, credit or debit card and point-of-sale systems, and e-money schemes
(mobile money and virtual money).
5. The “National Payment System Regulations, 2014” issued August 1, 2014, under the
National Payment System Act (No. 39 of 2011).
6. “Banking Correspondent” refers to a financial model in India whereby a representative
is authorized to offer services such as cash transactions where the lender does not have
a branch.
7. “Self-help group,” in this context, refers to a village-based financial intermediary com-
mittee that is most common in India, usually composed of 10–20 women.
8. Microinsurance is the protection of low-income people (those living on between
approximately US$1 and US$4 per day) against specific perils in exchange for regu-
lar premium payment proportionate to the likelihood and cost of the risks involved.
This definition is the same as one might use for regular insurance except for the
clearly prescribed target market: low-income people. The target population typically
consists of persons ignored by mainstream commercial and social insurance schemes,
as well as persons who have not previously had access to appropriate insurance
products.
9. Aadhaar unique ID and its link to DBTs are discussed in chapter 6 as a critical enabler.
For more information about the unique ID program, see the Unique Identification
Authority of India’s website: http://uidai.gov.in/.
10. CDMA (Code Division Multiple Access) and GSM (Global System for Mobiles) are
shorthand for the two major radio systems used in cell phones.

11. Global Findex Survey 2011 data, http://datatopics.worldbank.org/financialinclusion

/region/south-asia/.
12. Payment and Settlement Systems Act, No. 28 of 2005; Convention on the

Suppression of Terrorist Financing Act, No. 25 of 2005; Financial Transactions
Reporting Act, No. 6 of 2006; Prevention of Money Laundering Act, No. 5 of 2006;
Electronic Transactions Act, No. 19 of 2006; Payments Devices Frauds Act, No. 30
of 2006; Computer Crimes Act, No. 24 of 2007; and Secured Transactions Act,
No. 49 of 2009.
13. The Local Treasury Bills Ordinance, No. 8 of 1923; Bills of Exchange Ordinance, No.
25 of 1927; Registered Stocks and Securities Ordinance, No. 7 of 1937; Banking Act,
No. 30 of 1988; Evidence (Special Provisions) Ordinance, No. 14 of 1995; Consumer
Affairs Authority Act, No. 9 of 2003; Intellectual Property Act, No. 36 of 2003.
14. Convention on the Suppression of Terrorist Financing Act, No. 25 of 2005; Financial
Transactions Reporting Act, No. 6 of 2006; and Prevention of Money Laundering Act,
No. 5 of 2006.
15. The Budapest Convention on Cybercrime is also known as the Council of Europe
Convention on Cybercrime. It is the only available international treaty on the subject
seeking to address Internet and computer crime by harmonizing national laws,
improving investigative techniques, and increasing cooperation among nations.
16. LankaClear is owned by the CBSL and commercial banks.
17. National Development Bank partnered with Dialog Axiata, to offer the eZ Pay mobile
money service.

18. Mobile Payments Guidelines, No. 1 of 2011, for the Bank-led Mobile Payment
Services; and Mobile Payments Guidelines, No. 2 of 2011, for Custodian Account
Based Mobile Payment Services. The entry requirements stipulated in the “Service
Providers of Payment Cards Regulations, No. 1 of 2009” were further clarified in the
“Payment Cards and Mobile Payment Systems Regulations, No. 1 of 2013.”
19. Chinese mobile payments in general reached 1.7 billion transactions in 2013, up 213
percent from the previous year, according to figures the bank released earlier in 2013.
Those transactions were worth US$1.6 trillion, up some 317 percent from 2012. Alibaba
and Tencent are responsible for the bulk of those figures (Hernandez 2014).
20. “Legal certainty” is a principle that the law must provide those subject to it with the
ability to regulate their conduct. Legal certainty is internationally recognized as a
central requirement for the rule of law.
21. The Payment Cards and Mobile Payment Systems Regulation (No. 1 of 2013) replaces
the Service Providers of Payment Cards Regulation (No. 1 of 2009).
22. Although the Global Findex 2014 Survey shows 78 percent of the adult population
having access to formal financial institutions, there are definitional differences
between FinScope and Findex.
23. Data from Committee on Payments and Market Infrastructures (CPMI) 2016
“Statistics on Payment, Clearing, and Settlement Systems in the CPMI Countries,”
http://www.bis.org/cpmi/publ/d155.pdf. Formerly known as the Committee on
Payment and Settlement Systems (CPSS), established by the Bank for International
Settlements (BIS), CPMI monitors payment systems developments in its
23 member economies annually. CPMI member economies include Australia;
Belgium; Brazil; Canada; China; France; Germany; Hong Kong SAR, China;

India; Italy; Japan; the Republic of Korea; Mexico; the Netherlands; the Russian
Federation; Saudi Arabia; Singapore; South Africa; Sweden; Switzerland; Turkey;
the United Kingdom; and the United States.
24. These costs include higher direct costs such as fees as well as indirect costs such as
transport costs, loss of daily wages, and so on.

25. Bank of Thailand Notification No. SorNorSor. 9/2553: Guideline for Appointing
Banking Agents. (In terms of the guidelines, agent activities are restricted depending
on the type.)
26. By 2016, there were more than 9,542 7-Eleven stores throughout Thailand, 44 percent
of them in the Bangkok area. For more about CP All Public Company Ltd., see “CP
All,” https://en.wikipedia.org/wiki/CP_All.
27. ITMX was founded by the Thai Bankers’ Association as the ATM Pool Co. Ltd. in
1993, renamed as National ITMX in 2005. Created to satisfy Thailand’s requirement
to keep up with continuing global advancement in electronic commerce and payment
systems, its business policy follows the BOT’s Payment Systems Roadmap 2004.
28. Financial inclusion data from the 2011 and 2014 Global Findex Surveys, http://
datatopics.worldbank.org/financialinclusion/.
29. The Central Bank of the Philippines’ (Bangko Sentral ng Pilipinas, or BSP) National
Strategy for Financial Inclusion states that the presence of other financial service pro-
viders such as pawnshops, remittance agents, money changers or foreign exchange
dealers, e-payment service providers, mobile banking agents, nonstock savings and loan
associations (NSSLAs), and credit cooperatives have helped significantly to enhance
the access to financial products and services in the unbanked areas. Accordingly, this
relates to 50,000 touchpoints, reducing the unserved municipalities from 36 percent
to 12 percent (196 municipalities); however, the number of adults with accounts
remains unchanged (BSP 2015).
30. However, unique mobile subscribers were 50.9 million in 2014, with an average of
two SIMs per subscriber (GSMA 2014).
31. In 2014, 38 percent of Filipino adults were receiving remittances from a family mem-
ber abroad. There were more than 10 million overseas Filipinos in 2013. Remittances
reached an equivalent of 8.5 percent of the country’s GDP in 2014 (BSP 2015).
32. Overseas Filipinos send an average of US$2 billion per month in international remit-
tances, equivalent to 8.5 percent of GDP (BSP 2015).
33. Circular No. 240 of 2000 required all banks to obtain prior approval from BSP before
launching e-banking services, while Circular No. 269 of 2000 set out the approval
process for a new e-banking service.
34. The SMART Money service earns a commission on the bank interchange fee charged
to merchants using banks other than BDO.
35. The Committee of Sponsoring Organizations of the Treadway Commission (COSO)
is a nonprofit organization providing thought leadership and guidance on internal
control, enterprise risk management, and fraud deterrence.
36. Circular No. 511 of 2006.
37. Circular No. 542 of 2006.
38. A draft Payment and Settlement bill is in the parliament.
39. The BSP has agreed to allow EMIs to train their own agents and now allows them to
register many remittance agents with a single application. However, regulations are
yet to reflect these amendments.

40. There is no national ID in the Philippines, and the impact of having 20+ types of ID
documents is discussed in chapter 6, “Unique Identification.”
41. This case study was informed by the Policy Note entitled “Maldives: A Mobile Money
Operator-Based Mobile Money Solution,” prepared by Anoma Kulathunga and Ranee
Jayamaha (South Asia Finance and Markets Global Practice) as one of two outputs
from a World Bank mission to Maldives March 1–13, 2015. The mission team was led
by Thyra Riley.
42. Bank of Maldives PLC (BML), as Maldives' largest bank, provides financial services
throughout the country’s hundreds of atoll islands through 177 cash agents, 12 Self-
Service Banking Centers, and 5 Dhoni Banking Units.“Dhoni” refers to a traditional
multipurpose boat used in the Maldives. Dhoni Banking Units—comprising BML staff
teams—make over 2,000 trips a year to the distant atolls and outer atoll islands to pay
salaries and pensions, and to provide cash management services to agents and ATMs.
43. “Keesa” is Dhivehi for “wallet.”
44. Maldives has two MNOs: Dhiraagu and Ooredoo.
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CHAPTER 5
Innovative Uses of Infrastructure

and Digital Ecosystems
Introduction
The development of digital services offers a huge opportunity to advance financial
inclusion and develop new markets through business models that are viable for
the base of the pyramid. A critical first step is to ascertain that a conducive digital
ecosystem and infrastructure are in place that can reach down to the poor and
vulnerable. For innovative digital financial initiatives to become reliable conduits
for financial inclusion, they must be accessible quickly and efficiently to promote
fast, reliable, simple, and affordable solutions. A major challenge is putting in place
all of the elements needed to go the last mile in terms of connectivity.
This chapter focuses on the critical meso- and micro-level elements of
interoperability; agent network management; mobile money add-on applications;
and biometric-enabled, card-based grant payment disbursement systems. The
analysis highlights the efficiency and proactive use of each of these elements by the
case study countries in delivering results and reaching meaningful scale. In terms of
financial inclusion, scaling-up does not mean just commercial viability; it implies
reaching the unbanked masses in a sustainable manner. The case studies discussed
in this chapter have reached or have shown the potential to reach scale and have
demonstrated how the ecosystem and infrastructure can be used as a digital rail
system to deliver an array of affordable services to the poor and the vulnerable.
Interoperability in Indonesia, Pakistan, Sri Lanka,

Tanzania, and Thailand
Competitive market conditions should be fostered in the retail payments industry,
with an appropriate balance between cooperation and competition to foster,
among other things, the proper level of interoperability in the retail payment
infrastructure.
—World Bank, “Developing a Comprehensive National Retail
Payments Strategy”

106 Innovative Uses of Infrastructure and Digital Ecosystems
Results from the World Bank survey on innovations in retail payment instru-
ments and methods highlight that the majority of innovative products and
mechanisms have limited interoperability, meaning that information cannot flow
seamlessly between different operating systems and platforms (World Bank
2012a). Less than 20 percent of the products were reported to be fully or
partially interoperable. Around 25 percent of the products and services sup-
ported some mechanism to exchange funds with traditional payment products.1
Although interoperability is considered to be best practice, evidently it is the
exception rather than the norm.
Most digital financial systems launched are closed-loop systems and propri
etary. Hence, the ability for the customers to transact with another service using
a different provider’s platform is limited. On the other hand, enhancing the value
proposition to the customers and furthering the social agenda through interoper-
ability may have costs in terms of possible higher rates,2 lower levels of account-
ability, and lower levels of investment resulting from greater difficulty in capturing
revenues relative to proprietary or closed-loop systems. Hence, it is necessary to
evaluate what level of interoperability a country should aim for based on the
financial landscape, the desired or targeted level of deepening, and the strategic
policy agenda. Ideally, payment system interoperability involves the ability of the
various players such as banks, nonbank financial institutions, payment system
providers, mobile network operators (MNOs), card acquirers, governments, busi-
nesses, and customers to send, receive, and process funds, documents, and other
instruments electronically through a common channel.
“Interoperability” is defined as “a situation in which payment instruments
belonging to a given scheme may be used in platforms developed by other
schemes, including in different countries. Interoperability requires technical com-
patibility between systems, but can only take effect where commercial agreements
have been concluded between the schemes concerned” (World Bank 2012a). In
the context of retail payment, multiple levels of interoperability are identified:
systemwide, cross-system, and infrastructure-level. A system that has only system-
wide interoperability enables competition among the participants of that system;
a system that has cross-system interoperability enables competition between
systems; and a system that has infrastructure-level interoperability enables the
same infrastructure to be used to support multiple payment mechanisms.
Given the focus on mobile money as a digital means of reaching the under-
served, the study examines interoperability as one of the critical elements in
enhancing financial and payment access to the poor. When a country has more
than one MNO offering their own mobile money solutions on proprietary plat-
forms with their own operating rules and networks of agents, measures to
achieve interoperability among MNOs are likely to be needed to optimize
outreach to customers who are not served or who are underserved by the bank-
ing community and to benefit from economies of scale, as well as to discourage
anticompetitive practices.
In reality, mobile networks are interoperable at a technical level, just as banks
are. Banks are able to allow customers of another bank to use their automated

Innovative Uses of Infrastructure and Digital Ecosystems 107
teller machines (ATMs) at a higher fee, as do mobile networks and service pro-
viders for calls between them. Although interoperability may exist at this techni-
cal level, at a functional or more practical level, such limited interconnectivity is
not optimal.
In terms of mobile money interoperability, the important types are platform-
level interoperability (which permits customers of one service to send money to
customers of another service); agent-level interoperability (which permits agents
of one service to serve customers of another service); and customer-level interop-
erability (which permits customers to access their account through any sub-
scriber identification module [SIM]).
The most successful mobile operation, Kenya’s M-Pesa, is not a model for
interoperability as it is a closed-loop system. If an M-Pesa account holder wants
to send money to a non-Safaricom phone, they can do so and M-Pesa will gener-
ate a one-time code for them. The recipient will have to take this code to an
M-Pesa agent and must cash out; it is not possible to add to his or her e-wallet.
Hence, interoperability was not a factor in M-Pesa’s success.
Although M-Pesa’s market dominance acted as a barrier to interoperability,
interestingly, the recently passed Kenya National Payment System Regulations
2014 require “open systems capable of becoming interoperable with other pay-
ment systems in the country and internationally.” This newly minted provision in
the regulations helped the Kenyan Competition Authority to end agent exclusiv-
ity, so that agents are able to offer their services to any MNO.
Countries such as Indonesia, Pakistan, Sri Lanka, Tanzania, and Thailand have
launched mobile money initiatives with diverse types of interoperability. Experiences
from these countries are summarized in the subsections that follow.
Sri Lanka: World’s First Full End-to-End Interoperable Mobile Money System
When Dialog Axiata, Sri Lanka’s leading MNO, launched Sri Lanka’s pioneering
mobile money service, eZ Cash, in June 2012, Sri Lanka already had high inclu-
sion numbers, with banks and nonbank financial institutions serving all parts of
the island. The Global Findex Survey 2014 shows that 83 percent of adults had
formal accounts in 2014, up from 69 percent in 2011.3 In 2014, the share using
financial institutions for saving and borrowing were 31 percent and 18 percent,
respectively. Genderwise, Sri Lanka has the highest equality in the South Asia
region, with 83 percent of adult women having accounts. Furthermore, the poor-
est also show very high inclusion numbers at 80 percent, while adults in rural
areas recorded a high 83 percent (table 5.1).
From the beginning, Dialog Axiata understood that mobile money would be
one more option for the Sri Lankans, and that they would not likely be able to
have an exclusive large footprint. They further realized that to compete with the
already established financial sector, the products and services that Dialog offered
would have to be tailored to the customers and provide more in terms of cost-
effectiveness, convenience, and value. Because not many Sri Lankans use credit
cards or similar card instruments, Dialog championed the small but voluminous
transactions that the banking sector was unlikely to pursue.

Table 5.1 Financial Inclusion in Sri Lanka Relative to South Asia and Lower-Middle-Income
Countries, 2014
Percentage
Sri Lanka:
Population, ages 15+ years: 15.3 million
GNI per capita: US$3,170
Lower-middle-
income
Survey item Sri Lanka South Asia countries
Account (ages 15+ years)
All adults 82.7 46.4 42.7
Women 83.1 37.4 36.3
Adults belonging to the poorest 40% 79.8 38.1 33.2
Young adults (ages 15–24) 85.2 36.7 34.7
Adults living in rural areas 83.4 43.5 40.0
Financial institution account (ages 15+ years)

All adults, 2014 82.7 45.5 41.8
All adults, 2011 68.5 32.3 28.7
Mobile account (ages 15+ years)

All adults 0.1 2.6 2.5
Source: Global Findex Survey 2014, http://datatopics.worldbank.org/financialinclusion/.
Note: GNI = gross national income.
In an unprecedented move, Dialog invited other MNOs to share the eZ Cash

platform, with the wallet to be jointly held and managed. In the Sri Lankan market
at this stage, only Dialog and Sri Lanka Telecom Mobitel had e-wallets. In 2014,
Etisalat (the third largest MNO) and a few months later Hutch (the fourth largest
MNO) also joined (figure 5.1). Hence, eZ Cash has the distinction of being the first
mobile money system in the world to be end-to-end interoperable across multiple
service providers. Dialog, Etisalat, and Hutch operate eZ Cash as a single wallet.
Today, the eZ Cash client base has grown to over 2.8 million Sri Lankan
mobile users who are connected with 20,000 merchants and service providers
through the country’s largest mobile payment and transaction gateway. The com-
bined subscriber strength of the three MNOs—over 15 million, or more than 65
percent of the entire Sri Lankan population—now have instant seamless access to
the full portfolio of eZ Cash services, and can transact electronically via eZ Cash.
The Fully Interoperable Model

Dialog has enabled access to eZ Cash services via an unstructured supplementary
service data (USSD) menu by typing #111# on mobile phones. Etisalat and
Hutch subscribers who register for the eZ Cash service use the same USSD
menu. Even the costs (service charges) are the same (table 5.2). Interestingly,
Mobitel (the second largest MNO in Sri Lanka), which launched a separate
mCash wallet, has the same low fees.
The ability to simply dial in and self-register for the basic wallet without going
to an outlet or kiosk is hugely convenient. Dialog currently has over 20,000

Figure 5.1 Market Share of Sri Lankan Mobile Service Providers, 2014
3.1 million,
14%
1.54 million, 7.73 million,

7% 35%
4.64 million,
21%
4.86 million,
22%
Dialog Axiata Etisalat Hutch
SLT Mobitel Bharti Airtel
Lanka
Source: diGIT IT 2014.
Table 5.2 Transaction Cost Comparison for eZ Cash and mCash

Transaction type eZ Cash (SL Rs) Mobitel mCash (SL Rs)
Cash top-up FREE FREE
Send money
SL Rs 500 and below FREE FREE
Above SL Rs 500 5 5
Own bill payments (mobile, television, fixed line, Internet) FREE FREE
for Dialog, Etisalat, and Hutch
Utility bill payments (LECO, NWSDB [water], etc.) 20 20
Utility bill payments (CEB)
SL Rs 200 and below 10 10
SL Rs 200–1,000 15 15
SL Rs 1,000–5,000 20 20
Cash withdrawal
SL Rs 200 and below 5 5
SL Rs 200–500 10 10
SL Rs 500–1,000 20 20
SL Rs 1,000–3,000 60 60
SL Rs 3,000–5,000 100 100
table continues next page

Table 5.2 Transaction Cost Comparison for eZ Cash and mCash (continued)
Transaction type eZ Cash (SL Rs) Mobitel mCash (SL Rs)
Payment of goods at appointed merchants FREE FREE
Mini statement FREE FREE
Detailed printed statement 200 200
Balance check FREE FREE
Change PIN FREE FREE
Institutional payment FREE FREE
Sources: “eZ Cash Transaction Charges,” http://www.Ezcash.lk/pricing.php; “Transaction Limits and Charges,” Mobitel mCash,
http://www.mobitel.lk/mcash#Transaction Limits & Charges.
Note: CEB = Ceylon Electricity Board; LECO = Lanka Electricity Company (Private) Ltd.; NWSDB = National Water Supply and
Drainage Board; PIN = personal identification number; SL Rs = Sri Lanka rupees.
eZ Cash merchants around the country, and will continue to manage this agent
network, while adding any customer service networks of the new providers on
request. Dialog has also added to the network the flagship stores of Etisalat and
the Hutch shops that are located around the country. Dialog also manages the
back office and overall customer service issues that arise during the transactions.
But issues faced by customers that the two MNOs bring into the service will be
the responsibility of the respective MNO.
The system is enabled under the Payment and Settlement Systems Act
(No. 28 of 2005) by the Central Bank of Sri Lanka (CBSL) (figure 5.2). Hatton
National Bank acts as the custodian bank for the entire eZ Cash service, and the
trust agreement is administered by Deutsche Bank. A third-party service pro-
vider (KPMG)4 acts as the customer profile manager between the eZ Cash
platform and Etisalat and Hutch, so that none of the MNOs have access to the
customer profiles of the other.
The cost and fee structure is the same within the interoperable system. Sending
money is free below SL Rs 500 (US$4) and sending more costs SL Rs 5 (US$0.03),
while the fee for receiving money is staggered and ranges from SL Rs 5 (US$0.03)
to SL Rs 100 (US$0.75).5 As can be seen by these low, affordable fees, the MNOs
pass on value to consumers.
As for revenue sharing between Dialog and the other two providers, the trans-
action revenue from the eZ Cash service is shared with Dialog and covers the use
of the eZ Cash brand, eZ Cash platform, and merchant network. Etisalat and
Hutch save by not having to develop the mobile cash operation. As a result, shar-
ing (for a fee) the eZ Cash platform is a win-win situation for all.
Developments and Possibilities

To further its national agenda on financial inclusion, in July 2015 the CBSL gave
permission to Dialog to engage in the inward remittance business. Hence, for
the first time, a mobile money service in Sri Lanka is able to engage in foreign
remittance services. With its islandwide reach and over 16,000-plus agent loca-
tions, eZ Cash continues to revolutionize mobile payments in Sri Lanka.

Figure 5.2 Schematic of End-to-End Interoperable eZ Cash System
Sri Lanka eZ Cash

Interoperability at all layers of ecosystem, spanning 60+ percent of
mobile market
Custodian bank Central bank Trustee bank
Launched by Dialog Axiata in 2012

1.2 million registered customer base
Payment system provider 16,000+ merchants
Retail
Internet/e-commerce
Utility/e-government
Customer profile manager Modern channel
(managed by third party;
ex. E&Y/KPMG/PWC) Merchant network
Partner network
User experience (#111#)
aligned to eZ Cash
Tariffs aligned to
World’s first ever end-to-end interoperable mobile payments system eZ Cash
featuring common merchant/northbound partners, top-up/withdrawal P2P—at engagement
network and uniform consumer experience stage
Source: GSMA 2014. © Dialog Axiata. Reproduced, with permission, from Dialog Axiata; further permission required for reuse.
Note: E&Y = Ernst & Young; P2P = person-to-person; PWC = PricewaterhouseCoopers.
Remittances continue to be important to Sri Lanka, at around 9.6 percent of

gross domestic product (GDP) in 2015. Inward foreign remittances to eZ Cash
mobile wallets have been made possible via the partnership between eZ Cash
and HomeSend, a joint venture created by MasterCard, eServGlobal, and
Belgacom International Carrier Services, which enables cross-border and cross-
network value transfers. The partnership allows the migrant population overseas
to transfer funds directly to eZ Cash mobile money accounts.
Sri Lanka’s experience with interoperability is a success story for South Asia.
In March 2015, eZ Cash beat out worldwide competition to win the Global
Award for the Best Mobile Money Service at the annual Mobile World Congress
in Barcelona, Spain (DailyFT 2015).6 The MNO-based e-wallet system operated
by Dialog enables interoperability with other telecom operators; for the custodian
bank, the infrastructure is MNO-neutral. When the national switch operated by
LankaClear, the national infrastructure provider, links the mobile payment sys-
tems into the main platform, the e-money–based mobile operations will be able to
provide enhanced interoperable 24-7 real-time clearing and settlement facilities.
Thailand: Fully Interoperable ATMs and ADMs Easing Access

Thailand is diligently working toward systemwide interoperability. Already the
country’s multifunctional ATM and automated deposit machine (ADM)

network is fully interoperable. As previously discussed, this has enabled nation-

wide proximity to cash access as well as payment transactions.
The Bank of Thailand (BOT) has established the National Payment Message
Standard to support the use of corporate e-payment transactions. This standard
will significantly drive interoperability and straight-through processing, as well as
reduce the cost of electronic connectivity.7 The BOT payment systems group has
established a working group to develop a payment systems road map with the
objective of establishing common e-money standards and developing the infra-
structure for e-money to facilitate interoperability among different e-money
operators. However, BOT has decided to follow a market approach in determin-
ing the feasibility of future developments.
Pakistan: Interoperability between Banks and MNOs, Even for

Over-the-Counter Customers
Pakistan’s Easypaisa mobile money service became the first in the country to
interoperate with the existing banking structure through the Inter Bank Fund
Transfer (IBFT) service, which enables customers to transfer funds between a
number of banks via the 1LINK switch.8 The IBFT service is available to both
Easypaisa mobile account holders and over-the-counter (OTC) customers.
Easypaisa mobile account holders can now move funds between any bank
account and their Easypaisa mobile account, and OTC customers can walk into
any of the Easypaisa shops and deposit cash directly into any bank account.
With 40,000 shops in more than 750 cities, Easypaisa makes access to formal
financial services easier for Pakistan’s nearly 6 million unique Easypaisa account
holders, as well as any OTC customers. For a country that has less than 13 percent
of the population in the formal financial system,9 this is a significant step.
Tanzania: Industry-Led Interoperability

In Tanzania, use of mobile money is growing at a fast pace, as in Kenya (figure 5.3),
with the regulator taking a test-and-learn approach. By enabling nonbank entities
to offer payment services and working with the Tanzania Communications
Regulatory Authority on the oversight framework, the Central Bank of Tanzania
has shifted the regulatory approach to a mandate-and-monitor phase.
A key objective is to guide the market without stifling innovations or disrupt-
ing success, while balancing financial stability and consumer protection. Starting
from a modest 1 percent adult use of mobile financial services in 2008, Tanzania
experienced impressive growth to 90 percent access by 2013, with 43 percent
active use among the adult population (di Castri and Gidvani 2014a).
Even more impressive is Tanzania’s recent development of interoperability.
Working closely with the regulator, the industry experts from payment systems
and mobile money services worked through frequent meetings, debates, negotia-
tions, and eventually consensus to successfully put together a set of standards
that will govern how person-to-person (P2P) payments will be handled
across networks.10 The four main MNOs in the mobile money space (Airtel,
Vodacom, Tigo, and Zantel) have come together with two of the largest banks

Figure 5.3 Comparing Mobile Money Use in Tanzania and Kenya, 2007–13
25
21.9
Annual transaction values, US$, billions
20
17.8 17.7
15 13.5
10.6
10 8.4
5.4
5 3.4
1.9
0.18 0.6
0.1
0
2007 2008 2009 2010 2011 2012 2013
Kenya Tanzania
Source: di Castri and Gidvani 2014a.

Note: In 2014, US$1 = T Sh 1,627.47 (Tanzania shillings) or K Sh 86.45 (Kenya shillings).
(CRDB Bank and National Microfinance Bank) as well as the Bank of Tanzania
to craft a set of operational regulations for interoperability. Once the standards
are adopted, a common technical switch can be operationalized, if desired.
According to the International Finance Corporation (IFC 2015), the Tanzanian
mobile market is fairly evenly distributed among the larger three players, without
undue market dominance of any one player (figure 5.4). Hence, there is a healthy
competitive environment and broad customer awareness of mobile payments as
a tested and proven service. For the process of establishing interoperability of
mobile financial services, this meant that there was relative parity in negotiating
power between market actors and greater value in interoperating for both cus-
tomers and providers because of the potential number of connections. Global
Findex 2014 data show that the percentage of adults included had jumped from
11 percent in 2011 to 40 percent in 2014, with 32 percent included through
mobile accounts.11 If interoperability works as planned, Tanzanians will not only
be able to send money through the network but also connect to banks as well.
In the meantime, Tigo and Vodacom signed the mobile money interoperability
agreement in February 2015, thereby connecting M-Pesa and Tigo Pesa custom-
ers in Tanzania. Nearly 4 million Tigo Pesa customers and 7 million M-Pesa cus-
tomers will be able to transact with each other. The process is still ongoing, and
it remains to be seen how much fruit this collaboration will bear. Another impor-
tant interconnect collaboration is happening between the East Africa region’s
two biggest mobile money operators, Vodafone Group and MTN Group. This
will enable convenient and affordable international remittances between M-Pesa
customers in the Democratic Republic of Congo, Kenya, Mozambique, and
Tanzania and MTN Mobile Money customers in Rwanda, Uganda, and Zambia.
Hence, interoperability seems to be picking up in the Africa region.

Figure 5.4 Active Subscriber Market Shares of Tanzanian Mobile

Service Providers, 2014
Zantel,
3%
Airtel Money,
21%
Vodacom M-Pesa,
47%
Tigo Pesa,
29%
Source: IFC 2015.
Indonesia: Multi-Wallet Interoperability

Indonesia is the world’s fourth most populous country, with a population of
around 245 million, over 60 percent of whom are of working age. Indonesia has
the same archipelagic barriers to connectivity and access that Maldives and the
Philippines have, but on a much larger scale. Indonesia has over 17,500 islands,
of which over 6,000 are inhabited and around 1,000 are permanently settled.
Driven largely by domestic demand, Indonesia’s economic growth is on an
upward trajectory, and connectivity and financial access are becoming increas-
ingly important to Indonesians.
The Global Findex 2014 data show that only 36 of adult Indonesians have
access to the formal financial sector;12 of those, 27 percent save at a financial insti-
tution, while 13 percent borrow. Given the country’s dispersed geographic struc-
ture, connectivity to formal financial institutions via traditional bank branch and
ATM networks will always remain a problem. Although Indonesian mobile pene-
tration is comparable to its peers in the region, its banking services are relatively
underdeveloped (figure 5.5). With mobile-phone penetration at over 100 percent,
Indonesia is in the perfect position to use mobile money to enhance financial
inclusion. Indonesia currently has six mobile money schemes.13
Regulatory Bottlenecks
Regulatory barriers have inhibited the growth of agent and branchless banking
in Indonesia. The central bank, Bank of Indonesia (BI), did not allow agency
banking. Any person providing money transfer or cash withdrawal service needed

Figure 5.5 Financial Account and Mobile-Phone Penetration, Indonesia versus

Selected Asian Countries, 2014
160
140
Market penetration, percent
120
100
80
60
40
20
0
Indonesia Malaysia Thailand Vietnam
Debit card penetration
Bank account penetration
Mobile-phone penetration
Source: Ernst & Young 2014.
a money transfer license. Also, outsourcing of opening accounts or know-your-

customer (KYC) assessments was not allowed, and no concessions were made for
the inherently low risk of low-value transactions.
Although regulations have been issued allowing nonbanks to offer e-money,
until recently, any person wishing to start a money remittance or cash-out service
had to obtain a license as a money remitter. This was not feasible for small busi-
nesses, which were discouraged from applying for licenses. As such, people in the
outer islands and rural communities had severely limited opportunities to obtain
financial services. To withdraw money from an e-wallet, a person has to go to an
outlet managed by their own operator; with only around 25 outlets nationwide
for each operator, mobile money was not a viable option in rural areas. Realizing
the regulatory bottleneck, however, BI issued Fund Transfer Regulations in 2013,
effectively paving the way for mobile money agents to offer cash-in/cash-out
and account-opening services. As a result, thousands of agents started signing up
(Camner 2013).
Industry Collaboration on Multi-Wallet Interoperability

Realizing that they have more to gain by working together and pooling resources
than by competing with each other to cover the geographically challenging ter-
rain, discussions among three MNOs—Telkomsel, Indosat, and XL (Axiata)—led
to the decision to interoperate. Recognizing the opportunity present in the pay-
ments market, these MNOs decided to interoperate yet keep their own identities
by way of a multi-wallet interoperable arrangement.
On May 15, 2013, just six months after the discussions started, the ground-
breaking scheme was launched, allowing customers of the three MNOs to

transfer and cash out money from any location across each other’s network.
Cash-ins are currently a cost for each mobile money deployment but may lead
to other more lucrative businesses, such as bill paying, other payment services,
banking, and so on.
Most important in this operation is the continuous dialogue among the
members. They still need to iron out many issues, some of them industrywide,
others system-specific. A primary concern is the protocol for customer grievance
and redress. They have already decided to address each operation bilaterally, and
end-of-the-day net settlement is to be done by the custodian bank in real time
with the BI payment system. Managing Anti-Money Laundering and Combatting
Funding of Terrorism (AML/CFT) regulations and training staff to perform KYC
and customer due diligence (CDD) duties in a tiered fashion and moving toward
risk-based supervision are other important aspects.
These measures are expected to lead customers to develop faith in the system
and, over time, to transition toward e-money transactions. Anecdotal evidence
suggests that many people still do not understand the value of mobile banking.
A survey carried out by Financial Inclusion Insights (FII 2015) found that only
around 3 percent of Indonesians were aware of the concept of mobile money,
and those who were aware had heard of only one type of service (figure 5.6).
Awareness raising is very important.
Figure 5.6 Mobile Money Awareness in Indonesia, 2014
Indonesian Inclusion
Many Indonesians don’t have access to banks, but they do have access to mobile phones that could provide
financial services—yet few have ever heard of such mobile services.
Borrowed from 42
friends or family 42 Own or can 84
borrow a
mobile phone 68
Percentage of respondents
Percentage of respondents
Adults (+15) with 36

bank accounts 20
Saved at a 27 Own a 72
financial institution 15 mobile phone 52
Adults with 26
debit cards 11
Have heard of a 8
money mobile
Borrowed from a 13 provider 3
financial institution 9
0 10 20 30 40 50 0 10 20 30 40 50 60 70 80 90
Percent Percent
2014 2011 Urban Rural
Source: Schonhart 2015. Adapted with permission from Dow Jones, Inc. Further permission required for reuse.
Note: Left chart: Survey conducted of 1,000 respondents May 18–13, 2011, and May 3–June 4, 2014. Margin of error is +/−3.6 percentage points.
Right chart: Survey of 6,000 respondents conducted August–November 2014. No margin of error provided.

Banks in Indonesia are fully interoperable and have established their payment
and clearing services and ATMs. However, agent banking is yet to pick up. The
majority of ATM transactions are actually payments, not cash withdrawals, indi-
cating that there is a demand for self-service electronic payments. Opening up
interoperable services for MNO-led e-money is a smart early move, and MNOs
have gained on the banks. By building consumer trust and awareness, they can
secure this potentially untapped market. Either way, with a broader range of com-
petitive services to choose from, consumers will be the winners.
Agent Network Management in Kenya

You can buy a Coca-Cola anywhere in the world, but affordable products that
provide essential value like water treatment or lighting often do not reach
billions of poor populations around the globe. However, in what is commonly
known as the “last mile distribution challenge,” some social entrepreneurs are
providing innovative solutions to make the last mile a first opportunity.
—Nicolas Chevrollier and Stéphanie Schmidt,
“Overcoming the Last Mile Challenge: Distributing Value to Billions”
The world’s best innovative solution or product could fail to achieve its objec-
tives if the last mile problem is not solved in a cost-effective manner. Making the
final connection between consumers and the service or the product has often
proven to be disproportionately expensive to solve, or sometimes may be forgot-
ten in the focus on technological and other important problems. Chevrollier and
Schmidt (2014) sum up this reality:
A majority of the population in developing economies live in rural areas often
accessible only by poor quality road infrastructure. Furthermore, geographical isola-
tion or limited access to relevant information disconnects populations in many
developing countries from any business value chain. The consequence—which can
affect both urban and rural populations—is that products providing essential value
either do not reach the intended customers or are more expensive or lower quality
than the standard products that are accessible by other populations.
These challenges hold for financial services as well. Comparing case study
experiences of success in e-money deployments in some cases with inability to
reach a seemingly feasible target in others, the manner in which the last mile
problem is addressed is a critical element that often makes the difference. Even
if all the key elements appear to be in place—progressive regulators pass enabling
regulations, an innovative technology model exists that would be seamless in
operation, and there is supporting physical infrastructure or connectivity—if the
human element of the customer is not taken care of, the intended goal of wide-
spread, low-cost access to financial services by the poor may not be achieved.
According to the GSMA (2014), on average, there were 2.3 million mobile
money agent outlets globally in developing countries in 2014 (figure 5.7).
This is 4.3 times the average density of bank branches in these markets, which

Figure 5.7 Number of Financial Access Points across Developing

Countries, 2014
2.5
2.0
Access points, millions
1.5
1.0
0.5
500,000 501,000 524,000 1,376,000 2,260,000

0
Western Union Post offices Commercial ATMs Mobile money
agent locations bank branches agents
Source: GSMA 2014.

Note: ATMs = automated teller machines. GSMA data from the Mobile Money for the Unbanked (MMU)
Deployment Tracker, the 2014 Global Adoption Survey of Mobile Financial Services, and MMU estimates
and forecasts. The countries surveyed included those classified by the World Bank in 2014 as “developing
countries” plus four countries that were not on that list: Chile, Qatar, Singapore, and the United Arab Emirates.
total 524,000. In three-quarters of the 89 markets where mobile money is avail-

able today, agent outlets outnumber bank branches. In 25 of those markets,
there are more than 10 times as many mobile money outlets as bank branches.
The ability of the MNOs to reach the customer and their last mile advantage
is undeniable, as they already have extensive touchpoints by way of airtime
agents. Although that might bode well for the success of any MNO-led mobile
money initiative, this is not necessarily the case. While the number of registered
accounts highlights the growing ubiquity of mobile money, the number of active
accounts is more important to understand the speed at which customers
are adopting mobile money services. At the end of 2014, out of 255 live mobile
money initiatives across 89 countries, 21 services had more than 1 million
90-day active accounts, seven of which passed this threshold during 2014
(GSMA 2014).
For any mobile money or digital financial service to reach the base of the pyra-
mid, therefore, building efficiency and quality into the agent network is a critical
element in success. The agents perform registration, facilitate cash-in/cash-out, and
also act as brand managers and awareness builders. Hence it is important that they
are recruited wisely and trained on how to perform KYC and CDD duties, adhere
to AML/CFT standards, manage liquidity, address consumer complaints, build
awareness, and promote the service. Interpersonal skills are important, too: one
main advantage of these last mile touchpoint agents often is that they are already
well known in the area that they serve.

As mobile money initiatives grow in scale, the challenge of managing the

network of agents is compounded, possibly stalling growth if not carefully struc-
tured. Examining M-Pesa’s agent network management offers crucial insights
into how Safaricom (the mobile network operator that developed M-Pesa)
recruits, trains, and manages its vast network of agents to reach high levels of
efficiency.
Winning with Superior Agent Network Management

The dominance of M-Pesa in Kenya is partly due to the efficient management of
its vast network of agents. Today M-Pesa has 26 million users (around 18 million
active, as against 35 million deposit accounts in the entire banking sector), who
transact through nearly 130,000 agents, with a deposit base of K Sh 1.8 billion
and K Sh 7 million in loans issued monthly (CBK 2016; Maina 2017). The fact
that M-Pesa has raised Kenya’s financial inclusion from 26 percent to 70 percent
underscores the importance of the whole agent operation (Johnson 2012).
Agent Recruitment
Before the launch of M-Pesa, it was difficult to imagine the entrance of an MNO
into the field of financial services. The existing network of dealers that Safaricom
used to distribute airtime seemed the obvious choice to facilitate M-Pesa transac-
tions by providing cash-in/cash-out (CI/CO) services. An airtime dealer is an
independent company, typically with 5–20 retail outlets, selling airtime, mobile
phones, and other goods. These dealers quickly agreed to become M-Pesa agents
because of their trust in the Safaricom brand. Agents have to register the customers
by performing KYC/CDD checks, educate customers on available digital options,
and perform CI/CO functions.
To support rapid growth, Safaricom initially had to ensure that enough agents
were recruited to provide a viable service for users and, subsequently, balance
the number of agents with the numbers of customers to ensure that agents had
profitable businesses while customers did not face overcrowding and long wait-
ing times. The service was going to be successful only if a large network of agents
and customers was quickly established. Despite some initial lag in the growth of
agents relative to the growth of customers, engagement of agents picked up in
2009 and brought the agent-customer ratio down from a peak of 1 to 1,000 in
mid-2008 to about 1 to 600 by the end of 2009, and subsequently kept pace
(figure 5.8) (Davidson and Leishman 2012; Jack and Suri 2014). If Safaricom
had gotten the pace of scale-up wrong, M-Pesa could easily have failed.
In the early stages, Safaricom was able to use its reputation to bridge the gap
in trust that is typical for new products and services. Agents trusted that Safaricom
could launch a new profitable service, and consumers trusted Safaricom’s brand
enough to experiment with the new system. Safaricom enjoys greater consumer
confidence and trust than do many banks, and it is still Kenya’s most admired
brand. To support the launch and growth of M-Pesa, Safaricom needed to build
an ecosystem of actors. Each actor needed to be incentivized for Safaricom to
grow M-Pesa without compromising the quality of customer service.

Figure 5.8 Growth in Number of M-Pesa Customers and Agents, 2007–14
20 100
Customers, millions
80
Agents, thousands
15
60
10
40
5
20
0 0
8
4
7
9
00
01
01
01
01
01
00
00
-2
-2
-2
-2
-2
-2
-2
-2
ar
ar
ar
ar
ar
ar
ar
ar
M
M
M
Customers Agents
Source: Safaricom.
Table 5.3 Roles and Responsibilities in M-Pesa Agent Structure

Safaricom/ Agent network
Roles and responsibilities M-Pesa Superagent Aggregator Agent managers
M-Pesa business strategy √
Selecting agents * √ *
Providing equipment √
Providing start-up capital √
Agent rebalancing √ *
Agent training * √
Agent monitoring * √
Source: World Bank.
Note: √ = primary responsibility; * = some involvement.
The roles and responsibilities of these different actors have necessarily evolved
over the course of M-Pesa’s existence. That evolution has been pivotal to
M-Pesa’s success as it grew from start-up (albeit with sound corporate backing)
into a major provider. The roles and responsibilities of agents, aggregators, agent
network managers (ANMs), and superagents are summarized in table 5.3 and
detailed in table 5.4.
Incentive Structure
Since M-Pesa’s launch, agents have been incentivized to acquire customers for
M-Pesa with a K Sh 40 (US$0.47) commission paid when they sign a customer and
a further K Sh 40 when that customer makes his or her first deposit into an M-Pesa
account. A staggered commission is also given to agents for each deposit that they
receive and each withdrawal that they facilitate. It is free for customers to sign up
and free to deposit, with charges levied on withdrawals and P2P payments.
Safaricom invested heavily in its agent channel. Commissions to agents to register
4 million customers cost the company US$5 million (Mas and Morawczynski 2009).

Table 5.4 Detailed Roles and Responsibilities in M-Pesa Agent Structure

Safaricom M-Pesa
Issues e-money 1:1 against cash held in M-Pesa trust accounts
Superagent
• Direct relationship with Safaricom (usually a bank)
• Purchases e-money from Safaricom and sells to agents
• Accepts deposits of cash from agents
• Retains 1% commission on e-float sales
• Deposits funds into M-Pesa trust account
Aggregator
• Agent with direct relationship with Safaricom
• Purchases e-money from superagent (or Safaricom)
• Deposits cash with superagent (or into M-Pesa trust account)
• Recruits, trains, and monitors a group of agents (subagents)
• Manages cash and e-money for group of agents
• Retains 20% of subagent’s commission
Agent
• Agent with direct relationship with Safaricom
• Purchases e-money from superagent (or Safaricom)
• Deposits money with superagent (or into M-Pesa trust account)
• Registration of M-Pesa customers
• Depositing cash into registered customers’ M-Pesa accounts
• Processing cash withdrawals for registered M-Pesa customers
• Processing cash withdrawals for nonregistered M-Pesa customers
• Customer education
• Compliance with Safaricom AML and KYC policies
• Compliance with Safaricom business practices
• Branding of their outlets per Safaricom-provided guidelines
Subagent
• Registered with Safaricom
• Purchases e-money from its aggregator
• Deposits cash with aggregator or into bank account of aggregator
• Customer care and compliance as per agent
Agent network managers
• Firms tasked by Safaricom to provide agent training and monitoring
• Check branding of M-Pesa agents
• Circulate branding materials, posters, and M-Pesa registers
• Carry out mystery shopper checks on AML and KYC compliance
Source: World Bank.
Note: AML = anti-money laundering; KYC = know your customer.
Even agent aggregators are incentivized to support customer growth with a K Sh 10

(US$0.12) commission for each new customer their agents sign (Omwansa and
Sullivan 2012). Although the M-Pesa commission offered to agents is lower than
that for airtime sales, M-Pesa still makes sense for agents.
The business case for agents has been important since the launch of the
service. A Consultative Group to Assist the Poor (CGAP) study of rural and
urban M-Pesa agents 18 months after the launch of the service revealed some of
the reasons to become an agent (Mas and Morawczynski 2009). The noncommis-
sion benefits include being associated with Kenya’s best-known brand and
attracting increased foot traffic in shops. This was and remains particularly

important for rural agents, where M-Pesa brings cash into the villages; the cash is
spent locally, usually in an agent’s shop.
M-Pesa generated nearly three times more revenue than mobile-phone airtime
revenue for the typical agent. Average daily commissions for selling airtime were
US$3.78 compared with average daily commissions of US$10.65 from M-Pesa
transactions. (This had to be offset by the agent’s cost of travel to the nearest
bank branch, which cost up to US$5, as well as lost revenue if the shop was
closed during travel.)14
The business case for individual agent outlets depended on their costs of rent
and wages (if it was not an owner-operated business), the return on their capital
tied up in the M-Pesa float, and any losses to theft. At the average number of
transactions, an M-Pesa agent needs US$1,341 to maintain his or her float and
cash balances. The cost of capital may be a borrowing cost or an opportunity cost.
Many aggregators strongly discourage borrowing to maintain working capital,
because the additional expense undermines the profitability of the business. For
the average agent, the largest proportion of costs is associated with rebalancing—
that is, management of liquidity between cash and e-float—estimated at US$1.13
per daily transaction; although the introduction of more superagents may have
lowered this cost over time. The average M-Pesa agent was profitable at 53 trans-
actions per day, but only if wages and rent were low.
Awareness Building
At the same time that it was incentivizing agents to promote the service, Safaricom
invested in a massive advertising campaign with the simple proposition: “Send
Money Home.” The advertising budget was spent in a big splash to support the rapid
uptake of service. M-Pesa offered just three features: the ability to cash-in and cash-
out at agents’ locations; send money P2P; and buy airtime direct from Safaricom.
As M-Pesa began to take off, Safaricom had to invest in regular system
upgrades. This massive investment can be seen in Safaricom’s financial results for
fiscal year 2008, the first year of M-Pesa’s launch: capital expenditures were up
by 41 percent, and sales and advertising were up by 92 percent. To execute this
massive project, Safaricom had ensured buy-in from senior management, includ-
ing from the chief executive officer (CEO), and established a dedicated business
unit to manage M-Pesa. It is estimated that Safaricom spent US$30 million over
the first three years to launch M-Pesa (Omwansa and Sullivan 2012).
Agent Structure
MNOs such as Safaricom have a built-in advantage as mobile money service
providers because of their experience in building and managing agent networks
for the distribution of airtime. Safaricom’s approach to agent network manage-
ment grew from airtime distribution, but it evolved over time to ensure a consis-
tent customer experience and a viable business proposition for agents. As M-Pesa
grew, Safaricom needed to constantly balance the number of agents with the
number of customers; this was to ensure high enough commissions for agents
without overcrowding outlets so much as to cause customer dissatisfaction.

Figure 5.9 Initial M-Pesa Agent Network Structure
a. Initial period b. Initial expansion with subagents
M-Pesa Safaricom M-Pesa Safaricom

trust account M-Pesa trust account M-Pesa
Agent Agent
Subagent
head office head office
Agent Agent
outlet Agent outlet Agent
Agent outlet Agent outlet
outlet outlet
Cash e-float
Note: Blue arrows indicate deposit of cash. Orange arrows indicate e-float crediting.
The initial arrangement of players in the M-Pesa system is shown in figure 5.9,
panel a. During this initial period Safaricom directly recruited M-Pesa agents from
its pool of existing airtime dealers. These agents offered M-Pesa service through
the outlets that they directly owned. In these early days, M-Pesa agents were
required to have an outlet in at least three provinces; this was later relaxed to
three outlets, and they could have subagents (figure 5.9, panel b). Safaricom
maintained a direct contractual relationship with all agents at this time. Figure 5.9
also shows the flows of cash and e-float between the various parties, a process
described in the “Expanding E-float and Cash Management” subsection.
Outsourcing Agent Network Training and Management

In the first couple of years after launch, there was exponential growth of both
agents and customers. Safaricom centrally controlled the agent network in the
very early stages of M-Pesa, but the rapid growth in agents quickly led it to out-
source critical components of agent management. M-Pesa had 10 regional man-
agers across the country who were responsible for agent management. But with
the massive expansion of the network, regional managers now primarily manage
firms tasked with agent management.
These contracted ANMs helped Safaricom scale their agent network quickly,
while continuing to provide high-quality, consistent service to customers. The
first ANM that Safaricom recruited was a Kenyan marketing firm, Top Image,
which was given the specific responsibility of training agents, distributing market-
ing and business material, and monitoring agents. Top Image also helped to design
a training curriculum.
Training standards are defined by Safaricom and implemented by the ANMs.
The ANM trains new M-Pesa agent staff on how to operate M-Pesa successfully
and explains how to manage liquidity and how to comply with KYC and AML
rules and requirements. Then a simple test is used by the ANM to determine
whether prospective agents are ready to serve customers, in terms of both staff
and outlet readiness. Top Image is responsible for the delivery of marketing and
business materials to all M-Pesa outlets. Business tools include the agent tills,

transaction books, and registration books. They also distribute marketing and
branding materials and make sure that these are properly displayed at all M-Pesa
outlets, including M-Pesa tariff posters.
By 2011 Top Image was monitoring more than 80 percent of M-Pesa agents
(23,000). At the time, Top Image had a team of 92 trade development representa-
tives across the country monitoring M-Pesa agents (250 agents per trade develop-
ment adviser). During fortnightly visits these representatives use a 10-point
checklist to assess the agent outlet. Items that are checked include whether the
outlet has enough cash and e-float and whether the logbooks are in good order.
They also carry out “mystery shopper” checks on their KYC and AML procedures.
Safaricom now uses a number of ANMs in addition to Top Image to provide
it with information about the M-Pesa agent network and its performance. Firms
like Top Image are paid a fixed fee for their service, rather than being offered a
commission split. This is to ensure that they independently monitor agent
outlets, and that there is not a disincentive to report poor compliance—with
Safaricom’s KYC and AML procedures, for example.
As businesspeople clamored to become M-Pesa agents, existing agents made
informal arrangements with outlets that they did not own or operate (figure 5.10).
While these subagent outlets were not owned by the original M-Pesa agent, they
served to supplement the outlet distribution. Thus the roles of aggregator and sub-
agent evolved organically as an informal arrangement that had the tacit approval of
Safaricom. Among the more than 10,000 M-Pesa agents, over 50 percent were
subagents of aggregators. Agents acting as aggregators usually retain 20–30 percent
of subagents’ commissions, but sometimes as much as 50 percent. There were a
number of problems with subagents, who did not have a direct relationship with
Safaricom, in particular inconsistent branding, inadequacy of float, and poor
Figure 5.10 M-Pesa Agent Network Structure with Formal Introduction of

Aggregators
M-Pesa Safaricom
trust account M-Pesa
Aggregator Subagent
Subagent
Subagent
Subagent
Cash e-float

knowledge of AML procedures. These challenges resulted in a further refinement

of Safaricom’s agent network structure.
In late 2009 Safaricom began to reassert its control over the entire agent net-
work (Flaming, McKay, and Pickens 2011). The role of aggregator was officially
recognized. Aggregator agents were tasked with an active role in subagent train-
ing and monitoring. At the same time, the maximum portion of commission that
an aggregator could take from their subagents was capped at 20 percent. In addi-
tion, subagents were required to establish a direct contractual relationship with
Safaricom. Given some of the complaints that subagents had about unscrupulous
aggregators, Safaricom also mandated that a subagent could become an agent in
their own right after three months with their aggregator.
Aggregators identify potential subagents according to their own criteria, such
as outlet location, whether there is a large customer base, and whether the area
is undersupplied by existing M-Pesa outlets. ANMs like Top Image then vet
applicants and provide initial training. The incentive for aggregators is to recruit
and manage agents who generate profits from high volumes of business. The
economics differ between an aggregator’s own locations and those of a subagent.
An aggregator location needs sufficient revenue to cover the cost of at least
one full-time employee and rent, these costs being higher in urban areas than
rural areas.
A CGAP study looked at the business case in 2011 when the average number
of transactions per day for an agent outlet was 53 (Flaming, McKay, and Pickens
2011). An aggregator’s own rural agent could generate profits of US$60 on
53 transactions, but an urban aggregator agent could not generate profits until
80–100 transactions had been carried out. The 20 percent commission share
on subagents represents US$41 profit for an aggregator from subagents with 53
transactions per day. The average aggregator with 100 agents is quite profitable,
but this profitability rests on owning a large proportion of the agent outlets that
they manage.
CGAP’s financial modeling shows that customer transaction fees provide the
primary source of revenue within M-Pesa. M-Pesa retains 58 percent, aggregators
take 8 percent, and agents receive 34 percent. In addition, Safaricom profits from
airtime sales on the M-Pesa platform, at the same time making savings on airtime
distribution. There are additional benefits to Safaricom from increased average
revenue per user and reduced churn rates.
Expanding E-float and Cash Management

Agent recruitment is vital to M-Pesa, and so is the efficient running of their
daily business: the management of their stocks of cash versus e-money (a
relationship called “e-float”). Safaricom required K Sh 100,000 in working
capital from prospective agents, and this was split 50-50 between e-float and
cash. The typical urban-to-rural remittance pattern in Kenya means that an
agent in an urban location generally has more deposits and hence a greater
need for e-float, while a rural agent typically handles a larger number of with-
drawals and needs greater stocks of cash. If an agent runs out of e-float, he or

she will not be able to accept any more cash deposits, and an agent who has
run out of cash cannot process cash-outs. The management of liquidity is
essential to ensure continuous customer service. Hence, Safaricom provides
training on this essential activity. Agents manage liquidity by depositing cash
in a bank account in exchange for e-float. This active management of liquidity
is referred to as “rebalancing.”
Safaricom issues e-money to agents on a 1-to-1 ratio against the money
held in the M-Pesa trust account; hence, no money is created. Since M-Pesa’s
inception, the funds of all M-Pesa customers have been held separate from
Safaricom in a trust account held by a prudentially regulated bank. The
Commercial Bank of Africa (CBA) held the first M-Pesa trust account. (CBA
continues to hold an M-Pesa trust account, but the monies are now also split
between three additional banks in Kenya to reduce risk.) In the early days,
Safaricom was centrally issuing e-float to aggregators, who then distributed it
to their subagents. The process did not appear to be well automated, as delays
of two to four days in issuing e-float were regularly reported by agents. This
tied up agents’ working capital and limited the volume of business that they
could support.
To provide greater liquidity and much speedier rebalancing for agents,
Safaricom introduced the “superagent” concept (figure 5.11). In May 2009,
Safaricom unveiled its first M-Pesa superagent, Kenya Commercial Bank
(KCB). Safaricom also made an agreement with KCB to provide collateral back-
ing for agents at favorable rates. KCB additionally provided overdraft protection
Figure 5.11 Current M-Pesa Agent Network Structure and E-float/Cash

Management Process
M-Pesa Safaricom
trust account M-Pesa
Superagent
(bank)
Aggregator Agent
Subagent
Subagent
Subagent
Cash e-float

for agents’ working capital delivered through M-Pesa. Safaricom has continued
to recruit banks as superagents to provide vital liquidity services to the agent
network. Superagents deposit funds directly into an M-Pesa trust account and are
issued with e-float by Safaricom, which they then sell to agents for a 1 percent
commission. Although it is still possible for agents to buy e-float directly from
Safaricom, in practice this is done infrequently. Banks, acting as superagents, pro-
vide agents with dedicated tellers in their branches and instant delivery of e-float
after a cash deposit. Barclays Bank and Ecobank joined as superagents shortly
after KCB, helping to formalize a new financial ecosystem of which banks are an
essential part. (Superagents were then also able to offer bulk payment services to
their corporate customers via M-Pesa.) Most agents rebalance their cash/e-float
holdings daily with the help of the bank network.
Another tool to assist agents in e-float management is the management SIM,
which enables aggregators to speedily credit e-float to subagents. Aggregators can
use an online interface that allows for more streamlined and speedy e-float
management. Subagents either deposit float with their aggregator or directly into
the aggregator’s bank account. Through the management SIM, the aggregator is
notified when a subagent has made a cash deposit at the bank, and hence they
immediately release e-float. This eliminates the delay incurred when waiting for
subagents to present teller deposit slips to the aggregator. The speed of rebalanc-
ing allows agents to be more flexible with their working capital; if they are in an
urban area, where the predominant activity is taking deposits, they can hold
more in e-float.
To summarize, Safaricom controls the business strategy for M-Pesa and sets
the rules for the various actors. Safaricom defines the requirements for becoming
an agent and manages the overall recruitment process, but it is the aggregators
who select and manage these agents for vetting by the ANM and for approval
by Safaricom. Agent training and monitoring is outsourced to an ANM like
Top Image. The agents are responsible for providing their own phone and start-
up capital. Banks act as superagents to rebalance agent e-float and cash levels
on demand.
Because each market is different, it is hard to generalize the M-Pesa model and
expect that a similar mobile deployment would necessarily thrive in another
country environment. What is more important is to appreciate how M-Pesa
understood the agent network as a critical enabler and evolved it dynamically to
suit the market’s needs. The levels in the network were not predetermined but
evolved to fill a gap or to formalize a practice that seemed to work. Safaricom
was a dynamic, hands-on manager that realized early on that, left to its own
devices, sooner or later the market would find a solution, and ensured that this
took place within established boundaries.
Mobile Money Applications as the Digital Ecosystem

Many emerging markets lack the core infrastructure (national switches and
settlement systems, connectivity, even electricity) required for innovative

payment systems to operate reliably. One option that addresses this pain-
point is Eseye’s innovative machine-to-machine (M2M) technology. By
embedding SIM chips into solar-powered lighting units, Eseye has created a
remote device management system enabling prepaid and pay-as-you-go
(PAYG) financing via M-Pesa in East Africa. Prepaid customers buy
exactly as much light as they need, while PAYG customers see their lights
go out if they miss a payment. The payment options enabled by Eseye’s
technology and its relationship with M-Pesa circumvent infrastructure short-
comings in East Africa by operating through mobile channels. Without this
technology, customers would have to pay up front or borrow in order to
purchase the system. With it, many more people are gaining access to solar
lighting.
—Monica Brand Engel and Jackson Scher, “Four Barriers—and Four
Solutions—to Financial Inclusion through Payment Innovations”
Competition is increasing in many markets as mobile money becomes a main-

stream product for a growing number of operators. Two or more mobile money
services operate in 56 markets, while 36 markets have three or more ser-
vices (map 5.1). In three markets—Pakistan, Sri Lanka, and Tanzania—MNOs
interconnected their services following the example of MNOs in Indonesia,
where domestic interoperability was implemented in 2013 (GSMA 2014).
Hence the question is no longer whether mobile money services are available,
but how to ensure that the industry continues to grow sustainably.
Map 5.1 Number of Live Mobile Money Services for the Unbanked, by Country, 2014
IBRD 43078 | AUGUST 2017
One mobile money service

Two mobile money services
Three or more mobile money services
Interoperable markets
Source: GSMA 2014. © GSMA. Reproduced, with permission from GSMA; further permission required for reuse.
Note: GSMA data from the Mobile Money for the Unbanked (MMU) Deployment Tracker, the 2014 Global Adoption Survey of Mobile Financial
Services, and MMU estimates and forecasts. The countries surveyed included those classified by the World Bank in 2014 as “developing countries”
plus four countries that were not on that list: Chile, Qatar, Singapore, and the United Arab Emirates.

Figure 5.12 Mobile Money Transfer Value Chain
MNO network
Take cash-in/ Hold deposits,
for data Move money
cash-out settle (Forex)
transmission
MNO Bank or third party Bank FI-led

Business models
MNO Bank or third party Bank
MNO Bank
MNO MNO-led
Source: Gencer 2009. © mPay Connect. Reproduced, with permission from mPay Connect; further permission required for reuse.
Note: FI = financial institution; MNO = mobile network operator.
Sustainability of mobile money services need not focus solely on providing the
basic functions of CI/CO, bill payment, and money transfer. Moving along the
value chain for an MNO starting from simple CI/CO to becoming a full-fledged
banking agent is a possibility, depending upon the regulatory framework in a
country (figure 5.12). The possibility of being a platform for the digital ecosys-
tem for millions of subscribers is an enticing prospect. Government payments,
social grant programs, and payrolls are some of the services that could be deliv-
ered via mobile money platforms. In Kenya, applications (apps) have been
designed by independent private sector developers. In partnership and by fee-
sharing agreements with Safaricom, M-Pesa has provided the infrastructural
foundation upon which these value-added services have been built, thereby
greatly extending M-Pesa’s digital connections and thus Kenya’s movement
toward a cash-lite society.
Innovative Mobile Applications Enabling Movement toward a

Cash-Lite Economy
Mobile payment–based e-money solutions can be operated even under trying
geographical circumstances and locations. Unlike ATMs, point-of-sale (POS)
operations, and Internet and telephone banking services, mobile e-wallet solu-
tions do not require broadband connectivity. Most modern-day mobile
money solutions are operated using simple 2G phones—usually available at a
cost of less than US$20 dollars per handset and thereby affordable to poor
people. Because of the simplicity of the technology—requiring neither
Internet service nor 3G or 4G connectivity—it is possible for MNOs to pro-
vide e-money services in faraway and outer islands and atolls in countries like
Maldives and the Philippines.

Figure 5.13 M-Pesa Service Development, 2007–13
M-Pesa M-Pesa
2007
2013
• CI/CO at agents • CI/CO at agents
• P2P national • P2P national
• Airtime top-up • Airtime top-up
• CO ATMs
• Bill payment
• Link to banking products
• Merchant payments
• Bulk payments
• P2P international
Source: World Bank and Safaricom 2017 data.

Note: ATMs = automated teller machines; CI/CO = cash-in/cash-out;
CO ATMs = cash-out-only ATMs; P2P = person-to-person.
M-Pesa was launched with an intentionally basic functionality, focused on

CI/CO, P2P, and buying airtime. This provided a clear proposition that agents
and customers could understand and adopt. Today, as figure 5.13 details, the
functionality is significantly richer. As functionality was added, it opened
opportunities for other businesses, particularly financial institutions, to use
the system.
Table 5.5 shows the timeline of M-Pesa expansion of functionality and ser-
vices, and some of the most important enabling applications are summarized in
subsequent pages. Since M-Pesa’s launch in 2007 Safaricom has continued to
enrich the offer with additional services and features. This customer-centric
approach has increased the utility of M-Pesa for more and more users. The key
service enrichments (table 5.5) highlight those services that were introduced
onto the platform following negotiations and agreement by private developers
with Safaricom (some were not successful).
It is also useful to note that Safaricom has a financial incentive for the expan-
sion of the digital ecosystem that also well serves the customer, micro- and
small businesses, and microfinance institutions (MFIs) as well as the economy.
In this regard, commissions to M-Pesa agents are now the largest direct cost of
running M-Pesa. Safaricom’s 2013 first-half results show that K Sh 5 billion
(US$60 million) was paid out to M-Pesa agents, compared with voice and short
message service (SMS) interconnect costs of K Sh 3.09 billion and airtime com-
missions of K Sh 4.65 billion.
Given the high cost of incentivizing agents to provide CI/CO services,
Safaricom naturally wants to encourage M-Pesa users to spend their e-money
within the ecosystem instead of cashing out. Developing M-Pesa’s financial eco-
system enables M-Pesa customers to perform more digital transactions, resulting
in more transaction revenues for Safaricom, but also less agent commission pay-
ments for cash-out, and a further profitability boost. Building the M-Pesa ecosys-
tem to provide opportunities for more non-agent-based transactions increases
the velocity of money on the platform.

Table 5.5 Timeline of M-Pesa Expansion of Functionality and Services, 2005–13

Year Service name Description
2005 Sambaza Airtime sharing
MFI pilot Loan repayment tool
2007 M-Pesa Payment service
2008 PesaPoint ATMs Cardless ATM withdrawals from M-Pesa account
Postbank M-Pesa agent
Old Mutual Top-up unit trust accounts
2009 KPLC Bill pay through M-Pesa for electricity utility
SMEP MFI loan repayment through M-Pesa
KCB Superagent providing liquidity to M-Pesa agents
Kenswitch ATMs Card to any M-Pesa account from 650 ATMs
2010 Equity ATMs Cardless ATM withdrawals from M-Pesa account
Musoni MFI disbursing loans and receiving individual repayments
through M-Pesa
M-KESHO Equity Bank account accessed through M-Pesa
Nunua na M-Pesa Pay at Naivas and Uchumi supermarkets with M-Pesa
2011 Lipa Karo na Pay school fees with M-Pesa through PesaPal and KCB
M-Pesa
Visa prepaid card Safaricom and I & M Bank cobranded card topped up directly from M-Pesa
Western Union International money transfer from 45 countries directly to M-Pesa account
M-Bima-Jijenge Endowment plan from CIC Insurance with daily contributions of K Sh 20
Savings Plan (US$0.23)
Kilimo Salama Crop insurance from UAP Insurance
Mbao Pension scheme for the informal sector with daily contributions of K Sh 20
(US$0.23)
2012 Linda Jamii Health insurance
M-Shwari Microcredit and microsavings product
2013 Lipa na M-Pesa Pay merchants with M-Pesa at no charge to customers
Lipa Kodi Pay rent with M-Pesa
Source: World Bank.
Note: ATM = automated teller machine; KCB = Kenya Commercial Bank; MFI = microfinance institution.
Merchant Payments
M-Pesa was designed for individual use—which is fine if you are paying your taxi
driver, as he just uses his personal account—but how do individual tellers in a shop
reconcile M-Pesa with their till? Consumers in Kenya pay US$12.8 billion to other
consumers (30 percent of their payments), but they pay US$29 billion to busi-
nesses (69 percent of their payments). The balance of US$0.3 billion (1 percent
of payments) is paid to the government (Bill and Melinda Gates Foundation
2013). The greater opportunity is therefore in merchant acceptance.
At the end of 2010, Safaricom entered into its first merchant agreement,
which would allow customers to pay with M-Pesa at the supermarket
chains Naivas and Uchumi. By 2011, however, M-Pesa had only 100 individual
stores signed up, and it took an innovative merchant acquirer, Kopo Kopo

(“transactions”), to convince Safaricom of the potential opportunity. A huge

amount of money is circulating digitally through M-Pesa, but there was no easy
way to use it to pay for things. Kopo Kopo managed to convince Safaricom to
change its charging structure to launch a new service. Instead of customers
paying tiered fees for transactions, merchant payments would be free for cus-
tomers, with the merchant paying a fee of 1.5 percent. Safaricom signed a
merchant aggregator agreement with Kopo Kopo in March 2012. But Safaricom
was not satisfied with an arrangement in which only Kopo Kopo acquired mer-
chants on their behalf. They also started aggressively recruiting merchants
themselves, directly competing with Kopo Kopo and targeting 100,000 mer-
chants in the next six months.
Lipa na M-Pesa was launched in June 2013. Although Safaricom has a
contractual relationship with Kopo Kopo, two months after launch Safaricom
dropped the merchant fee to 1 percent without notice, which Kopo Kopo has
matched. This 1 percent merchant fee to accept M-Pesa is significantly lower
than the 2.5 percent typical for accepting payment cards. In addition, Safaricom
has not shared its application programming interface (API) with Kopo Kopo,
meaning that any changes on the M-Pesa platform can cause knock-on headaches
for Kopo Kopo. Kopo Kopo has recruited 10,000 merchants onto its platform,
about a third of the merchants on Lipa na M-Pesa. They are recruiting at a rate
of 1,500 per month.
Kopo Kopo enables small and medium enterprises (SMEs) to accept, process,
and manage mobile money payments. But, given that it is in direct competition
with Safaricom, it has to do more. MasterCard statistics show that 90 percent of
small businesses still track payments via pen and paper (Miller and Salazar 2013).
Kopo Kopo’s platform offers a number of tools online or in a mobile app to help
merchants track customers and transaction trends; they also offer real-time set-
tlement to bank accounts.
Following half-year results in 2013, Safaricom stated that it intended to continue
growing M-Pesa by growing Lipa na M-Pesa and cashless distribution, e-commerce,
transport payments, bank-to-M-Pesa linkages, and uptake of savings and loans pro
ducts (Safaricom 2013). Safaricom’s plans for a near-field communication card
management system may indicate its desire to move further still.
PesaPal is another company providing merchant services. Its focus is to enable
merchants to accept mobile money, Visa, and MasterCard for online payments.
Merchants are charged 2.7 percent of the value of transactions to access these
payment channels. PesaPal payments also settle through a bank account, meaning
that merchants do not have to be official partners with Safaricom, which settles to
M-Pesa. PesaPal has been particularly successful helping schools to accept electronic
payments. It is also investigating utilizing mobile point of sale (M-POS) to economi-
cally serve small merchants for card payments. PesaPal also offers individual users a
PesaPal e-wallet. Users can top up their virtual wallets through PesaPoint ATMs,
M-Pesa, Airtel Money, or yuCash and then make payments directly from it.
Another online and mobile payment platform is JamboPay, launched by tech
firm Webtribe in 2009. JamboPay now has 700 businesses and over 100,000

users on its platform (Matinde 2013). The JamboPay service provides value to
merchants by aggregating multiple payment channels such as M-Pesa, Airtel
Money, yuCash, Orange Money, Visa and MasterCard debit and credit cards, as
well as direct bank account debiting and crediting. JamboPay was the 2013–14
winner of the Google Innovation Award in the financial sector category.
One of the first service enhancements was the use of ATMs to provide M-Pesa
account holders, who are not bank account holders, with 24-7 access to cash. This
approach was pioneered in Kenya, but the relatively low stock of ATMs (fewer
than 2,500) limited the extension of mobile money. This approach is much more
interesting in countries with large numbers of ATMs—for example in Thailand,
where more than 50,000 ATMs can be used for mobile money CI/CO (Pénicaud
and Katakam 2014). Another service, the bill payment function, was designed as
a way for customers to pay their utility bills directly from their phones without
having the inconvenience of waiting in long lines. Kenya’s electricity utility was
the first company to accept bill payment through M-Pesa.
M-Pesa’s huge customer base is larger than that of any bank or other financial
sector organization in Kenya. As a result, after banks initially criticized the system
and even lobbied the Central Bank of Kenya (CBK) to close it down, they started
joining M-Pesa. Postbank was the first bank to join M-Pesa as an agent, just five
months after launch. Today numerous banks and MFIs are linked to M-Pesa,
enabling them to receive funds from customers through the bill-pay function, and
smaller numbers of banks have a USSD link that integrates their customers’
accounts with M-Pesa, enabling their customers to move money to and from
M-Pesa 24 hours a day (table 5.6).
Table 5.6 Banks and MFIs Linked to M-Pesa, 2013

# Bank or MFI Bank to M-Pesa (US$) M-Pesa to bank (PayBill)
Banks
1 African Banking Corporation (ABC) Bank ¸
2 Bank of Africa ¸ ¸
3 Barclays Bank K Ltd. ¸ ¸
4 CfC Stanbic ¸ ¸
5 Chase Bank ¸ ¸
6 Citibank N.A. Kenya ¸
7 Commercial Bank of Africa ¸ ¸
8 Consolidated Bank Ltd. ¸ ¸
9 Co-operative Bank ¸ ¸
10 Diamond Trust Bank ¸ ¸
11 Ecobank ¸ ¸
12 Equatorial Commercial Bank ¸
13 Equity ¸ ¸
14 Family Bank Ltd. ¸ ¸
15 First Community Bank Ltd. ¸ ¸
16 Gulf African Bank ¸ ¸

Table 5.6 Banks and MFIs Linked to M-Pesa, 2013 (continued)

# Bank or MFI Bank to M-Pesa (US$) M-Pesa to bank (PayBill)
Banks (continued)
17 Housing Finance Company Ltd. ¸ ¸
18 I & M Bank Ltd. ¸ ¸
19 Imperial Bank Ltd. ¸
20 Jamii Bora Bank ¸
21 Kenya Commercial Bank ¸ ¸
22 K-Rep Bank ¸ ¸
23 National Bank ¸ ¸
24 National Industrial Credit Bank Ltd. ¸ ¸
25 Post Office Savings Bank ¸ ¸
26 Prime Bank ¸
27 Standard Chartered Bank ¸ ¸
28 Transnational Bank ¸ ¸
29 United Bank for Africa ¸
MFIs
30 Faulu DTM ¸ ¸
31 KADET Ltd. ¸ ¸
32 KWFT DTM ¸ ¸
33 Musoni ¸ ¸
34 Rafiki DTM ¸ ¸
35 SMEP DTM ¸ ¸
36 Uwezo DTM ¸
Source: Safaricom 2013.
Note: DTM = Deposit Taking Microfinance; KWFT = Kenya Women Finance Trust; MFIs = microfinance institutions.
ATM Transactions: Third-Party Providers

PayNet was the first company in the world to initiate cardless ATM transactions
when its PesaPoint ATMs became cash-out locations for M-Pesa in July 2008.
This provided M-Pesa users with 24-hour access to funds in their mobile money
accounts. This is particularly interesting from a financial inclusion point of view
because it not only increased the revenue for ATMs but also exposed cardless
M-Pesa users to an important piece of mainstream payment infrastructure,
increasing their knowledge and understanding of it.
PayNet is a financial services support company that is best known in Kenya
for its PesaPoint-branded independent ATM network. PayNet started its indepen-
dent ATM network in 2005 in an effort to support interconnected services. It has
180 PesaPoint-branded ATMs and 34 banks on its network, interconnecting
800 ATMs. The company aims to interconnect as many financial institutions as
possible. Its ATMs provide shared infrastructure for small- and medium-size
banks and a backup network for the larger banks. PesaPoint charges just K Sh 30
for ATM transactions.
PayNet also provides a debit and credit card processing center for banks, acts as
a third-party issuer for Visa and MasterCard, and runs a POS-enabled agent net-
work selling mobile airtime. The company also offers a wage payment system
called Wagepoint that issues closed-loop cards and places ATMs at employers’ sites.

This service is primarily used by employers of large numbers of unbanked workers,

such as flower and tea farms, that have previously relied on time-consuming cash
payment arrangements. Closed-loop cards are also made available to savings and
credit cooperatives and MFIs.
Musoni Microfinance: Using M-Pesa as Its Core Banking System

Musoni (M for “mobile” and usoni meaning “future”) was established in 2009 to
showcase how a cashless and paperless MFI could be transformative. Musoni uses
electronic payments through mobile money for all loan repayments and dis-
bursements as well as deposits and withdrawals of savings.
One of the reasons that a pre-M-Pesa pilot with Faulu, a large Kenyan MFI,
failed was because of the MFI’s concern that using mobile money for loan repay-
ment would undermine its group-lending methodology. Musoni, however, has
managed to adopt the technology without undermining its group-lending
methodology. Instead, it has used M-Pesa as its core banking system to reduce costs
and increase the quality of service to customers. Musoni has effectively outsourced
the expense of cash handling to M-Pesa. (Musoni estimates that approximately
50 percent of resources in a typical MFI are consumed by cash handling.) The
company’s branches have very low costs because they have no safes or security
measures in place; branches are merely convergence points for purely administra-
tive purposes. Loan officers are much more efficient than in traditional settings, as
they do not have to spend any time banking. Field branch offices are also paperless,
having digitized all parts of the application process with the use of tablets.
Since Musoni issued its first loan in May 2010, it has disbursed 18,000 loans
totaling K Sh 500 million (US$6 million). Musoni’s minimum loan size is US$58,
and its average loan size is US$500. It currently serves 8,000 clients and handles
50,000 transactions per month through its proprietary M-Pesa-based core bank-
ing system. The company’s loan book stands at US$3.5 million, with nonper-
forming loans at zero. It believes that the quality of its loan book is in part due to
the financial discipline provided by using mobile money.
Musoni has a 100 percent repayment record because groups need to pay the
day before their loan meeting. Group meetings are a maximum of one hour in
length, and this time is used exclusively for training, including business manage-
ment, public hygiene, current affairs, and introduction of useful products and
services, which helps to motivate attendance. Most repayments are after 5 p.m.
and on Sunday, when people have time that does not impinge on their daily busi-
ness activities. Musoni’s solution allows the disbursement of loans within 24 hours
of application directly to a borrower’s M-Pesa account. It also provides privacy in
loan repayment while being supported by the group guarantee.
M-Shwari: Savings and Loans

M-Shwari is a bank account, available only through M-Pesa, that can be used for
savings as well as a means to access microcredit. M-Shwari was launched in
November 2012. It is a product of the partnership between Safaricom and
CBA, although most customers are unaware of the bank’s involvement.

Safaricom already had a long-standing relationship with CBA: as a corporate cli-

ent, CBA held the first M-Pesa trust account. (CBK still holds an M-Pesa trust
account, but funds are now split among three banks.) CBA is a bank for corpo-
rate customers and high-net-worth individuals with a strong focus on technology.
The success of M-Shwari has boosted its customer base from just 37,000 to
5 million, the second largest bank customer base behind Equity Bank.
Since its launch, M-Shwari has reached nearly 9.2 million customers, with
deposits of almost US$1.5 billion and loans of US$277.2 million (figure 5.14
and table 5.7). The speed of uptake is remarkable, possibly indicating a large
unserved market. M-Shwari loans are available in a real-time credit to an indi-
vidual’s M-Pesa account. To qualify for a loan, an applicant must have been an
M-Pesa subscriber for at least six months, and then an algorithm based on their
use of M-Pesa and airtime purchases is used to determine the initial loan limit.
Figure 5.14 Growth in Number of M-Shwari Savings Accounts, 2013–14
10
M-Shwari savings accounts, millions
9.2
9 8.1
8 7.6
7.0
7
6 5.0
4.8
5 4.0
4
2.9
3
2
1
0
Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4
2013 2014
Period
Sources: CBA 2013; Cook and McKay 2015.
Table 5.7 Key M-Shwari Statistics

Measurement Statistics
Total savings accounts 9.2 million opened
7.2 million unique customers
4.7 million active 90 days
Total number of loans 20.6 million cumulative loans since launch
2.8 million unique borrowers since launch
1.8 million active as of December 2014
Deposit amounts US$1.5 billion deposited since launch
US$45.3 million deposit balance as of December 2014
Loan amounts US$277.2 million disbursed since launch
US$17.7 million outstanding as of December 2014
Average savings balance K Sh 504 (US$5.56)—all accounts
K Sh 911 (US$10.06)—active 90 days
K Sh 1,971 (US$21.76)—active 30 days
Nonperforming loans 2.2 percent over 90 days
Sources: CBA 2013; Cook and McKay 2015.
Note: K Sh = Kenya shillings.

This microloan product is serving the base of the pyramid with a minimum loan
size of just K Sh 100 (US$1.15), a maximum loan size of K Sh 20,000
(US$235), and an average loan size of K Sh 305 (US$3.50). Loans are for
30 days and have a 7.5 percent fee. The majority of loans (70 percent) are
repaid before the one-month due date. Backers suspect that this is an indication
of the importance of this line of credit to individuals. Subsequent loan limits are
based on the levels of regular savings with M-Shwari and customers’ repayment
history on the initial loan.
These customers are below the threshold of most MFIs. M-Shwari is a very
different product from a typical MFI loan, which takes a long time to obtain
while a group is formed and savings are accumulated as security against a loan.
In addition, this product provides a confidential service on an individual basis.
CBA spent two years in product development for M-Shwari, using data
from the FinAccess Survey and receiving some assistance from Financial Sector
Deepening (FSD) Kenya (FSD Kenya and CBK 2013). The survey showed that
people believe savings should be free and held with a trusted person or institu-
tion. Focus group discussions revealed that individuals want their bank both close
and far. M-Pesa, people said, made it too easy to access one’s money. They needed
structure to help them with savings discipline, but they also wanted flexibility.
CBA uses the digital footprint that users develop through their use of M-Pesa
and airtime purchases to prescore them for credit. This allows CBA to offer a truly
unsecured loan. CBA then makes a real-time query of the National Population
Register to verify identity. (CBA is the first nongovernment user of the database.)
CBA is happy to remain in the background of this product, given the reputation
of Safaricom versus the banks in Kenya. The aim was for the product to break
even in a little under two years, but it broke even in just eight months.
Multi Media Mobile: An App that Facilitates International Remittances

Multi Media Mobile (MMMobile) is a software company that provides interop-
erability between the card and mobile money ecosystems by facilitating card-to-
M-Pesa transactions through an app on a user’s phone. The company believes
that cards will form the predominant digital payment technology in the future.
However, at the moment, mobile money predominates in Kenya. Hence the
company’s approach is to build trust in cards through M-Pesa. The SMS and
USSD platforms used by mobile money cannot support the level of security
associated with card encryption, yet the public in Kenya trusts M-Pesa over cards.
The company’s initial target market is for international remitters, who link the
card they want to use to the MMMobile app, allowing them to send money to
any mobile money account in Kenya. They are also targeting tourists who want
to buy from smaller merchants who do not have card acceptance devices; the
MMMobile app allows them to still have the security of not carrying cash while
allowing them to pay through mobile money, which is more readily accepted.
This innovation has the potential to trickle down to lower-income users.
As with M-Pesa, lower-income individuals’ first experience of the system may be
by receiving funds from a friend or family member. MMMobile again broadens

individuals’ remittance ecosystem to cardholders based anywhere in the world. It

is particularly interesting to note that it is not a requirement to hold a bank
account for either a sender or a recipient. A sender could transfer funds from their
prepaid account to a mobile money account and in the future from card to card.
Additional Important Lifestyle Services for the Bottom of the Pyramid

M-Bima: Savings and Life Insurance. In 2011 the CIC Insurance Group, the third
largest insurance company in Kenya, introduced a new technology platform
called M-Bima (“mobile insurance” in Kiswahili) to strengthen the scale and effi-
ciency of its microinsurance operations. The platform allows customers to send
their premiums via M-Pesa and Airtel Money, through the PayBill function. CIC
does not charge its customers for transfers into the M-Bima account and even
bears the Safaricom charges of K Sh 30 for each transfer.
The first product, launched in 2011 on the M-Bima platform, was the Jijenge
Savings Plan. Clients can save as little as K Sh 20 (US$0.23) a day using M-Pesa
or Airtel Money and receive SMS reminders to stimulate savings. The product
provides clients with a convenient and safe way to build savings. It is a 12-year
endowment plan with monthly installments of a minimum K Sh 600 (US$7) for
a minimum coverage of K Sh 50,000 (US$580). The product combines savings
with life insurance. Immediate coverage is provided for accidental death and,
after three months, for natural death. An exit benefit is available at the end of the
third year, with a surrender value of K Sh 20,000. Customers can cash out their
savings from the third year but can also take the money as a loan from their own
account. The target customers are those employed in the informal sector with
low and erratic incomes. The product was developed with assistance from
the Microinsurance Innovation Facility, housed at the International Labour
Organization’s Social Finance Programme.
Kilimo Salama Plus: Crop Insurance. In February 2011 UAP Insurance and the
Syngenta Foundation extended their insurance product for smallholder farmers
with Safaricom and M-Pesa. The low-cost mobile-phone payment and data system
is linked to automated, solar-powered weather stations to issue an insurance pol-
icy and rapidly compensate farmers for investments in seeds, fertilizer, and other
inputs that are lost to either drought or flood. Kilimo Salama (“safe farming”) is
the largest agricultural insurance program in Africa and the first to use mobile-
phone technology to speed access and payouts to rural farmers. Farmers purchase
Kilimo Salama Plus through local agrodealers, who use a camera phone to scan a
special bar code that sends the policy to UAP over Safaricom’s mobile data net-
work. Premiums are collected at the store and sent via M-Pesa to UAP.
This index-based weather insurance relies on the data collected and relayed
from 30 weather stations. When data from a particular station indicate rainfall is
either 15 percent above or below historical averages and hence likely to signifi-
cantly reduce crop yields, all farmers with a policy registered with that station
automatically receive payouts directly to their M-Pesa accounts at the end of
the growing season. Kilimo Salama is supported by the International Finance

Corporation, the Global Index Insurance Facility (which is supported by

the European Commission), and Syngenta Foundation for Sustainable Agriculture
(Syngenta Foundation 2011).
Mbao Pension Scheme. The Mbao pension scheme targets the estimated 8.9 million
informal workers in various sectors of the economy. At the press launch of the
scheme in June 2011, the chairman of the Retirement Benefits Authority looked
forward to a scenario in which beneficiaries were provided for in old age and funds
were raised for investment in the Kenyan economy. Unfortunately, although con-
tributions may be received electronically, a physical application form must be
collected from Mbao chapter offices, and pension payments currently have to
be made by check. The scheme is gaining in popularity, and by the end of 2012
membership stood at 40,000 (RBA 2013).
“Mbao” refers to the K Sh 20 note (US$0.23), which is the daily minimum
contribution required by this individual pension plan. The Kenya National Jua
Kali Cooperative Society developed this defined contribution scheme for the
informal sector. The project started with a nine-month pilot project in which
11,000 informal sector workers made contributions through the bill payment
function on M-Pesa or Airtel Money. Any Kenyan over the age of 18 years is
eligible to join this individual pension plan. To join, a membership fee of K Sh
100 is paid, and a commitment is made to contribute at least K Sh 100 per week.
The fund is run professionally with a conservative investment strategy focused
on investment in money market and fixed income securities. The KCB acts as
custodian, the Co-op Trust part of the Cooperative Bank invests the funds, and
administration is by Eagle Africa Insurance Brokers.
Linda Jamii: Health Insurance. “Linda Jamii,” Swahili for “protect the family,” is a
private medical care insurance that uses M-Pesa to collect premiums and to
make benefit payouts. In November 2012 Changamka Microhealth and Britam
Insurance Company launched the mechanism, which allows people to save small
amounts of money over time toward purchasing health insurance. They started a
pilot with Safaricom in May 2013 and have 2,000 households enrolled to date.
Customers can save in a premium deposit facility on M-Pesa and purchase health
insurance once they accumulate K Sh 6,000. They then have an additional six
months to pay the outstanding K Sh 6,000.
Changamka’s strategies to address barriers to coverage include exclusive sav-
ings toward health care expenses, flexible timing of payments, affordable access
to plans, and use of available mobile technology. In addition, the microinsurance
program benefits health care providers, because the electronic operating plat-
form reduces the administrative burden on hospitals and clinics. The product
targets the estimated 35 million uninsured in Kenya. Changamka plans to scale
up this initiative nationally (Gathara 2013).
To subscribe to the service, users dial *525# and follow the directions. After
subscription there is a requirement to complete the registration process by visit-
ing the nearest Linda Jamii agent outlet at Britam offices, Safaricom shops,

selected M-Pesa agents, Uchumi outlets, or Postbank branches countrywide. Once

a person is registered, a unique Linda Jamii number is used to make payments
through Safaricom’s PayBill function.
M-POS
The growth of alternative delivery channels to provide financial services has been
called “branchless banking,” because it relies on the use of channels other than
traditional bank branches. Using these alternative channels holds the prospect of
extending access to financial services because of the potential for a dramatic
reduction in the cost of provision.
In addition to mobile money, another exciting emerging technology is being
used in Kenya: M-POS, a card reader attached to a smartphone creating a low-
cost POS center for use by smaller merchants. Because of its lower cost, it has
the potential to massively increase card acceptance infrastructure and hence card
use. (See figure 5.15 for a comparison of costs for various channels.)
Challenges to M-Pesa
Although M-Pesa is truly inspiring innovators in Kenya and globally to develop
apps to provide services using the M-Pesa payment platform as the digital con-
nector, the biggest complaint from app developers is the reluctance of Safaricom
to share the M-Pesa API with them. API is the technology that allows two soft-
ware programs to communicate with each other and allows any potential service
developer to get linked directly to the mobile money account in M-Pesa instead
of a bank account or credit card for payment.
With more than 12 million active accounts, it is no surprise why all devel-
opers want to have access to M-Pesa. Everyone in the application developer
Figure 5.15 Average Capital Expenditure Costs for Financial Service Providers in
Kenya, by Channel
Branch 100,000
ATM 20,000
POS 2,000
M-POS 80
Mobile phone
30
(Internet-enabled)
Mobile phone (basic) 10
0 20,000 40,000 60,000 80,000 100,000 120,000

Average capital expenditure cost, U.S. dollars
Sources: Branch, ATM, and POS costs from FSD Kenya 2013; M-POS and mobile-phone costs from expert
interviews in November 2013.
Note: ATM = automated teller machine; M-POS = mobile point of sale; POS = point of sale.

community has been waiting for ages for Safaricom to release an M-Pesa API
that would enable them to build innovative, value-added services on the
M-Pesa platform or to link up already developed apps. In 2015, Safaricom took
initial steps to open its API to the public to help developers build platforms
that can use M-Pesa for quick payments. However, this promise has been there
for some time, and the delay had led to independent development of open-
source M-Pesa APIs. However, “the systems are not yet in place to facilitate
seamless integration into Safaricom’s platforms,” and opening up would entail
technical, financial, risk management, and market implications for M-Pesa to
consider (Morawczynski 2015). Nevertheless, opening up the M-Pesa API
could be beneficial for the communities that otherwise do not get served.
Digitizing Social Grant Disbursement Programs: Brazil, Mexico, and

South Africa
In a number of countries, two separate, but potentially complementary policy
agendas have emerged in the past five years: governments have sought to
increase the use of electronic means for government payments and to promote
greater financial inclusion. While the two agendas have by no means converged
yet, in practice they have often been translated into a single headline objective:
to increase the proportion of recipients of government social cash transfers who
receive payment directly into a bank account.
—Chris Bold, David Porteous, and Sarah Rotman, “Social Cash
Transfers and Financial Inclusion: Evidence from Four Countries”
According to the 2014 United Nations E-government Survey, public administra-

tion can become more efficient and widely used through the use of recent digital
developments, such as mobile apps and innovative financial instruments
(UN 2014). The survey report identifies three types of e-government interactions:
government-to-government (G2G), government-to-business (G2B), and govern-

ment-to-consumers (G2C).15 This volume focuses on reaching the underserved
through G2C (or, alternatively, G2P) methods.
National governments and the international community are increasingly
recognizing the value of social transfers (including pensions, grants for families,
public works schemes, and other programs) in achieving the Millennium
Development Goals. In addition to their vital social contribution, social trans-
fers can support critical economic objectives. Many of the world’s fastest-
growing economies over the past several decades have built social protection
programs into their policies at early stages because of their potential to increase
productivity and help stabilize domestic demand (Samson, Mac Quene, and van
Niekerk 2006).
Social grant payments are disbursed as cash payments in most developing
countries. Barriers to transitioning such payments to digital systems include
inadequacy of payment infrastructure outside of urban areas, absence of proper
identification documents, lack of awareness and trust in payment options and

Figure 5.16 Share of Adults Receiving Government Transfers, by Region and Payment
Method, 2014
Share of adults receiving transfers, percent 30
25
21
20
15 15
15 13
10 8
7
5 3
0
East Asia Europe High-income Latin Middle South Sub-Saharan
and Pacific and OECD America East Asia Africa
Central economies and the
Asia Caribbean
Using other method In cash only Into an account
Source: Global Findex Survey 2014, http://datatopics.worldbank.org/financialinclusion/.

Note: OECD = Organisation for Economic Co-operation and Development. Figure displays percentages of adults who
reported receiving transfers over the previous year.
institutions, cost of transition, regulatory barriers, and lack of preparedness by

governments for digitization. According to Findex 2014, whereas in high-income
Organisation for Economic Co-operation and Development (OECD) economies
a majority of those receiving transfer payments (83 percent) receive them into
an account, in developing countries only about half of them reported receiving
such payments into an account (figure 5.16).
In many developing economies, government grant disbursement programs are
used to ensure opening up of bank accounts, thus enhancing financial inclusion.
Findex 2014 reported that around 61 percent of grant recipient adults also use
these accounts for cash management purposes. Four countries in particular—
Brazil, Colombia, Mexico, and South Africa—use digital means in various forms
to disburse grant payments on a scale that is significant in terms of financial
inclusion. While all four use digitized payments, they adopted different methods
(table 5.8).
The grant payment schemes from Brazil and Mexico are discussed briefly,
highlighting the magnitude of these programs and the opportunities in terms of
sheer numbers of people who can be brought into the mainstream financial
system. However, because of the proximity issues of formal financial institutions,
both programs still remain largely transaction- or cash-based. The South Africa
case, on the other hand, highlights superior technology with important features
that have supported financial inclusion in a more meaningful manner.

Table 5.8 Payment Approaches of Selected Grant Programs as of 2012

Program aspect Brazil Colombia Mexico South Africa
Frequency of Monthly Bimonthly Bimonthly Monthly
payment
Payment provider Caixa Economica Banco Agrario Bansefi (state- Any bank or specific
Federal (state-owned (state-owned owned bank)a payment providers in
bank) bank) different provinces: Net 1,
Empilweni, and AllPay
(subsidiary of ABSA Bank)
Physical cash 1% 9% 66% 0%
Limited-purpose 84% 91% 0% 41%
instrument Magnetic-stripe debit Magnetic-stripe Specific payment
card (Social Card) debit card that providers that offer
whereby funds must be can be used only store-of-value via
withdrawn within 60 at Assenda smart cards, but no
days at Caixa agents or merchants and additional fund deposits
various ATM networks ATMs and use only at dedicated
and no additional funds pay points
can be deposited
Mainstream financial 15% 0% 34% 59%
account Caixa Facil basic • 16%—Bansefi Mainstream bank
bank account with savings account with accounts; Sekulula
magnetic-stripe card magnetic-stripe card account (offered by AllPay)
(Debicuenta) with magnetic-stripe card
• 12%—Bansefi as default option in certain
prepaid account provinces
with smart card
• 6%—Bansefi
passbook accountb
Source: Bold, Porteous, and Rotman 2012.
Note: ATM = automated teller machine.
a. In 2011, state communications agency Telecomm was still involved as a direct payment provider. But Oportunidades is in the process of
consolidating its payments previously made through several agencies, including Telecomm, so that all payments would be made in 2012 through
Bansefi, which then subcontracts with other networks, including Telecomm, to effect payout.
b. These cash payments into accounts are being phased out.
Brazil: Bolsa Família

From 2001 to 2003 Brazil created four cash transfer programs that were merged
into the Bolsa Família program (BFP) in late 2003 and subsequently expanded.
The new program seeks to invest in human capital by associating cash transfers
with educational goals and uptake of health services (Paes-Sousa, Santos, and
Miazaki 2011). BFP is the world’s largest conditional cash transfer program,
reaching all 5,564 municipalities in the 27 states of Brazil. Over 12.9 million
households are enrolled, benefiting over 60 million people (about 30 percent of
the total population).
Bolsa Família owes much of its targeting success to Cadastro Único (CadÚnico),
a single registry that has consolidated data on Brazil’s most vulnerable and
has enabled Brazil to expand and improve its social welfare system.16 CadÚnico is
managed by Caixa Economica Federal (Caixa), a state bank.17 Eligibilities are rede-
termined every two years. Local governments collect the data and the information,

while the federal government, through the Ministry of Social Development, over-
sees the registry, defines eligibility requirements, and cross-checks data within the
registry. Caixa plays a distinct role in implementing BFP by managing the database,
assigning identification numbers, and finally distributing grants.
In terms of payment method, around 1 percent of the recipients receive cash,
while 15 percent receive the grants through basic bank accounts held with Caixa.
These are no-frills accounts, easier and faster to open by regulation, and offering
four withdrawals free each month. Monthly balances are limited to R$2,000
(US$575). A majority of the recipients, around 84 percent, get their grants using
a limited-purpose card—the Social Card. This card is linked to a nontransactional
account that requires withdrawal of the grant within 90 days in one transaction
from the day of the deposit and does not allow other deposits. There is a nominal
fee for the withdrawal. If money is not withdrawn, the grant recipient will lose
that particular payment—the reason why the Findex 2014 Survey found that
close to 88 percent of grant recipients withdraw all the money right away.
Caixa has a very effective network of payment agents of over 36,000
points of service in all municipalities of the country, including 2,780 branches,
24,756 retail agents, and 10,954 lottery outlets (CGAP 2011). A majority of the
recipients (around 61 percent) withdraw money at lottery centers. Caixa is con-
ducting pilot studies on collecting biometrics, use of mobile phones and enhanc-
ing the touchpoints. Efficient administration and good targeting have enabled
BFP to achieve its success at a very low cost.
Ten years after its inception, BFP has been key to helping Brazil cut its
extreme poverty by more than half—from 9.7 percent of the population in 2003
to 4.3 percent in 2013. Most impressive, and in contrast to other countries,
income inequality also fell markedly, by 15 percent, to a Gini coefficient of 0.527
(Wetzel 2013). Given the structure of the payment process, the Social Card
remains a transactions card and not a savings mechanism for most grant
recipients. However, efficient targeting by the CadÚnico registry, wide distribu-
tion of agent touchpoints, and effective management of the whole process have
made BFP a powerful tool in fighting poverty.
Mexico: Oportunidades (Prospera)

The conditional cash transfer scheme in Mexico was originally founded in 1989
and was rebranded twice before being renamed as Prospera in 2014.18 This was the
first major social grant program in Latin America where grants were conditioned
on activities such as school enrollments and getting regular health checkups.
To date, this model has been replicated in as many as 52 countries. The program
serviced around 5.8 million families, which is around 20 percent of the population
in 2011, and in 2014 this increased to 6.1 million families.
The feeling in Mexico had been that Oportunidades was failing to make a
meaningful long-term impact on the country’s social panorama, with atrocious
levels of poverty and inequality refusing to budge over the years. This led the
government to relaunch a widened program under the new name of Prospera,
in the hope that it would finally reverse a trend of stagnant and widespread

poverty across Latin America’s second biggest country in terms of the size of its
population and economy (Constantine 2014).
Prospera is also promoting beneficiaries’ access to higher education and formal
employment. Additionally, Prospera is facilitating access to financial services
(savings, microcredit, and insurance), thereby enhancing social inclusion of
the country’s poorest citizens (World Bank 2014). The Social Development
Secretariat (SEDESOL) is working to develop an integrated social information
system to identify the poor, and it hopes to have a system similar to the Cadastro
Único in Brazil.
The payments under Oportunidades were made bimonthly through the state-
owned development bank, Bansefi. However, 66 percent of payments were made
in cash. The rest were distributed through Bansefi accounts: 16 percent through
savings accounts with magnetic-stripe cards; 12 percent through Bansefi prepaid
accounts operated through smart cards; and the remaining 6 percent through
Bansefi passbook accounts. In 2012, the amount transferred to 6.5 million benefi-
ciaries was Mex$63.78 billion (US$3.9 billion). Given that most beneficiaries
live in rural, hard-to-reach areas, SEDESOL has been continually trying out
various new payment partners and options—Telecomm (the state telegraph
company), gas stations, cooperatives, and Diconsa stores,19 to name a few.
In 2010 the government mandated SEDESOL to centralize the electronic
payments of the grant program. As a result, all payments were outsourced to
Bansefi, with Telecomm and Diconsa as subcontractors. Where banking infra-
structure is available, the beneficiaries are issued a no-fee open debit card to be
used at any ATM or POS terminal,20 and the rest are issued a biometric closed
debit card that can cash out only at Bansefi, Telecomm, or Diconsa touchpoints.
Even though Diconsa stores have the physical outreach, the National Banking
and Securities Commission approved fewer than 290 stores as banking agents.
Hence this method, too, failed to gain traction. By 2012, only 20 percent went
through open cards, with the rest paid in cash at either fixed points (20 percent)
or at temporary points (61 percent) (Babatz 2013).
The lesson is that mandatory regulatory action alone will not bring about the
desired results, unless backed by a well-designed strategic plan. Furthermore,
proximity to payment touchpoints is especially important in programs that serve
the rural poor. Transaction cost is not the only thing poor people worry about; hid-
den opportunity costs of travel, loss of daily wages, or even the safety of carrying
cash are all factored into the decision of choosing payment alternatives. The posi-
tive impacts of this conditional cash transfer program can be fully realized by
addressing these issues, possibly through innovative use of digital solutions.
South Africa: Card-Based Biometric Grant Payment Disbursement System

Millions of South Africans lack access to the most basic financial tools. They don’t
have secure places to save money or reliable means to transfer it and use it for
transacting. Through the introduction of the SASSA Debit MasterCard card,
nearly one fifth of the South African population now benefits from having a formal

banking product, helping them build a stronger future for themselves, their families
and their communities.
—Ann Cairns, president of international markets, MasterCard,
during award presentation to the South African Social Security
Agency (SASSA), August 20, 2013
South Africa has seven major social security grant programs: Old Age, War Veteran’s,
Disability, Grant in Aid, Child Support, Foster Child, and Care Dependency.
Eligibility for each grant is dependent on an income-based means test. Administered
by the South African Social Security Agency (SASSA), the grants are financed
through general tax revenues collected on a national basis. As of June 2015, there
were 16.78 million grant recipients (about 31 percent of the total population).
Over the five years from 2009–13, social grants were around 3.4 percent of the
GDP, and this trend is expected to continue (National Treasury, South Africa 2013).
Social Grants and Financial Inclusion

South Africa is fairly financially inclusive, according to the Findex 2014 Survey:
around 70 percent of the adults over 15 years of age have accounts in formal
financial institutions.21 However, the share of adults who save and borrow
(33 percent and 12 percent, respectively) leaves room for improvement.
The impact of social grants on financial inclusion is highlighted in the
FinScope 2014 Survey (figure 5.17), which shows that 80 percent of the adult
population is formally served (through either banks or formal nonbank institu-
tions) while 75 percent is banked. Another 6 percent is served by informal means,
while 14 percent of the population is financially excluded. Financial inclusion
grew from 17.7 million adults in 2004 to 31.4 million in 2014, and the adults
who rely only on informal mechanisms have been reduced from 3.4 million in
2004 to 2.1 million in 2014. In terms of gender, women are more likely to have
bank accounts (79 percent) than men (70 percent) and less likely to be finan-
cially excluded (11 percent and 18 percent, respectively).
According to the FinScope Survey, the increase in financial inclusion is largely
driven by the SASSA grants that are disbursed through a bank account–linked
debit card. Accordingly, 34 percent of the banked population now owns a
SASSA MasterCard. This is a remarkable achievement. Deeper examination
reveals that it is not just the different types of social grants that made such inclu-
sion possible; the technology behind delivering grant payments to 16 million
people has helped to bring them into the formal financial system.
SASSA Card: Biometric Chip Technology–Enabled Debit MasterCard

Until 2004, the grants had been allocated to provinces as block grants and disbursed
mainly through private companies contracted for this purpose. In 2004, the
National Treasury revised this practice and started disbursements through the
Department of Social Development, and the payment options offered were cash at
specific pay points or direct bank credits. Given the low banking access possibilities
for the poor and the high cost of banking, in reality most grants were paid in cash.

Figure 5.17 Financial Access Strand in South Africa, 2004–14
2014 75 5 6 14
2013 75 4 5 16
2012 67 6 8 19
2011 63 5 5 27
2010 63 5 9 23
2009 60 4 10 26
2008 63 3 11 24
2007 60 4 11 25
2006 51 7 9 33
2005 47 8 8 37
2004 46 4 12 39
0 10 20 30 40 50 60 70 80 90 100
Share of respondents, percent
Banked Other formal (nonbank) Informally served only Not served

Note: In constructing these strands, the overlaps in financial product or services usage are removed.
The figure reflects FinAccess 2014 Survey respondents who were ages 18 and older. The “Access Strand”
is a graphical method (routinely used in FinScope Surveys) of placing each survey respondent along a
continuum of access, depending on use of services by category. “Formal” refers to the share of the
population using a bank, banklike institution, Postbank, or an insurance product. “Other formal (nonbank)”
refers to the share using semiformal services from nonbank financial institutions (such as microfinance
institutions), not bank services. “Informally served” refers to those using only informal financial service
providers such as savings and credit associations and groups or individuals other than family and friends.
“Not served” refers to those using no institutionalized financial services.
In 2011, realizing the challenges by a variety of resource and logistical limita-

tions that made grant delivery vulnerable to widespread waste, fraud, and
abuse, SASSA contracted Cash Paymaster Services (CPS, a subsidiary of Net 1/
Aplitec), in partnership with Grindrod Bank, to handle the grant disbursements.
Grindrod Bank turned to MasterCard as its payment partner of choice. As the
designated issuer, Grindrod Bank was able to hold deposits and, as a member of
the Payments Association of South Africa, is able to clear through the National
Payment System.

Net 1 and MasterCard collaborated on developing a unique MasterCard,

integrating Net 1’s Universal Electronic Payment System (UEPS) biometric
technology with MasterCard Europay, MasterCard, and Visa (EMV) chip
technology22 to create a solution that successfully operated both online and
offline,23 unlike traditional payment systems offered by major banking institu-
tions that require immediate access through a communications network to a
centralized computer. This offline capability allows the user to conduct transac-
tions at any time with other cardholders in even the most remote areas, so long
as a smart card reader, which is often portable and battery powered, is available.
The card authenticates cardholder identity and authorizes spending using a single
chip that can be instantly issued. The hybrid chip solution incorporates biometric
identification and loading of funds with traditional spending and fund access
functionality through e-wallets. Table 5.9 highlights the salient features of this
unique and innovative card.
With the launch of the new card, SASSA also took the unprecedented
difficult task of reregistering all the beneficiaries of the seven types of social
grants. The new technology enabled the registration and instant issuance of a card
in just under 10 minutes, thus saving registration and wait times for the grant
beneficiaries. In peak times, around 150,000 cards per day were registered and
issued. Since the card launch in March 2012, just under 22 million social grant
Table 5.9 Characteristics of the SASSA Card

Category or feature Description
International card scheme MasterCard
Issuing bank Grindrod Bank Ltd.
Government agency (cobranding partner) SASSA
Provider of funding National Treasury of South Africa
System operator or service provider CPS/Net 1/Aplitec
Account holders or cardholders Approved and registered government grant recipients
Card technology Contains an EMV-compliant chip, which allows fingerprint
biometric verification, PIN verification, and debit
card purchases. Also contains an offline UEPS Net 1
electronic purse (wallet)
Proof of life authentication Fingerprint biometric (Net 1 proprietary); voice
recognition
Payment transaction cardholder Fingerprint biometric; PIN
verification method
Registration access points SASSA regional offices
Proof of life access points SASSA regional offices, selected retailers
Transactional access points CPS cash payout points (biometric cards); selected
retailers (biometrics); retailers (PIN); any ATM (PIN)
Frequency of payments Monthly
Source: Volker 2013.
Note: ATM = automated teller machine; CPS = Cash Paymaster Services; EMV = Europay, MasterCard, and Visa; PIN = personal
identification number; SASSA = South African Social Security Agency; UEPS = Universal Electronic Payment System.

beneficiaries have reregistered in the new system. With 10–12 million SASSA
cards issued, fraudulent grant applications have been minimized and administra-
tion costs reduced by distributing all grant payments electronically.24
As part of the SASSA reregistration process, each recipient has a bank account
opened for them, which is offered free of monthly charges by Grindrod Bank.
Recipients can deposit funds into their bank account via electronic funds transfer
(EFT) or third-party bank transfer. The SASSA Debit MasterCard can be used
anywhere MasterCard is accepted, and grant recipients can use it like a normal
debit card to make purchases, check their account balances, and withdraw cash
without incurring transaction charges at selected South African retailers. Recipients
can also withdraw cash at any ATM, although normal banking charges apply.
According to Net 1, unlike a traditional credit or debit card where the opera-
tion of the account occurs on a centralized computer, each of the SASSA
smart cards effectively operates as an individual bank account for all types of
transactions. Although the SASSA card is a single-wallet system, it is possible
to enable multiple e-wallets on a single card, where each wallet can be tied
to specific payment partners. For example, education grants could only be acti-
vated when used to pay school fees. This could potentially enhance cash
management capabilities of the beneficiaries and ensure grants are used for the
intended purpose.
Future of Grant Payments in South Africa

There is no question that using a unique biometric-enabled UEPS EMV SASSA
card transformed the distribution of social security benefits in South Africa.
The gains made by reregistration and incorporation of biometrics in the process
are substantial. While creating a comprehensive national social grants database,
it also helped to reduce waste, abuse, and fraud. Consolidating seven social pro-
grams and combining all payments under one card also brought in efficiency
gains. According to the CEO of SASSA, the elimination of ghost accounts, dupli-
cations, and other irregularities resulted in over 650,000 accounts being removed
from the grants register, thus creating annual savings of R 2 billion (US$157
million) (SASSA 2013). An additional R 800 million (US$63 million) in service
fees were saved in the 2012/13 financial year alone (Brand South Africa 2014).
For the grant beneficiaries, absence of long lines at payment locations with
scheduled payment times, reduction of personal security risks of carrying money,
prevention of abuse and fraud, increased efficiency and safety, and availability
of free transactions and withdrawals are some of the important benefits that
enhanced their value proposition.
Nevertheless, it must be mentioned that the SASSA operation is laden with
controversies, court cases, and allegations against most stakeholders, including
SASSA itself. However, this case study focuses only on the important technical
solution offered. Digitizing manual payments is a difficult process, and digitizing
seven grant programs and creating one innovative, easy-to-use, bank account–
linked debit card is an impressive feat that significantly enhanced the value propo-
sition for the poorest and most vulnerable in terms of their financial inclusion.

Notes
1. The questionnaire was designed to capture innovations resulting in new products as
well as innovations in processing. A total of 101 central banks completed the survey
and reported 173 innovative retail payment products or product groups. Many central
banks provided information on a product group basis and not individual products (see
World Bank 2012a).
2. If providers have proprietary technical and usage standards, interoperability would
entail higher cost of compliance.
3. For all Global Findex Survey 2014 data, see http://datatopics.worldbank.org
/financialinclusion/. For the Findex findings on Sri Lanka, see appendix A, table A.6.
4. KPMG is a leading audit and adviser services provider.
5. Sri Lanka also has the world’s lowest rates for fixed broadband Internet, around US$5
per month, resulting from a high level of competition among the suppliers and an
explicit aim from the government to keep the cost to a minimum (ITU 2012).
6. The global mobile industry converges on Barcelona annually for the Mobile World
Congress, with the 2015 edition attracting a record 93,000 delegates and over 2,000
exhibitors. For more information, see DailyFT (2015).
7. Standard setting can also suppress the incentives to innovate and, hence, sometimes
can restrict competition by curbing such innovative business models.
8. 1LINK is the leading shared ATM network of Pakistan.
9. Global Findex Survey 2014, http://datatopics.worldbank.org/financialinclusion/.
10. The team was supported by the International Finance Corporation (IFC) of the World
Bank Group, the Bill and Melinda Gates Foundation, the Financial Sector Deepening
(FSD) Trust, and Groupe Speciale Mobile Association (GSMA) (GSMA 2014).

12. According to the Findex data, the entire 36 percent have access through formal bank
accounts and only 0.4 percent through mobile accounts. (Note: there may be sampling
issues underlying these numbers.) For more of the Findex 2014 data on Indonesia,
see appendix A, table A.2.
13. Indonesia’s six current mobile money service providers and scheme names include
Telkomsel: T-Cash (begun in 2007); Indosat (Ooredoo): Dompetku (2008); XL
(Axiata): XL Tunai (2012); mCoin: mCoin (2012); BTPN (Bank): Wow! (2013); and
Bank Mandiri: e-Cash (2013).
14. M-Pesa revenue and expenditure data from Safaricom and authors’ field interviews.
15. G2C is also called government-to-persons (G2P).
16. The registry contains data on over 23 million low-income families and 78 million
people. Estimates based on the 2010 census data show that there are 20 million low-
income families in Brazil (67 million people), or 35 percent of the total Brazilian
population. Therefore, there is 114.5 percent coverage. Its biggest program is the BFP.
This is a huge undertaking, given that Brazil is the fifth largest country in the world
(8.5 million square kilometers) (Mostafa 2014).
17. Established in 1861, Caixa is a government savings bank.
18. It started as Pronasol in 1989, and was renamed Progresa in 1997 and Oportunidades
in 2002.

19. Diconsa stores are small stores owned and operated by local communities; there are
over 20,000 of such stores, mostly in rural Mexico.
20. Fees are paid by Bansefi.

/financialinclusion/. For the Findex findings on South Africa, see appendix A, table A.5.
22. EMV stands for Europay, MasterCard, and Visa—the three companies that originally
created the standard. EMV is a technical standard for smart payment cards and for
payment terminals and ATMs that can accept them. EMV cards are smart cards
(also called chip cards or IC cards) that store their data on integrated circuits rather
than magnetic stripes, although many EMV cards also have stripes for backward
compatibility. They can be contact cards, which must be physically inserted (or
“dipped”) into a reader, or contactless cards, which can be read over a short distance
using radio-frequency identification technology. Payment cards that comply with
the EMV standard are often called chip-and-PIN or chip-and-signature cards, depend-
ing on the exact authentication methods required to use them.
23. Real-time but offline.
24. Because many of the beneficiaries are underage or too old to collect funds, collection
can be delegated to dependents or nominees, who in turn may be grant beneficiaries.
Multiple grant beneficiaries can be loaded onto a single SASSA Debit MasterCard.
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CHAPTER 6
Unique Identification
Introduction
Unique national identification (ID) is a critical component of a digital money
system. The ability of the service provider to accurately identify its current and
potential customers is central to providing digital-money services, such as mobile
money or prepaid-card-based government grant programs. One important reason
why M-Pesa was able to roll out the mobile money initiative so quickly—while
also addressing the know-your-customer (KYC) concerns—is because Kenya has
an established national ID system.
In Sri Lanka too, mobile network operators (MNOs) leveraged the existing
national ID system put in place by the national government and the mandatory
registration of subscriber identification module (SIM) cards when launching
mobile money solutions. The Central Bank of Sri Lanka relaxed its KYC
requirements, adopting a more proportionate approach to customer due dili-
gence (CDD) based on the e-wallet size. Similarly, Thailand’s biometric smart
ID enabled wider reach in banking access, while in South Africa, biometrics
were introduced to the social security system, to register or identify grant
recipients.
The success of mobile money and scaling-up depends on speeding up account
opening and minimizing steps in transacting. Overly strict requirements regard-
ing the identification and verification of customers tend to restrain the impact of
efforts to increase financial inclusion. For example, strict application of CDD
requirements may exclude people lacking official documentation from entering
the regulated financial system. Strict CDD procedures may also lead financial
institutions to pass on costs to the customer, resulting in a disincentive (especially
for the poor) and thus may push them toward informal service providers.
Although such measures may be appropriate risk mitigation measures for regu-
lated financial institutions, they may result in marginalization and exclusion of
poor people from financial intermediary functions and payments mechanisms
that enhance poor peoples’ coping capability.
In terms of Financial Action Task Force (FATF) guidelines as endorsed by the
Bank for International Settlements (BIS), from an Anti-Money Laundering and

156 Unique Identification
Combatting Funding of Terrorism (AML/CFT) perspective, small-value and

low-risk mobile money transactions qualify for simplified CDD. Therefore,
countries may consider applying “tiered” approaches whereby KYC and CDD
requirements vary according to transaction or payment limits or wallet sizes.
Higher limits entail a more extensive CDD process, including proactive
account monitoring for suspicious activities. Since most potential mobile
money users or grant recipients are either unbanked or underbanked, it is
important to maintain minimum KYC requirements and allow simplified
CDD processes to sign up for mobile money and digitally maintained grant
programs, and to transfer or transact smaller values. At the entry level, a national
ID document can be used to validate identity for KYC purposes. Sri Lankan
mobile money operators use this tiered KYC/CDD approach and offer several
types of accounts with different KYC requirements to ease registration require-
ments for low-income users.
In developing countries, civil registration systems are largely absent or cover
only a fraction of the population. In developed countries, most people establish
their official identity through an official birth certificate. However, a United
Nations Children’s Fund (UNICEF 2013) report shows that births of nearly
230 million children under five have never been registered—approximately
one in three of all children under five around the world. UNICEF estimates
that 35 percent of children worldwide, and 40 percent of children in develop-
ing countries, were not registered at birth. South Asia had the highest percent-
age of unregistered births (61 percent) in 2013, followed by Sub-Saharan
Africa (56 percent) (Gelb and Clark 2013).
UNICEF maintains that having a birth registration is the first step toward
realization of other rights throughout a person’s lifetime. Furthermore, the UN
High Commissioner for Refugees (UNHCR) estimates that at least 10 million
people across all regions are stateless (UNHCR 2017). Without official ID, these
people formally do not exist. Gelb and Clark (2013) explain that this “identity
gap” is increasingly recognized not only as a symptom of underdevelopment but
also as a factor that makes development more difficult and less inclusive.
They suggest that biometric ID systems could have a transformative impact on
development, similar to microcredit and mobile phones in the far-reaching abil-
ity to improve poor people’s lives.
Biometrics take a variety of forms—iris scans, fingerprints, even face scans—and
are being used to establish identities for many different purposes: elections,
health care, payroll, government services, and more. Gelb and Clark (2013)
conducted the first global survey of 160 cases where biometric ID has been
used for economic, political, and social purposes in developing countries
(map 6.1). The survey results show that some 1 billion people in developing
countries across the world have taken part in biometric ID programs.
Sub-Saharan Africa is the most active region (75 surveyed cases, covering an
estimated 288 million people), while South Asia is third (27 surveyed cases,
covering an estimated 426 million).1 Overall, at least half of these projects are
donor-funded with official development assistance.

Unique Identification 157
Map 6.1 Global Participation in Biometric ID Programs, by Region, 2012
IBRD 43079 | AUGUST 2017
Asia
41 surveyed cases,
Latin America and covering 648 million
the Caribbean people (est.)
34 surveyed cases,
covering 280 million Africa
people (est.) 75 surveyed
cases, covering
288 million
people (est.)
Prevalence of developmental biometrics

National: at least one countrywide application (such as national ID, elections)
Subnational: at least one state- or ministry-level application (such as civil service payroll, pensions)
Project: at least one project-level application (such as health and demographic survey)
Source: Gelb and Clark 2013. © Center for Global Development (CGD). Reproduced, with permission, from CGD; further permission
required for reuse.
The cases are categorized as either (a) ID-supply-driven, or foundational,

cases (such as establishing civil registries and national IDs); or (b) application-
demand-driven, or functional cases (such as demand for particular services or
transactions such as voter IDs, bank cards, and health records). Under the func-
tional class, the general financial services category is an additional transactional
type needing ID. In terms of projects or businesses that are implementing
ID-facilitated financial services, Sub-Saharan Africa is in the lead with eight proj-
ects, followed by South Asia with three projects. Biometric authentication
appears not to be widely used in mobile banking, although certain smartphones
already have fingerprint scanners.2 While currently biometrics have not been
popular in the developing-country mobile applications, they are available as a
tool to expand use over time.
Biometrics are used more extensively in a wide variety of social transfers.
The survey identifies 23 cases worldwide where biometrics have been used in
creating beneficiary registries and authenticating cash or in-kind transfers at the
point of service.
Biometric ID technology is one option for identity management and identifi-
cation that can help to leapfrog traditional paper-based identity systems in terms
of proliferation, efficiency, and accuracy. It can extend current security and anti-
fraud efforts by preventing ready impersonation of the authorized user. At the
same time, practical difficulties in implementing biometric ID cannot be
ruled out, including the huge up-front cost of registering the users, privacy issues,

and social and cultural issues involved in getting people to consent to biometric
ID methods. A further question is how well the data security and safeguard
measures, and other operational aspects in using biometrics, would work in
developing-country settings.
In the mobile money world, mandatory registration of prepaid SIM cards is
viewed by governments and regulators as a counterterrorism measure enabling
efficient KYC assessment, especially in developing countries. In the developed
world where self-regulation is highly valued, privacy rights have discouraged
such practices. As highlighted in the Groupe Speciale Mobile Association white
paper (GSMA 2013), mandating SIM registration can have unintended negative
consequences, such as loss of access to communications services when mobile
users’ SIM cards are deactivated; restricted access due to possible geographic
limitations on where SIM cards can be registered or purchased; and emergence
of black markets for fraudulently registered or stolen SIM cards. However, estab-
lishing such a registry opens up more options for the users. Hence, it is up to the
policy makers to harmonize the regulations with market needs after consulting
with industry to analyze costs, benefits, and implementation options.
A national ID system provides not only verification of a person’s identity, but
also addresses acceptable and approved basic KYC protocols for accessing
finance and payment systems. The case studies analyzed in this chapter highlight
why having a unique ID (UID) is a foundational and critically important enabler
toward scaling up e-money initiatives while managing risks. The case studies
focus on
• How lack of a UID can be a limitation in terms of scaling up digital finance for
disaster relief programs and financial inclusion schemes;
• How transformative responses to the ID barrier enable millions of people to
access financial services in a hassle-free manner; and
• How digital identity enhances customer experience in moving toward a cash-
lite society.
Not directly addressed in this volume are the political economy dimensions
where vested interests actively hinder development, application, spread, and use
of a unique identifier. By definition, a UID in any environment allows traceability
by the tax authorities; enables AML/CFT compliance; and eliminates opportuni-
ties for leakages (fraudulent receipt of subsidies and social transfers), black
market transactions, tax avoidance, and theft. Linkage of UID across financial
sector databases and with phone and utility authorities promotes transparency
and traceability, which are also challenges.
The Philippines: 21 IDs and Counting

If unbanked individuals lack appropriate forms of identification, which is not
uncommon, they may struggle to participate in mobile money opportunities.
This is prompting many governments to rethink the identity process and use

creative solutions that employ biometrics, for example, or that use group gather-
ings, where the identified identify the unidentified.
—USAID-Citi Mobile Money Accelerator Alliance,
“10 Ways to Accelerate Mobile Money”
There is no unique national ID system in the Philippines. Various government

departments collect personal information about every Filipino who has been
issued a passport, a driver’s license, or a residence certificate. The government
and businesses also obtain personal information for income tax payments, voter
registration, marriage, public health insurance coverage, security clearance for job
applications, and most business transactions.
The government initiated actions to establish a national ID system two
decades ago, but various interest groups have thwarted implementation. During
her term President Gloria Macapagal Arroyo issued an executive order for
government agencies and government-controlled corporations to harmonize

their systems, and the unified multipurpose ID card (UMID) was established.
However, this excluded nongovernment workers and average citizens, including
those who are unemployed or working abroad. Proposals to issue every citizen a
national ID card were vehemently opposed, principally on the perceived threat
to security and violation of privacy by the government’s collection of personal
information. At the same time, proponents argued that this could help fight
criminal activities and cut down on corruption.
The Central Bank of the Philippines (Bangko Sentral ng Pilipinas, or BSP) has
issued a circular identifying 21 different types of valid ID that can be used for
financial transactions,3 and several other ID types are also accepted in the
Philippines (table 6.1). The length of the list demonstrates how difficult the ID
process would be for the customer and service provider, as well as for the
regulator, to provide and verify one or more of these forms of ID, whose authen-
ticity is often difficult to establish.
Anecdotal evidence suggests that providing a valid ID is still difficult for most
of the poor, who tend to prefer informal financial service providers that use
group or personal identification methods rather than subjecting themselves to
KYC checks by regulated formal financial institutions. In rural areas, 558 rural
and cooperative banks with a network of 2,101 branches provide basic interme-
diary functions. Poor people in the Philippines often use sari-sari shops4 or pawn-
shops for their financing needs. Many (25 percent) still use drivers and relatives
for money transfer purposes.
Sari-sari stores are ubiquitous in the Philippines, numbering over a mil-
lion, nearly all of them owned by women. A demand study on domestic
payment systems done by Bankable Frontier Associates (BFA 2010) revealed
that pawnshops (such as LBC, ML, Cebuana Lh., and others) are well
known, and more people use them for their payment needs than other ser-
vice providers (figure 6.1). In 2014, there were 5,971 pawnshops with a
branch network of 11,542 shops in the country (BSP 2014). Even though

Table 6.1 Acceptable ID Documentation for Financial Services in the Philippines

Form of ID Sample
Listed in BSP Circular No. 608 Series of 2008
1 Passport
2 Driver’s License
3 Professional Regulation Commission ID
4 National Bureau of Investigation Clearance
5 Police Clearance
6 Postal ID
7 Voter’s ID
8 Barangay Clearance/Certificate
9 Government Service Insurance System ID
10 Social Security System ID
11 Senior Citizen’s ID Card
12 Overseas Worker’s Welfare Administration ID
13 Overseas Filipino Worker ID
14 Seaman’s Book

Table 6.1 Acceptable ID Documentation for Financial Services in the Philippines (continued)
Form of ID Sample
15 Alien Certificate of Registration
16 Government Office or Government Owned and Controlled Corporations ID

(such as AFP ID, HDMF [Pag-IBIG Fund] ID, and others)
17 Certification from the National Council for the Welfare of Disabled Persons —
18 Department of Social Welfare and Development ID
19 Integrated Bar of the Philippines ID
20 Company ID —
21 Student’s ID or School ID (as beneficiary for remittances or fund transfers) —
Other types of valid IDs not listed in the 2008 BSP circular
1 Tax Identification Number (TIN ID)
2 National Statistics Office (NSO) Birth Certificate
3 Marriage Certificate (NSO Authenticated)
4 PhilHealth Identification Card
5 Consular ID —
6 Permit to Carry Firearms
7 Company/Office ID —
8 Philippine Overseas Employment Association ID —
9 PRA Special Resident Retiree Visa ID —
10 Unified Multipurpose ID (UMID) —
Source: “Top 31 Valid ID’s Required in the Philippines,” affordableCebu website: http://www.affordablecebu.com/load/philippine_government
/top_28_valid_id_39_s_required_in_the_philippines/5-1-0-109#ixzz3bY8UUSZJ.
Note: BSP = Central Bank of the Philippines. — = not available.
BSP was given the authority and responsibility to regulate pawnshops since
1972, they remain the least-regulated businesses that fall under BSP.
For service providers, too, lack of a universally accepted ID is a barrier when
it comes to account opening and operating. With no universal national ID, the
financial sector must rely on other forms of ID, which not all customers may
have. The institutions have to manage their risk profiles while adhering to KYC

Figure 6.1 Use and Awareness of Payment System Providers in the Philippines, 2010
90
83
80 78
75
Share of users, percent (n = 1,000)
69 68
70
60
50 47 46
39
40 35
30 30 28 28
30 25 25
21 23 21
20 17
10
10 7 5
4 4
1 0 0 0
0
.
c.
h
n
a
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L
ps
s
r
IT
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ey
C
am
al
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as
io
et
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on
ad
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s,
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aw
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ar
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en
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GC
ym
es
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e,
SM
he
W
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Ot
Ot
la
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Awareness Usage
Source: BFA 2010.

Note: LBC Express is the market leader in the Philippines for payments, remittances, courier services, and so on. ML = M Lhuillier Bank.
and CDD guidelines set out by the authorities. Additional training and capacity
building will be needed to carry out an acceptable level of due diligence.
Regulators can set risk-based measures such as limited transaction amounts and
reporting thresholds to ensure financial access. Also, the agents will have to be
given clear guidelines and training on performing KYC and CDD duties using
acceptable ID documents. Again, anecdotal evidence shows that confusion
remains widespread, making customers apprehensive about going to a formal
financial institution.
UID is important in the provision of government welfare disbursements and
disaster recovery management. Using a UID to verify identification and entitle-
ment, and making the payments accordingly, could address the leakage and inef-
ficiencies in some transfer programs based on cash. Coupled with switching to
electronic payments, this could save the government a considerable amount of
money that could be channeled back to the welfare schemes. The Philippines is
one of the most disaster-prone countries in the world. Hence, streamlining its
disaster recovery program in terms of providing assistance is important for the
country. In the aftermath of super typhoon Haiyan in 2013, the Philippines’
primary statistics office revived calls for a national ID system to speed up the
process of identifying calamity victims—both the dead and the missing—and to
offer financial assistance to the surviving victims.
The Philippines had begun to move a step closer to getting a UID card. The
House endorsed Bill No. 5060 (the proposed Filipino Identification Act) for Senate

passage on May 20, 2015, which had been expected to greatly streamline govern-
ment transactions and promote more efficient service delivery. The proposed ID
system would bring all existing government-initiated ID systems into a single
integrated ID system. Once effectively implemented, the ID will provide proof of
identity, status, age, and address for admission to all learning institutions, employ-
ment purposes, voting identification, transactions in banking and financial institu-
tions, and provision of benefits or privileges afforded by law to senior citizens.
The House of Representatives had also approved a bill requiring the registra-
tion of all prepaid mobile-phone SIM cards. If Bill 5231 had become law, it
would cover tens of millions of existing and future prepaid mobile-phone users.
At present, anyone can buy a prepaid SIM card and use it without filling out any
form or being asked to present an identification card. Under the bill, as proposed,
sale may be denied if the buyer does not present valid and clear proof of identity.
In most countries SIM card registration with national ID is taken as the basic
threshold in setting risk-based tiered systems for KYC and CDD purposes. As of
May 2017, the Filipino Identification System (FilSys) had not yet been passed
into law.
By beginning to seriously consider the UID issue, the Philippines is addressing
one of the key conditions for mobile money proliferation. In a country already
facing unique geographical barriers to financial access, enabling government
programs to go digital and mobile offers a crucial step toward financial inclusion.
Steered by BSP as a forward-thinking and enabling regulator, the effort to lower
these macro-level barriers should improve the ability of the unbanked population
to access the mainstream financial sector in pursuit of economic opportunities.
India’s Aadhaar Program: Potential Game Changer in Digital

Financial Inclusion
The largest and best-known biometric ID program in the world is India’s UID
program, which provides a unique 12-digit identity number called “Aadhaar” to
855 million people (around 68 percent of the country’s total population) as of
May 2015 (figure 6.2).
In the year 2015 alone, 124 million people were admitted to the program at
a rate of about 24 million new identifications each month. Uttar Pradesh has the
highest number of registrations (118 million), followed by Maharashtra
(93.5 million), and West Bengal (63 million) (figure 6.3).
Genderwise, out of the total number of Aadhaar registrations, 51.8 percent are
male, while female coverage is 48.2 percent. Out of the total, 77.3 percent are
age 18 and above (figure 6.4). These numbers are truly impressive and remark-
able, especially considering that signing up for Aadhaar ID is not mandatory.
Aadhaar can affect financial inclusion and inclusive growth in a transformative
manner by establishing links with bank accounts and facilitating a variety of ser-
vices targeted at the poor.
Since issuing the first Aadhaar number on September 29, 2010, in Maharashtra
state, the Unique Identification Authority of India (UIDAI) remained on track

Figure 6.2 Aadhaar Registration Trends in India, 2014–15
30 855,197,481
27 833,709,544
24 812,221,607
Number of Aadhaars, millions
21 790,733,670
Cumulative Aadhaars
18 769,245,733
15 747,757,796
12 726,269,859
9 704,781,922
6 683,293,985
3 661,806,048
0 640,318,111
14
4
14
4
14
5
15
15
01
01
01
01
01
01
01
20
20
20
20
20
l-2
-2
t-2
r-2
-2
-2
-2
v-
c-
p-
n-
n-
g
ar
ay
b
Ju
Oc
Ap
De
No
Au
Ja
Ju
Se
Fe
M
Month values Cumulative values
Source: “Aadhaar Dashboard,” Unique Identification Authority of India (UIDAI), https://portal.uidai.gov.in/uidwebportal/dashboard.do.
Figure 6.3 Top 10 States for Aadhaar Registration in India, 2015
126
Number of Aadhaars, millions
108
90
72
54
36
18
0
ra
es a
an
es a
u
t
r
r
ha
ra
ad ta
ad hr
ad y
ak
ga
ad
ht
Pr adh
th
h
ja
Pr Ut
M esh
Pr nd
at
Bi
en
il N
as
Gu
rn
ja
A
M
ar
tB
Ra
Ka
ah
es
Ta
W
Source: “Aadhaar Dashboard,” Unique Identification Authority of India (UIDAI), https://portal.uidai.gov.in/uidwebportal

/dashboard.do.

Figure 6.4 Aadhaar Registration, by Gender and Age Group in India, 2015
100
77.3
80
Percentage of Aadhaars
60
40
21.5
20
1.2
0
0 to less than 5 to less than 18 years and
5 years 18 years above
Age and gender percentage of total Aadhaars
Female Male Transgender
Source: “Aadhaar Dashboard,” Unique Identification Authority of India (UIDAI), https://portal.uidai.gov.in

/uidwebportal/dashboard.do.
to achieve its target of issuing Aadhaar numbers to 930 million individuals by

the end of 2015. To reach such a massive scale, UIDAI used over 275 service
providers chosen through a competitive process in line with procurement norms
laid down by the government (figure 6.5). Both Indian and non-Indian organiza-
tions have contributed significantly to the proliferation of Aadhaar. In addition,
by December 2011, UIDAI had true and tested statistics demonstrating system
accuracy of 99.965 percent computed from an operational resident enrollment
database of 84 million people (UIDAI 2012b).
UIDAI was established under the Planning Commission of India with a
budget of Rs 123.98 billion (US$1.94 billion). By July 2013, Rs 30.62 billion
had been spent on the project (Economic Times 2013). The National Institute
of Public Finance and Policy conducted a cost-benefit analysis of the Aadhaar
project over a 10-year period (2010–21) and concluded that the Aadhaar
project has an internal rate of return in real terms of 52.9 percent to the gov-
ernment (NIPFP 2012).
Aadhaar offers a platform approach to financial services, especially financial
inclusion (figure 6.6), by providing standardized services such as
• Electronic KYC platform for Aadhaar-enabled accounts;

• A payments mechanism to facilitate direct benefits transfer (DBT) by govern-
ment departments; and
• Standardized consumer experience through the Aadhaar Enabled Payment
System (AEPS) and micro automated teller machines (ATMs).

Figure 6.5 Number of Aadhaar Registrations Completed by Top 10 Service

Providers in India, May 2015
Vakrangee
Softwares Ltd.,
47,126,300
Swathy Smartcards
Hi-Tech Pvt.,
41,421,518
Karvy Data
Management Services,
41,059,624
Others (267),
305,935,793
Wipro Ltd.,
40,369,312a
Tera Software Ltd.,

27,973,532
Madras Security Printers Ltd.,

26,949,013
Computer LAB,
24,639,129
Smart Chip
Financial Information Eagle Software Ltd.,
Network, India Pvt. Ltd., 21,187,700
20,247,800 20,777,192
Source: “Aadhaar Dashboard,” Unique Identification Authority of India (UIDAI), https://portal.uidai.gov.in/uidwebportal

/dashboard.do.
a. The number of Wipro registrations is as of 2017.
Figure 6.6 Financial Inclusion Applications of Aadhaar
Universal ID, valid all

India 6654 3212 9087
Interoperable
Only one number per
platform for multiple
person
applications
Anywhere authentication Identity verifiable

through demographics or through mobile and
biometrics online
Can link to a bank

account and mobile
Source: UIDAI 2012a. © Unique Identification Authority of India (UIDAI). Reproduced, with permission, from
UIDAI; further permission required for reuse.

AEPS allows Aadhaar cardholders to carry out financial transactions on a

micro-ATM terminal (point of sale [POS]) at a business correspondent (BC).5
The Aadhaar number, along with an individual’s mobile number and an elec-
tronic bank account number, can revolutionize the way people access and
transact financial products and services. Aadhaar has the potential to become
the universal linkage for disbursing government payments in a more secure,
streamlined, efficient, and cost-effective way.
e-KYC and Aadhaar-Enabled Accounts

With Aadhaar, the banks can now authenticate customer details with the UIDAI.
The UIDAI provides an e-KYC service through which the KYC process can be
performed electronically with explicit authorization by the cardholder. As part
of the e-KYC process, the cardholder authorizes UIDAI (through Aadhaar
authentication using either biometrics or a one-time password) to provide their
demographic data along with their photograph (digitally signed and encrypted)
to service providers such as banks (UIDAI 2016). This process facilitates easy and
quick account opening at banks.
The Aadhaar-linked e-KYC also provides a hassle-free approach for the mil-
lions of poor in India who do not have other ownership or identity documents.
The Reserve Bank of India (RBI) in September 2013 approved the paperless
electronic authentication (e-KYC) provided by the UIDAI as valid ID documen-
tation. Previously, in December 2012, the RBI allowed the use of the Aadhaar
enrollment letter as a valid proof of identity and address (Rao 2013). These are
important regulatory measures taken by the regulator to further financial
inclusion.
Electronic opening of accounts at the time of Aadhaar enrollment is possible
in partnership with banks through an electronic process. Aadhaar can also be
linked to an existing bank account through any of the delivery channels—for
example, branch, ATMs, Internet, mobile, and micro-ATMs. Any bank interested
in using the facility must use UIDAI-approved biometric scanning devices and
register with it to receive access to its data.
Direct Benefits Transfer

To facilitate DBT, bank accounts of the recipients can be linked with the
Aadhaar number. This ensures that money under various developmental wel-
fare schemes and subsidies reaches beneficiaries directly and without delay.
The scheme was launched in the country in January 2013 and has been
rolled out in a phased manner, starting with 26 welfare schemes in 43 districts.
This was extended to an additional 78 districts and three more schemes from
July 1, 2013, and is to be extended to the entire country in a phased manner
(Srikanth 2013).
The government also started transfer of a cash subsidy for domestic lique-
fied petroleum gas (LPG) cylinders6 (used for energy and fuel purposes by
households) to Aadhaar-linked bank accounts of the customers from June 1,
2013, in 20 pilot districts. About 7.5 million recipients benefited in these districts.

A modified scheme was relaunched in November 2014 in 54 districts covering

23 million households, and will be phased into the balance of 622 districts in the
rest of the country.
The scheme aims at halting diversion to other purposes of highly-subsidized
LPG cylinders meant for domestic use. Over 153 million consumers across
676 districts of the country will be covered. Currently over 65 million consumers
have already joined the scheme and will continue to receive the subsidy through
their bank accounts. Since the modified program was launched in November
2014, an amount of Rs 6.24 billion has been transferred to over 2 million LPG
consumers (MPNG 2014).
The Mahatma Gandhi National Rural Employment Guarantee Act
(MGNREGA) is one of the flagship schemes of the Ministry of Rural
Development (MoRD), which guarantees 100 days of wage employment in a
financial year to every rural household whose adult members volunteer to do
unskilled manual work. Since September 2013, MoRD has been actively work-
ing toward collecting Aadhaar data of its beneficiaries, entering the data into
NREGASoft (software used by MGNREGA) and beneficiary bank accounts,
and thereafter making payments through the Aadhaar Payment Bridge System.
So far, providing the Aadhaar ID is optional. By October 2014, 20.7 million out
of 105 million beneficiaries of MGNREGA had already linked their Aadhaar
accounts to the program (MGNREGA 2014). According to news articles,
Rs 150 billion will be disbursed annually to around 43 million MGNREGA
beneficiaries (Mehra 2015).
Using the DBT facility, all types of social welfare schemes offered by dif-
ferent government departments can be streamlined and managed through a
single Aadhaar-linked account, thus creating efficiency gains for the govern-
ment while reducing opportunity and accessibility cost to the recipients.
An International Monetary Fund report (IMF 2013) states that the total
savings from linking DBT to Aadhaar bank accounts could be substantial.
The report highlights that leakages from outdated biographical information,
“ghost” identifications, double registration, and other losses are estimated in
the range of 15–20 percent of total spending. If the combination of direct
cash transfer and Aadhaar eliminates the estimated 15 percent leakage cited
above for the programs being integrated, savings could total 0.5 percent of
gross domestic product (GDP), in addition to the gains from the better tar-
geting of spending on the poor.
Micropayments and the Aadhaar-Enabled Payment System

To enable payments from the Aadhaar-linked accounts, banks are issuing
debit cards to beneficiaries. Banks have also started strengthening banking
infrastructure, providing BCs in areas that were previously unserved, and
introducing mobile banking solutions to ensure access and facilitate payments
over a wide geographic area. The branch networks with ATMs, along with
mobile banking systems and BC agents, ensure that banking services reach all
the beneficiaries.

The cost of providing banking services to the poor, who transact in small
amounts, is a limitation. Banks consider such “micropayments” unattractive
because the transaction costs are relatively high. Aadhaar enables an efficient,
cost-effective payment solution (AEPS) for promoting financial inclusion.
AEPS is a bank-led model that allows online interoperable financial inclusion
transactions at POS (also called micro-ATMs) that are operated by a BC or BC
subagent, appointed by banks using the Aadhaar authentication. Unlike an
ATM, the cash-in/cash-out functions of the micro-ATM are performed by an
operator, thus bringing down the cost of the device and the cost of servicing the
customer. The micro-ATM supports deposits, withdrawals, fund transfers, and
balance inquiries. Once successfully deployed, the AEPS payment mechanism
will allow account access from anywhere through any delivery channel online in
real time, thus enabling an efficient and cost-effective remittance transfer system
within India. In addition, a variety of other services such as microcredit, micro-
insurance, and micropensions can be offered on top of this solution.
Though Aadhaar was a policy initiative by the previous government, it has
received support from the present government. The Prime Minister’s Office
(PMO) has directed the Planning Commission to collect data on Aadhaar and
DBT schemes in 300 priority districts where Aadhaar enrollment is currently
over 60–70 percent, as well as information on Aadhaar and DBT with respect to
five key government schemes: MGNREGA, pensions, scholarships, Public
Distribution System, and LPG (Tewari 2014). The Indian government subsidizes
food, fuel, and fertilizers, with the total subsidy bill earmarked in the 2015 bud-
get at a massive Rs 2.5 trillion (around 2 percent of GDP). A significant portion
of these funds is believed to be wasted because of improper targeting, middlemen,
corruption, and duplication. Hence the Aadhaar-enabled DBT system could
eventually address this massive leakage.
Issues and Setbacks with Aadhaar

Aadhaar is not without its critics among privacy and security advocates and others.
Privacy and information security are very real concerns in a civil society, hence the
need for open dialogue and providing assurance, especially given the way e-money
in India is poised to take off with the introduction of Jan Dhan Yojana (JDY)
accounts linked to the Aadhaar ID (as discussed further in chapter 4).
To address such concerns, a simplified form of security policy and standards
should be introduced at inception so that service providers as well as users under-
stand the potential risks in digital finance and adhere to security guidelines and
procedures. Given that the system is dedicated to the poor and underserved
groups, a disruption could have far-reaching political, economic, and social con-
sequences. Other issues and concerns about Aadhaar are discussed in the next
two subsections.
Aadhaar and the National Population Register

In addition to UIDAI and Aadhaar, the government of India initiated
the National Population Register (NPR) in 2010, entailing the creation of a

Table 6.2 Key Differences between Aadhaar and the National Population Register
Aadhaar National Population Register
Voluntary Mandatory
UIDAI issues a number Only a register
For identity and authentication Signifies resident status and citizenship
Based on other forms of documentation and identification Based on census information
Note: UIDAI = Unique Identification Authority of India.
National Citizens Register, which is being prepared at the local, subdistrict,

district, state, and national levels. The database will contain 13 categories of
demographic information and 3 categories of biometric data collected from all
residents ages five years and above. Collection of this information was initially
supposed to take place during the house listing and housing census phase of
Census 2011 from April to September 2010 (Hickok 2013). The NPR is legally
enshrined in the provisions of the Citizenship Act 1955 and the Citizenship
Rules 2003.
While it is not clear why two separate exercises are needed, the Planning
Commission is of the view that it is necessary to speed up the collection of bio-
metric details of residents and issue them Aadhaar numbers as well as National
Multi-purpose Identity Cards. The key differences between the two programs are
shown in table 6.2.
Cost of Making Existing Infrastructure Aadhaar-Enabled

While the innovations have helped in generating the world’s cheapest ID cards
under the UIDAI—costing around Rs 100 per person (Economic Times 2014)—the
challenge will be deployment of Aadhaar-compliant biometric fingerprint POS
devices (micro-ATMs) at hundreds of thousands of agents. This can be a costly
and complex proposition, making it challenging for the system to be scaled up
quickly in a cost-effective manner.
In addition, given the financial inclusion mandate, although the govern-
ment wants biometric authentication for credit card and ATM transactions,
the market players are hesitant because of the costs they have to incur to
upgrade each and every ATM and POS at thousands of merchant outlets.
The RBI-constituted panel has estimated the cost of banks’ readiness for
Aadhaar at around Rs 42.6 billion. It is interesting to note that, other than
the cost, the stakeholders agree on most things, and one cannot rule out the
potential internal demand that is being created by the government through
this massive financial inclusion project.
The Indian economy predominantly uses cash, with cash in circulation in
2013 at around 13 percent of GDP (more than double the global average)
(Chakrabarty 2014). Studies have estimated that the cost of cash to the economy
is significant (around 5–7 percent of GDP). This cost could be reduced by digi-
tizing payments.
Aadhaar has come a long way from its 2009 inception and is on track to
deliver transformational outcomes to India’s poor. Financial inclusion is one such

application riding on the UIDAI’s infrastructure, since possession of an Aadhaar

number enables opening of a bank account. Unlike a cash-in/cash-out e-wallet
in an MNO-led mobile money solution, hundreds of millions of potential micro-
entrepreneurs who were outside the banking system are being brought into the
credit economy.
Some critics maintain that UIDAI has no legal standing. However, the present
government is placing considerable emphasis on its financial inclusion agenda
and plans to accelerate DBT payments through JDY bank accounts linked to the
Aadhaar number. Hence it is likely that the government may resolve this issue,
perhaps through a legislative enactment conferring statutory authority to UIDAI.
Sri Lanka: Mobile Connect, the Interoperable ID

Mobile Connect is your new online identity. Simply by matching you to your
mobile phone, Mobile Connect lets you log-in to websites and applications
quickly without the need to remember passwords and usernames. It’s safe,
secure and there’s no need to worry that your personal information will be
shared without your permission.
—Groupe Speciale Mobile Association (GSMA),
“Introducing Mobile Connect”
The importance of a UID for success in scaling up mobile money or digitized gov-
ernment benefit programs was discussed in the two case studies earlier in this
chapter. Although in the real world, a person’s identity can be established and
verified using identity cards and documents along with personal face-to-face
verifications, in the digital world identity verification has to rely on digital identi-
ties. A digital identity is an online or networked identity adopted or claimed in
cyberspace by an individual, organization, or electronic device. These users may
also project more than one digital identity through multiple communities. In terms
of digital identity management, key areas of concern are security and privacy.
Because digital identities created by individuals are inherently weak, and such
identities are linked to online websites, e-mail addresses, or domains, security
becomes a key consideration. The Mobile Connect Sri Lanka case study focused
on how digital identity management allows consumers to move seamlessly from
cash to cash-lite transactions through digital services. This is neither a costly
operation nor meant only for expensive transactions. On the contrary, for average
consumers, digital identity solutions such as Mobile Connect offer privacy pro-
tection, reduce the risk of identity theft, and simplify the login experience for a
range of services, such as retail, health care, government, and banking, among
others (Finextra 2014).
The Mobile Service Providers

In Sri Lanka, mobile penetration has grown steadily from 87 percent in 2011 to
123 percent in 2016 (Harpur 2016). Sri Lanka also has the world’s lowest rates

for fixed broadband Internet, around US$5 per month, resulting from a high
level of competition among the suppliers and the government’s explicit aim to
keep the cost to a minimum (ITU 2012).
There are currently five mobile operators in Sri Lanka. Dialog Axiata, the mar-
ket leader, and Sri Lanka Telecom Mobitel have a combined market share of over
65 percent, with around 9.5 million and 5 million customers, respectively. To date,
the top four market players have all offered MNO-led mobile money services.
Mobile Connect
In February 2014, Groupe Speciale Mobile Association (GSMA) announced
the launch of a collaborative initiative, supported by leading mobile operators
(including Axiata Group Berhad, China Mobile, China Telecom, Etisalat,
KDDI, Ooredoo, Orange, Tata Teleservices, Telefónica, Telenor, Telstra, and
VimpelCom), to develop an innovative, interoperable ID that would allow
consumers to securely access a wide array of digital services using their
mobile-phone account for authentication (GSMA 2014). The first interoper-
able beta trial of Mobile Connect was launched by Dialog and Mobitel com-
panies in Sri Lanka jointly in July 2014. WSO2, another Sri Lanka-based
company, provided the Identity Server on OpenID Connect protocol, thereby
providing broad interoperability across the mobile operators and online ser-
vice providers.
The result is the world’s first multioperator Mobile Connect solution that
provides an out-of-band medium for authenticating a user to any service
provider without requiring a password. The identity given under Mobile
Connect is a form of a “validated” identity. The user’s credentials are always
stored with the “home” entity (the “identity provider”). When the user logs
into a service, instead of providing credentials to the service provider, the
service provider trusts the identity provider to validate the credentials.
So the user never provides credentials directly to anybody but the identity
provider.
The User Case

The mobile operators usually have a subscriber base with their identities already
verified. Since Sri Lanka has unique national ID cards and SIM card registration
is mandatory, mobile operators already have the customers’ credentials. At the
beta stage, popular online e-commerce sites and an insurance provider were
linked to the system. The consumers were able to directly access the online sites
via mobile phones.
The system provides two types of authentications: implicit, where the cus-
tomer is logged into the website seamlessly; or explicit, where the user is
prompted to click OK. If the user is not on a mobile network (Wi-Fi access or
on a computer or other devices), the user will then be prompted to enter the
mobile number. However, this information is viewed only by the identity pro-
vider and not by the online service provider. In both instances the service pro-
vider only receives a verification of the credentials.

Figure 6.7 Mobile Connect Beta Trial Indicators
83% 63% 80% DESCRIBED
66%
Would recommend THE SERVICE AS
AUTHENTICATED VIA USSD CHANNEL. mobile connect. EASY TO USE.
90% 66%
72% WOULD
RECOMMEND REPORTED
SAID IT WAS
THEIR OPERATOR
FOR HAVING REPORTED CONSISTENCY ACROSS
IMPROVED EASIER THAN
OTHER LOG-IN
MOBILE CONNECT. DIFFERENT WEBSITES. PRIVACY. METHODS.
Source: GSMA 2015. © Groupe Speciale Mobile Association (GSMA). Reproduced, with permission, by GSMA; further permission
required for reuse.
Note: USSD = unstructured supplementary service data.
The customers enjoy a hassle-free, consistent experience across different

online sites and never need to remember multiple usernames or passwords.
Moreover, the identity information is protected, and customers can surf the web
and make online purchases and payments without having to worry how their
personal information will be used by the service providers. Although the beta
trial was not considered statistically significant and the results were taken only as
indicative, the beta users acknowledged satisfaction with the service provided by
Mobile Connect (figure 6.7).
Future Pathways
In Sri Lanka Mobile Connect is now available as a service for the entire cus-
tomer base of both Dialog and Mobitel, totaling more than 15 million subscrib-
ers, and the companies are actively mobilizing service partners. Joint marketing
and public awareness campaigns are ongoing. Dialog Axiata and Sri Lanka
Telecom Mobitel won a special award at the European Identity Conference
2015, for the Mobile Connect implementation with the WSO2 Identity Server
(BusinessWire 2015.)
By 2015, the GSMA had already announced that 17 MNOs had launched the
Mobile Connect service in 13 countries, with plans for additional launches
and beta trials to follow. The GSMA’s Mobile Connect service enables customers
to create and manage a universal identity that will securely authenticate them
and allow them to safely access mobile and digital services such as e-commerce,
banking, health, and digital entertainment as well as e-government portals via
their mobile phones.
Because digital identity reduces the uncertainties inherent in transactions
effected from a distance, using digital identity has huge potential for developing
countries. Given the proliferation of mobile phones in developing countries,
mobile identity can be used effectively in a variety of ways. There are different
levels of security, from low-level website access to highly secure bank-grade
authentication. This can be effectively used by government welfare schemes,

for remittance transactions, financial transactions, and other online e-commerce

sites. Even for poor and older people who may find navigating the complex digi-
tal world challenging, having a digital identity through an identity provider
would work more effectively than having to remember usernames, personal
identification numbers (PINs), and passwords.
One very important issue to be addressed before scaling up this service is an
evaluation of the e-identity laws and regulations in a country. Even Sri Lanka does
not have such laws and regulations. Such regulations and guidelines would increase
the effectiveness and transparency of public and private sectors’ electronic services
by providing legal clarity in terms of security and data protection requirements,
national supervisory mechanisms, and reinforced accountability and interoperability
frameworks. Hence, developing countries should look at developing digital identity
services in a holistic manner.
Notes
1. A single country may have multiple cases (up to 15, for India) involving different
actors at the state, local, and national levels. The total population being targeted is
estimated.
2. iPhone 5S and Samsung Galaxy S5 and subsequent-generation phones come with
fingerprint scanners.
3. BSP Circular No. 608 Series of 2008.
4. Sari-Sari (“variety”) are little convenience stores.
5. Under the “business correspondent” model, nongovernmental organizations/
microfinance institutions set up under Societies/Trust Acts, Societies registered under
Mutually Aided Cooperative Societies Acts or the Cooperative Societies Acts of
States, section 25 companies, registered nonbanking finance companies not accepting
public deposits, and Post Offices may act as business correspondents (RBI 2006).
6. The DBT of LPG scheme, PAHAL (Pratyaksh Hanstantrit Labh).
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PA R T I I I
South Asia Digital

Landscape, Future Options,
and Conclusions
This study has examined how macro-, meso-, micro-, and customer-level actors
can lead, engage, and influence the policies, regulations, processes, and ecosys-
tems to achieve greater financial inclusion through critical game-changing
measures that foster innovative digital solutions. The experiences of the countries
studied, both within and outside the South Asia region, have revealed many
useful lessons that can be used as guiding principles to enhance financial inclu-
sion in South Asia and in the developing world as a whole.
Part III aims to distill the guiding principles and measures that would help
avoid the deficiencies and pitfalls that have constrained the pace of scaling-up
in several countries, and to suggest (in chapter 8) how they could be applied
to help change the digital landscape in South Asia (summarized in chapter 7)
as well as in developing countries more generally (chapter 9). Even though the
game-changing elements discussed in this study, and digital finance per se, can-
not be considered a panacea for persistent financial exclusion problems, the
lessons discussed here provide valuable options for policy makers and market
players in addressing shortfalls in the use and reach of financial services.

CHAPTER 7
Digital Landscape in South Asia
Introduction
South Asia consists of eight countries at different stages of economic development,
with widely varying economic characteristics and attributes. With nearly
40 percent of the developing world’s poor living in the region (World Bank
2015) and 54 percent of the region’s adult population (585 million) financially
excluded,1 addressing the financial inclusion gap is critically important.
Comparison of Findex data across the regions reveals that the South Asia region
lags behind the East Asia and Pacific, Europe and Central Asia, and Latin America
and the Caribbean regions in the percentage of adults with accounts, females with
accounts, and the poorest 40 percent with accounts in formal financial institutions
(table 7.1). On the other hand, the percentage of young adults (ages 15–24 years)
with accounts in South Asia compares well with the other regions.
Even though the mobile account ownership indicator for South Asia is the
second highest behind Sub-Saharan Africa, at 2.6 percent, considerable efforts
are needed to push the mobile account ownership numbers closer to the
11.5 percent achieved in Sub-Saharan Africa. South Asia shows limited owner-
ship and use of debit cards and credit cards (8.5 percent and 2.6 percent,
respectively). Although automated teller machines (ATMs) seem to be the
preferred method of cash withdrawal (31.1 percent), the region scores rela-
tively low on receipts of wages and government grants to accounts (3.5 percent
and 3.1 percent, respectively) and utility bill payments using an account
(2.7 percent). These gaps represent opportunities to use digital means to reach
the poor and unbanked in a more meaningful manner.
Before examining the applicability of the lessons and guiding principles from
the case study countries, it is important to diagnose the digital landscape and
readiness of each country. Detailed country reports based on publicly available
information and data gathered from different sources are summarized in
an “at-a-glance” matrix in chapter annex 7A, table 7A.1. This chapter also
reviews the status of South Asian countries in terms of the key themes at differ-
ent levels of analysis, as a basis for applying the lessons of experience and guiding
principles in chapter 8.

180 Digital Landscape in South Asia
Table 7.1 Financial Inclusion Data by Region, 2014

Percentage
High- Latin America Sub-

East Asia Europe and income and the Middle South Saharan
Data type and Pacific Central Asia OECD Caribbean East Asia Africa
Account (age 15+) (w2) 69.0 51.4 94.0 51.4 14.2 46.4 34.2
Account, female
(age 15+) (w2) 67.0 47.4 93.8 48.6 9.2 37.4 29.9
Account, income, poorest
40% (ages 15+) (w2) 60.9 44.2 90.6 41.2 7.3 38.1 24.6
Account, young adults
(ages 15–24) (w2) 60.7 35.6 84.1 37.4 7.6 36.7 25.9
Account, rural
(age 15+) (w2) 64.5 45.7 93.8 46.0 10.7 43.5 29.2
Account at a financial
institution
(age 15+) (w2) 68.8 51.4 94.0 51.1 14.0 45.5 28.9
Account at a financial
institution
(age 15+) (w1) 55.1 43.3 90.0 39.3 10.9 32.3 23.9
Mobile account
(age 15+) (w2) 0.4 0.3 — 1.7 0.7 2.6 11.5
Debit card (age 15+) (w2) 42.9 36.9 79.7 40.4 8.5 18.0 17.9
Debit card (age 15+) (w1) 34.7 36.4 61.9 28.9 5.5 7.2 15.0
Main mode of withdrawal:
ATM (with an account,
age 15+) (w2) 53.3 66.7 — 71.1 44.9 31.1 53.8
Main mode of withdrawal:
ATM (with an account,
age 15+) (w1) 37.0 72.5 68.5 57.0 42.4 16.9 51.7
Used an account to receive
wages (age 15+) (w2) 15.1 22.5 44.3 18.0 3.3 3.5 7.3
Used an account to receive
government transfers
(age 15+) (w2) 8.1 7.3 17.2 9.0 0.9 3.1 3.8
Used an account at a
financial institution to
pay utility bills
(age 15+) (w2) 11.8 12.5 61.1 6.3 0.2 2.7 2.8
Debit card used in the past
year (age 15+) (w2) 14.8 22.9 65.3 27.7 3.3 8.5 8.7
Credit card used in the
past year (age 15+) (w2) 10.8 14.9 46.7 18.0 1.5 2.6 1.9
Source: Global Findex 2014 data, http://datatopics.worldbank.org/financialinclusion/.
Note: — = not available; ATM = automated teller machine; OECD = Organisation for Economic Co-operation and Development. “w1” denotes
2011 Global Findex data (wave 1), and “w2” denotes 2014 Global Findex data (wave 2).

Digital Landscape in South Asia 181
Macro-Level Strategies
At the macro level (of policy makers, regulators, and donors), a few of the South Asian
countries have started aligning policies and strategies on financial inclusion as a
national agenda. Lack of a clear national strategy—as well as changes in strategy
when governments change—has resulted in inconsistent policies and discontinu-
ity of results-oriented programs. The region’s countries vary widely in their
approaches, although several have made progress:
• India now has a clear direction and vision, and the country has embarked on a
financial inclusion strategy focused heavily on digital financial inclusion
modalities.
• Pakistan has not yet formulated a comprehensive digital agenda for financial
inclusion, although its high-value payment system is digitized, and it report-
edly launched a national financial inclusion strategy in 2015.
• Sri Lanka does not have a national-level, comprehensive financial inclusion
strategy, but the country has a clear information and communication technol-
ogy (ICT) and e-government policy, and the Central Bank has pursued use of
digital finance for financial inclusion under its payment systems policy agenda.
• Bangladesh is also driving financial inclusion as part of its strategic plan, and it
has a national ICT policy that promotes digitization.
Meanwhile, a comprehensive national policy or strategy on financial inclusion

is absent in Afghanistan, Bhutan, Maldives, and Nepal, although efforts by their
respective central banks to address financial inclusion issues can be observed in
each country. More recently, the Maldives Monetary Authority (MMA), together
with the Ministry of Finance and Treasury, has decided to use mobile network
operator (MNO)-led mobile money as a short-term solution to address access to
finance and financial inclusion issues in the outer islands and atolls. In Nepal, a
large number of poverty alleviation–related programs have been initiated with
the help of donor agencies, but there is no comprehensive program for the use
of digital finance as a solution to address issues relating to financial inclusion.
Post-earthquake Nepal is experiencing many new issues and may need to draw
up a long-term strategy for this purpose. Afghanistan has a comprehensive wish
list, but it still has to prioritize the main programs that would address financial
inclusion issues. Bhutan is moving slowly with a declaration to support financial
inclusion, but it has yet to implement a sustainable strategy.
Traditionally, South Asian central banks have been the driving force in
financial sector development. However, lack of appropriate legal and regula-
tory structures has been a common problem of the e-money landscape in
South Asia. Nonbanks have taken the lead in providing e-money services at an
affordable cost to the poorer groups. The phenomenal growth in the use of
mobile phones in South Asia means that MNOs have the capacity to surpass
the traditional banking model in terms of facilitating access by the poor and
unbanked to basic payment and financial services.

However, because MNOs are outside the ambit of the financial regulatory
authorities, special dispensations are often necessary to permit these nonbanks
and MNOs to enter the payment space to provide mobile-phone–based e-money
solutions to the poor and the unbanked. India, Pakistan, and Sri Lanka have
enacted Payment and Settlement Laws. The other South Asian countries have no
payment laws but have used the provisions in the central bank or the monetary
authority Acts to issue relevant regulations for this purpose. Bangladesh has
drafted a Payment Law, and Maldives has submitted a bill to the parliament. All
countries have Anti-Money Laundering and Combatting Funding of Terrorism
(AML/CFT) laws or regulations covering financial transactions, many of which
are being reviewed.
Among the South Asian countries, Sri Lanka has the most comprehensive set
of enabling laws and regulations for digital finance and facilitating nonbanks to
enter into the payment space. It continues to adopt a flexible approach toward
promoting nonbank entry, but within the applicable legal framework.
Meso-Level Approaches and Issues

A supportive infrastructural environment for e-money is important for digital
finance to be successful as a means of enhancing financial inclusion. However,
many South Asian countries continue with ad hoc, proprietary, stand-alone systems
that do not necessarily provide a low-cost, affordable solution for the customers.
India has begun the process of making formal financial services available at
affordable costs—for example, by mandating its banks to use a common applica-
tion programming interface (API) for mobile banking and ensuring that bank-led
e-money projects are interoperable at all possible levels. The country’s biometric
identification (ID) initiative, Aadhaar, is an exceptional measure India has intro-
duced to ensure that a unique ID is available to help mobile-phone users to open
accounts and social grant recipients to access funds anywhere in the country.
Financial infrastructure provision is well coordinated by the Reserve Bank of
India, with support from the relevant ministries.
For its part, Sri Lanka has put key financial infrastructure in place, and systems
are running well to ensure that services are available. However, coordination at
the policy and regulatory levels needs improvement, in particular to address the
passive role played by the national payments committee (NPC). LankaClear Pvt.
Ltd., the retail payment infrastructure provider, is ready to move faster toward a
fully interoperable Common Switch, but this requires tight coordination among
stakeholders.
Bangladesh is still hesitant to allow MNOs to enter the payments arena,
despite the problems encountered in the bank-led agent network. Maldives is a
difficult geographical terrain for rolling out the necessary financial infrastructure,
and the outer islands and atolls have no efficient and conveniently available
access to payment and financial services. Therefore, a mobile money initiative is
now under way in Maldives that will be low-cost relative to services from banks
and other financial institutions.

Achieving full-scale financial inclusion is difficult in both Pakistan and

Afghanistan because of ongoing security situations. Nevertheless, authorities are
taking steps to deal with operational issues while promoting user-friendly digital
products to enhance financial inclusion. Nepal has a private switch and a national
common switch, but a comprehensive national strategy is needed to drive
efficiency. Interoperable National Payment Switches (Common Switch) have
been established in Bangladesh and Sri Lanka, although not all banks have joined
these national switches.
One unique feature about the South Asia region is that all eight countries are
members of the South Asian Association for Regional Cooperation (SAARC)
Payment Council (SPC), established in 2008 to promote sound payment and
settlement systems in the member countries. Digital finance as a means to
address financial inclusion issues can be taken up by this regional body.
Agent network management is a concern for mobile money in most South
Asian countries. Most MNO-led or bank-led but agent-managed initiatives are
experiencing issues with respect to over-the-counter (OTC) transactions—that is,
transactions that the agent conducts on behalf of a sender/recipient or both from
either the sender’s or the agent’s mobile money account. These OTC transactions
are often preferred by illiterate customers because they are apprehensive about
effecting their own transactions using their mobile or prepaid cards. However,
these agent-assisted transactions pose a number of issues including limiting the
evolution of a digital cash-lite ecosystem; decreased provider profitability because
of the high cost of monitoring; and unregistered transactions, which run the risk
of money laundering and terrorism financing.
In Sri Lanka OTC is not encouraged. In Bangladesh, the bKash system suffers
from liquidity rebalancing and consumer protection issues, as customers often share
their pin numbers with the agents. These issues require improved governance at the
agent level, and financial education at the customer level.
India also suffered a long time with OTC-type transactions, but more recently
has attempted to address some of the recurring issues. An MNO agent system is
cheaper than the bank-led models’ agent system, and it is critical for MNO
operations. Often, these agents are nondedicated to the mobile money operation,
and they engage in many other ancillary services.
Micro-Level Models
South Asian countries are heavily bankcentric, and financial system development
is usually driven through regulations. Although countries have recognized the
financial inclusion gaps and tried to find solutions, most of them still favor bank-
led models over MNO-led mobile money solutions.
India passed legislation permitting “payment banks” and “small finance banks,”
and deposit accounts in those entities are eligible for risk-proportionate know-
your-customer (KYC) procedures. The Reserve Bank of India (RBI) also amended
the regulation enabling nonbank entities to be banking correspondents. This will
enable nonbank entities, including mobile operators, and the national postal

service (with a larger network) to offer financial services by obtaining a banking

license. However, these payment banks and small banks will be subjected to
prudential regulations. Hence, the minimum capital requirement and other pru-
dential regulations will need to be addressed to facilitate scaling up to reach the
masses. And in Bangladesh, bKash—a fully owned subsidiary of BRAC Bank with
more than 80,000 agents—is the second largest mobile money company in the
world in terms of the number of individual accounts.
Only Afghanistan and Sri Lanka have allowed MNOs to enter the payment
space and offer MNO-led mobile money services. All others have stayed with the
bank-led model or some variation of it, partly because of legal and regulatory
issues. Although MNOs have the natural advantage of reaching rural people and
the poor, as they already have their last mile touchpoints in place, South Asian
policy makers and regulators generally remain hesitant to promote MNO-led
mobile financial services. Nevertheless, Maldives is actively launching an MNO-
led mobile money solution.
Sri Lanka has the world’s first single-wallet, end-to-end interoperability
among three MNOs. In terms of ATM interoperability, Bangladesh, India,
Pakistan, and Sri Lanka have full or partial interoperability. Most signifi-
cant is India’s Aadhaar-enabled accounts that allow for interoperable
transactions through any banking business correspondent of any bank
using Aadhaar biometric verification and authentication. If successful, this
would truly be a game changer for financial inclusion. Some forms of
interoperability exist in Nepal (eSewa payment gateway) and Pakistan
(between MNOs and banks).
South Asian countries have not used digital means to provide government
salaries or social grants in an effective manner. Afghanistan used mobile money
to send civil servant salaries, and India recently launched Aadhaar-enabled Jan
Dhan Yojana bank accounts to channel direct benefit transfers and all government
payments. Digitizing government-to-person payments has already started in
India by depositing government pension and scholarship payments directly into
bank accounts in some of the districts. Pakistan has also used National Database
and Registration Authority (NADRA) prepaid biometric cards to disburse flood
relief to victims, but it has yet to configure all grant disbursements to go through
such a mechanism. All others use a combination of cash and savings accounts in
microfinance institutions or commercial banks to disburse government benefits.
There is a huge opportunity to streamline grant payments, government salaries,
and pension payments.
Customer-Level ID Systems
The lack of a unique identity has been a continuing problem in the South Asia
region, and these countries will need to introduce digital ID systems to enable
the lower-income population to access formal financial institutions. India
now has provided a long-term solution: the Unique Identification Authority
of India (UIDAI)’s Aadhaar program is continuing the process of assigning ID

numbers to all citizens, having already issued 855 million IDs (68 percent of
the population).
Afghanistan, Bhutan, Maldives, and Sri Lanka have unique IDs, and Sri Lanka
is also planning to go for a biometric ID system that would solve many issues
related to fake IDs submitted at the time of opening a bank or transactional
accounts. Afghanistan came out with a digital ID (electronic-Tazkera) in 2015.
Bangladesh, Bhutan, and Nepal have multiple IDs, as does Pakistan—although
it now offers a Computerized National Identity Card (CNIC) by NADRA that
verifies users’ biometric data. NADRA also does biometric verification when
registering a new subscriber identification module (SIM) card.
Although all South Asian countries have data on grant recipients, India and
Pakistan have developed biometric-enabled databases, which is a significant step
forward. South Asia could learn from South Africa’s successful experience with
a biometric ID system (as discussed in chapter 6), which has managed to avoid
some of the KYC and customer due diligence and AML/CFT issues.

186
Annex 7A Digital Financial Landscape in South Asia, by Country: At a Glance

Table 7A.1 Digital Financial Landscape in South Asia: At a Glance
Digital finance
enabler Afghanistan Bangladesh Bhutan India Maldives Nepal Pakistan Sri Lanka
A. MACRO-LEVEL POLICIES, STRATEGIES, LAWS, AND REGULATIONS
1. Declared national policy or strategy
National financial No No separate policy; No: Maya Yes: Pradhan No Demand survey Yes: financial No: CBSL drives the
inclusion policy or Central Bank drives Declaration Mantri Jan done under MAP inclusion strategy, financial inclusion
strategy available financial inclusion signed; financial Dhan Yojana, program UNCDF; 2015 strategy
strategy inclusion policy 2014 on track to prepare
(Bangladesh Bank’s drafted road map to
strategic plan financial inclusion
2010–14
strategy #4)
National financial
inclusion strategy
being drafted
National digital No: Commitment Yes: Digital No Yes No No Yes: as part of No explicit agenda
financial agenda to Better than Cash Bangladesh Vision financial inclusion
Alliance; 2021 strategy
government-formed
Digital Finance
Committee to
oversee the salary
payments of civil
servants
National ICT No Yes: Digital No Yes No No Draft national ICT Yes: e-government
policy or Bangladesh Vision policy of 2012
e-government 2021
policy
Table 7A.1 Digital Financial Landscape in South Asia: At a Glance (continued)

Digital finance
National payment No Being done Being done Yes No No Not clear whether No: need to assess
strategy there is a the long-term
long-term strategy
strategy
2. Legal and regulatory (enabling laws and regulations)
Payment and No No (draft act) No Yes Bill stage No Yes, but restrictive Yes
settlement law
Payment Yes Yes Yes Yes Yes Yes: NRB IT Policy, Yes Yes
regulations under #2068 under
other laws (central NRB Act
bank law,
monetary
authority law, or
banking act)
AML/CFT law or Yes Yes Yes Yes Yes Yes Yes Yes
financial
transaction law or
regulations
Financial No No No: through Yes: also No No No No: only through
consumer other acts and banking financial
protection law or regulations ombudsman ombudsman and
regulations CBSL mechanisms
Electronic funds Yes: e-money issuer Yes No Yes: regulations No No Yes Yes
transfer law or regulations 2011 under RBI Act
regulations
187
188
Digital finance
A. MACRO-LEVEL POLICIES, STRATEGIES, LAWS, AND REGULATIONS (continued)
2. Legal and regulatory (enabling laws and regulations) (continued)
Electronic or No No No India IT Act No No No Yes
computer 2000, IT
transactions law or (Amendment)
digital finance law Act 2008 deals
with electronic
Payment devices offenses
fraud law No No No Same as above No No No Yes
Computer crimes
law No No No Same as above No No No Yes
B. MESO-LEVEL SYSTEMS AND NETWORK CHARACTERISTICS

National payment Work ongoing with Yes Yes Yes MMA operates ATM switch, SCT Yes Yes
system APS automated switch, and
clearinghouse; Payway gateway
National financial Work ongoing with Yes: Bangladesh Yes: Royal National National Yes: LankaClear
BML operates
infrastructure APS common payment Monetary Payments Institutional (Pvt.) Ltd.
the card and
provider (retail switch Authority of Corporation of Facilitation
proprietary
payments) Bhutan EFTCS India Technologies
ATM switch
(Pvt.) Ltd.
1LINK and Mnet

interoperable
ATM switches
ICT agency No No Yes Yes No No No Information and
Communication
Technology Agency
Industry No Unclear: BASIS Unclear: BICTTA NASSCOM No No Possibly: National SLASSCOM
involvement might be involved might be ICT R&D Fund
in financial sector involved in
digitization financial sector
digitization

Digital finance
Credit information Public credit registry Credit information Credit registry Credit registry Public credit Private credit Public credit Yes: credit
bureau and bureau and collateral registry information bureau registry information
Unified collateral No collateral
secured registry bureau and
registry Online platform registry No collateral Secured No collateral
transaction electronic
registry transaction law registry
registry However, not fully No collateral searchable
available; registry
operationalized? registry collateral
not implemented registry (need
amendment to
law)
Regional policy
advocates or
networks Member Member Member Member Member Member Member Member
Regional payment
council (SAARC)
Common national No Yes, being Yes Yes No Yes: three switches No Yes
payment switch enhanced
available?
ATM network Yes: mainly in Kabul Yes Yes Yes Yes Yes Yes Yes
available? city
ATM network No, but encouraged Partially No Yes No No Yes Yes
interoperable?
EFTPOS network Some Yes Yes Yes Yes: BML Yes Yes Yes
available?
MNOs providing Yes Yes Yes Yes Yes Yes Yes Yes
services on behalf
of micro-level
players
189
190

Digital finance
B. MESO-LEVEL SYSTEMS AND NETWORK CHARACTERISTICS (continued)
Nonbank-led Yes: no agent Yes: on behalf of No: just a Yes No Yes, but guidelines Yes Yes
agent networks banking regulations bank-operated network of not clear
available? mobile money agents who are
solutions Bank of Bhutan
agents
Custodian bank or Yes Yes No No Yes No No Yes
trusteeships
available?
C. MICRO-LEVEL MODELS, SYSTEMS, AND SERVICES

Mobile money: Yes, some banks do Yes Yes Yes Yes Yes Yes Yes
bank-led model
available?
Mobile money: Yes No: bank No No: now all Yes: just No No Yes
nonbank-led subsidiary-led have to get launched
model available? comes under bank- payment bank
led model status
MNO-led model Yes No No No Yes No No Yes
available?
Number of 4 9 0 15 2 3 7 2 (3 MNOs
nonbank-led interoperate
mobile money one wallet)
deployments
Interoperability No, but encouraged No No No No: planned Yes: in eSewa, Yes: mobile to Yes
among nonbank- a payment gateway bank
led mobile money
initiatives?

Digital finance
Services provided Cash-in/cash-out, bill Merchant or bill None Airtime top-up Bill/merchant Wallet-to-wallet Merchant Merchant payment
by nonbank-led pay, merchant pay, payment payment transfers payment
Link to other P2P transfer
mobile money remittance, salary
payments, MFI loan Other bulk payment banking P2P transfer Wallet top-up from Airtime top-up (domestic)
initiatives,
products (domestic) a bank account
including OTC disbursement or P2P transfer Loan Airtime top-up
repayment (domestic) Bill payment Airtime top-up Wallet-to-merchant disbursement
Bill payment
and online or repayment
Airtime top-up, link International Other bulk payments Depending on
to other banking remittances payment International
products provider, NFC to
(inward only) Prepaid cards for remittances
P2P transfer bus services,
wallet top-up
Airtime top-up, (domestic) P2P transfer international
G2P, B2P (depending on (domestic) remittance,
service provider) government
Link to other Other bulk pension payments
banking products payment
Bill payment
Mobile
microinsurance
Mobile money No No No No No No No NFC-enabled
applications? remittance app,
Mobile Connect ID
Social grant Banks and financial State-owned Commercial Yes: Aadhaar- BML (state- State-owned Banks, MFIs State banks.
disbursement institutions commercial banks, banks enabled Jan owned commercial banks Samurdhi, and
agency MFIs Dhan Yojana commercial Divineguma banks
Government accounts and bank)
pensions and state bank
national solidarity
program
Method of social Bank accounts, MFIs Bank account, Accounts, cash Cash or bank BML accounts Account or cash Cash or bank Bank accounts
grant BEFTN, MFS, cards account or or cash mobile-phone
disbursements cards? banking or
prepaid cards
191

192

Digital finance
C. MICRO-LEVEL MODELS, SYSTEMS, AND SERVICES (continued)
Digitized social No No No Yes: started No: planned No Yes: NADRA rolled No: project
grant out prepaid flood underway
disbursements relief cards, but
not all disbursed
through this
manner
If digitized, is it No No No Yes No No Yes, for the No
biometric flood-relief cards
enabled?
D. CUSTOMER-LEVEL ID POLICIES OR SYSTEMS

Unique ID? Tazkera (national ID) Several forms of ID Yes Yes: Aadhaar Yes: national Voter registration Computerized Yes: national ID
and National ID and many other National Identity
Population IDs Card
Register
Digital ID? No No No Yes No No Yes Yes: Mobile
Connect in
smartphones
Biometric ID? Yes: electronic: No No Yes No No Yes No
Tazkera began
August 2015
Social grant Yes? Yes? Yes Yes Yes No Yes Yes
recipient
database?
Note: AML/CFT = Anti-Money Laundering and Combatting Funding of Terrorism; APS = Afghanistan Payments Systems; ATM = automated teller machine; BASIS = Bangladesh Association of Software and
Information Services; BEFTN = Bangladesh Electronic Funds Transfer Network; BICTTA = Bhutan Information and Communication Technology Training Association; BML = Bank of Maldives; B2P = business-to-
persons; CBSL = Central Bank of Sri Lanka; EFTCS: Electronic Funds Transfer and Clearing System; EFTPOS = electronic funds transfer at point of sale; G2P = government-to-persons; ICT = information and
communication technology; ID = identification; IT = information technology; MAP = Making Access Possible; MFI = microfinance institution; MFS = Mobile Financial Services; MMA = Maldives Monetary Authority;
MNO = mobile network operator; NADRA = National Database and Registration Authority; NASSCOM = National Association of Software and Services Companies; NFC = near-field communication; NRB = Nepal
Rastra Bank; OTC = over-the-counter; P2P = person-to-person; SAARC = South Asian Association for Regional Cooperation; SCT = SmartChoice Technologies; SLASSCOM = Sri Lanka Association of Software and
Service Companies; UNCDF = United Nations Capital Development Fund.
Note
1. Data from the Global Findex Survey 2014, http://datatopics.worldbank.org
Bibliography
World Bank. 2015. Global Monitoring Report 2014/2015: Ending Poverty and Sharing
Prosperity. Washington, DC: World Bank.

CHAPTER 8
Opportunities, Challenges, and

Future Options in South Asia
Broader adoption of digital payments—with regard to both remittances and other

payments—can significantly advance the global financial inclusion agenda and
support the priority areas of the Global Partnership for Financial Inclusion (GPFI).
Not only are digital payments more efficient than cash payments, but their broader
adoption also can reduce rates of corruption and violent crime, reduce the cost of
government wage and social transfer payments, offer new pathways into the financial
system for the disadvantaged, and, importantly, contribute to the ongoing objective of
women’s economic empowerment.
—Leora Klapper and Dorothe Singer,
“The Opportunities of Digitizing Payments”
Introduction
While the previous chapter’s summary of the digital landscape in South Asia
cannot replace an in-depth diagnostic assessment of how best to digitize the
delivery of financial services in each country, it provides a basis for applying
the lessons and principles that emerged from the analysis provided in Part II.
The case study countries provided insight into how game-changing critical
enablers can enhance the effectiveness of, or help overcome barriers to, digital
financial interventions at the macro, meso, micro, and customer levels. South Asia
region countries can benefit from strong actions by the key stakeholders to give
priority to these critical enablers and provide the vision, direction, regulatory
adaptations, and resources to ensure their effective implementation.
Macro Level
Leadership and National Policies
National-level policy commitment, progressive leadership, and consistency
are important enablers. It is an imperative for governments, policy makers,

196 Opportunities, Challenges, and Future Options in South Asia
and regulators to clearly announce the objectives of policies for financial inclu-
sion and e-money, as well as the specific areas of focus for defined time periods.
Implementation authorities may simply ignore vague or unclear public policy
statements or be stymied by changes in policy when the government changes.
Countries should have a national policy for financial inclusion and a digital
financial agenda (including information and communication technology [ICT]
policy and e-government) to ensure that the strategy is implemented broadly
to reach the unbanked and the underbanked.
Most South Asian countries have yet to develop these strategies. Among the
case study countries, India’s Pradhan Mantri Jan Dhan Yojana financial inclusion
strategy is a clear example of how commitment to a major national strategy can
drive significant efforts to bring poor people into the formal financial system and
use digital mechanisms to reach them in a cost-effective manner.
Enabling Regulatory Environment

South Asian central bankers and regulatory authorities have always been at the
helm of financial sector development, with a fair share of success. However, some
still hold on to old definitions of intermediation and access as bank-only concepts.
With most capital markets in South Asia at nascent stages of development,
authorities’ understandable concern about financial sector stability pushes them
to maintain the status quo. But rapid development of digital payments and other
e-platforms have demonstrated that the approach to financial innovation and
regulation needs to be recast if persistent poverty and financial exclusion are to
be addressed more effectively.
Regulators in India and Sri Lanka (like those in Kenya) have started the process
of establishing a more conducive and nonprohibitive policy, legal, and regulatory
environment. The Central Bank of Sri Lanka proactively established the legal
framework for nonbank institutions to enter the payment space long before the
need arose, including legislation regarding payments, consumer protection,
Anti-Money Laundering and Combatting Funding of Terrorism (AML/CFT),
and electronic funds transfer.
By letting nonbanks into the payment space, the regulator establishes a level
playing field in which competition fosters innovations that enhance the cus-
tomer’s value proposition. At the same time, the regulator can address various
market developments and innovations in a more holistic manner. Sri Lanka has
successfully maintained the delicate balance between establishing a level playing
field among operators that encourages innovation while providing adequate
risk-based oversight and supervision.
Nevertheless, South Asian countries should take precautions against the risk
of cyberthreats when using digital finance for financial inclusion. Although the
damage in terms of value may be small, cybercrimes can wipe out people’s sav-
ings and exacerbate the already limited confidence of poorer and more vulnera-
ble groups in the formal financial system. Hence the regulator’s role is critical to
ensure that nonbanks as well as banks abide by prudential regulations and secu-
rity guidelines.

Opportunities, Challenges, and Future Options in South Asia 197
Meso Level
Financial Infrastructure Development
The widely dispersed poor population in many South Asian countries is a key
challenge for establishing the infrastructure needed to expand financial inclusion.
Connectivity, national switches, interoperability, and agent network management
are critical components of digital finance models. Coordination among macro-level
policy makers and regulators, meso-level institutions, and micro-level service
providers is key.
National retail payment providers, ICT agencies, and credit information bureaus
are some examples of meso institutions that can enable infrastructure
development—yet these remain largely undeveloped in most South Asian countries.
Since all eight South Asian countries are members of the South Asian Association
for Regional Cooperation (SAARC) Payments Council, it should incorporate digi-
tal finance as a priority agenda for financial inclusion at the regional level.
Meso-level enablers are evident in several of the case study countries.
In Thailand, the proactive Thai Bankers’ Association helps drive the policy that
provides for the spread of ubiquitous automated teller machines (ATMs) through-
out the country. Sri Lanka’s ICTA (ICT agency) drives the e-government program,
and LankaClear (retail infrastructure provider) promotes the corporate theme of
“A World beyond Cash” in moving toward a fully interoperable common payment
switch. The forward-thinking National Payments Corporation of India (NPCI)
facilitates strategic implementation of its dynamic inclusion policy.
Agent Network Management

The case that mobile network operators (MNOs) are best placed to offer
mobile money is based on fast-growing mobile penetration among the poor
and the unbanked population and their last mile coverage through ubiquitous
agent networks that can act as mobile money touchpoints. Managing the agent
network is a critical enabler for rapid mobile money deployment, through
training in handling the customers, implementing know-your-customer (KYC)
and customer due diligence (CDD) requirements, and addressing suspicious
transactions.
Poor or unbanked people identify themselves more readily with local MNO
agents than with formal bank outlets. South Asian countries have yet to
develop such agent networks as effectively as in Kenya, where they facilitated
the phenomenal growth of M-Pesa, which has now become the country’s
national payments system and platform for many innovations that promote
financial inclusion even among the poor in remote areas.
Micro Level
MNO-Led Mobile Money Model
Despite its clear advantages in terms of proximity and services to the targeted poor
and unbanked population in hard-to-reach rural areas and islands, the MNO-led

198 Opportunities, Challenges, and Future Options in South Asia
model is still not popular in the South Asia region. Only Afghanistan and Sri Lanka
operate full-fledged MNO-led mobile money solutions. Maldives has launched
its own MNO-led mobile money solution. And Bangladesh has bKash, which is
owned by BRAC Bank.
A recent Groupe Speciale Mobile Association (GSMA) article (di Castri
2013) concludes that regulators in a number of countries (including Colombia,
Ghana, Guatemala, India, Nigeria, and South Africa) have been reluctant to
grant MNOs mobile money licenses because they are (a) afraid that the MNOs
could scale up very quickly and dominate the formal financial sector; (b) con-
cerned that regulators would be unable to control such growth and use it to
deepen access to finance; and (c) nervous about the ability of MNOs to safeguard
customers’ money as effectively as banks. But in many other markets, the regula-
tor has been able to design prudential regulations and market conduct frame-
works that help to make nonbank e-money providers sound and effective.
Interoperability
Interoperability is another important enabler for MNOs to enhance their out-
reach and efficiency. However, not many countries in South Asia (or elsewhere)
have MNOs that interoperate. The best example is Sri Lanka, which launched
the world’s first end-to-end interoperable mobile money solution: three MNOs
operate a single wallet sharing merchants and agents, with firewalls built in so
they cannot access others’ subscriber information. Indonesia represents another
interoperability concept, with four MNOs interoperating but retaining four indi-
vidual wallets. Through such mechanisms, customers stand to benefit from lower
cost as well as a larger number of touchpoints.
Mobile Applications
While there are around 265 live mobile money deployments in the world—with
another 102 planned1—only M-Pesa has served as a basis for the development of
significant value-added services by app developers who enjoy the benefits of
low-cost, extensive outreach and convenience to customers. In Sri Lanka, the
MNOs are taking small steps in the right direction by enabling government pen-
sion disbursements, tax payments, and international remittances. In some cities,
near-field communications (NFC)–enabled, contactless smart cards can be topped
up and used to pay the bus fare.
Card-Based Grant Disbursement Systems

Digitizing payment of government grants, salary payments, and all
government-to-persons (G2P) operations (including pensions) is one of the
most effective ways of getting poor people into the financial space. Digitizing
these payments can address corruption, ghost accounts, leakages, and political
intervention, as well as enhancing financial discipline in the delivery of gov-
ernment payments.
Brazil and Mexico have digitized government payments, while South Africa
has started the process with a biometric-enabled unique identification (ID) system.

Opportunities, Challenges, and Future Options in South Asia 199
However, with the exception of India’s Aadhaar-enabled government benefit

transfer program, all other South Asian countries use cash, commercial or state
banks, and microfinance institutions for grant disbursement. Digitizing these pay-
ments would significantly enhance efficiency and reduce leakages, as well as
enhance financial inclusion of the beneficiaries.
Customer Level
Unique Identification
A unique ID is a key element in digital finance. It enables basic KYC subscriber
identification module (SIM) registration and avoids paper-based, tardy AML/CFT
and KYC and CDD processes that tend to exclude and discourage the unbanked
poor. The plethora of documents required at the time of opening mobile or
e-money accounts has put off the poor and pushed them to over-the-counter
(OTC) transactions to avoid paper-based procedures. Bangladesh’s bKash system
and Pakistan’s Telenor systems are experiencing OTC-related issues.
In the South Asia region, except for Bangladesh and Nepal, other countries
have unique ID. Pakistan has the National Database and Registration Authority
(NADRA)-issued Computerized National Identity Card (CNIC), and Afghanistan
is planning to roll out the electronic Tazkera. India has Aadhaar ID, which is
biometric-enabled and linked to bank accounts. In addition, Sri Lanka mobile
subscribers have a Digital Connect online ID that can be used for authentication
for online purchases.
Note
1. Data from GSMA’s Mobile Money Tracker: http://www.gsma.com/mobilefordevelop
ment/programmes/mobile-money-for-the-unbanked/insights/tracker.
Bibliography
di Castri, S. 2013. “What Could We Learn from Nigeria Barring MNOs from Participating
in the Mobile Money Market?” Groupe Speciale Mobile Association blog, April 29.
http://www.gsma.com/mobilefordevelopment/programme/mobile-money/what
-could-we-learn-from-nigeria-barring-mnos-from-participating-in-the-mobile-money
-market.
Klapper, L., and D. Singer. 2014. “The Opportunities of Digitizing Payments: How
Digitization of Payments, Transfers, and Remittances Contributes to the G20 Goals of
Broad-Based Economic Growth, Financial Inclusion, and Women’s Economic
Empowerment.” Report No. 90305, prepared for the G20 Australian Presidency,
World Bank, Washington, DC.

CHAPTER 9
Conclusions
Introduction
In the developing world as a whole, lack of money is the most commonly
reported reason for being unbanked. Other reasons for not having access to
formal financial services (through a bank, credit union, savings and credit coop-
erative, post office, or microfinance institution) include lack of proximity and the
costs associated with maintaining an account. The wide accessibility of mobile-
phone and digital technologies offers the potential to reduce disparities by gen-
der and area (urban or rural).
Technology-based solutions offer a tremendous opportunity to transform
the landscape of access to financial services for typically underserved groups,
such as the poor, women, and remote populations. Digital or e-money can be
enabled by mobile phones, branchless banking, point-of-sale (POS) transactions,
prepaid or smart cards, and well-organized agent networks. These decentral-
ized modalities have the capacity to reach the unbanked masses in a safe,
simple, reliable, convenient, and cost-effective manner, enabling them to
manage small transactions, including personal and government payments as
well as remittance transfers.
Greater financial inclusion means higher potential for the poor to participate
and share in their country’s economic growth. Although the services avail-
able through e-money at present do not represent the full range of services avail-
able through financial institutions, they nevertheless enable those at the bottom
of the pyramid to formally conduct certain basic financial transactions, and they
can increasingly be linked to bank accounts and other means of accessing a more
complete range of financial services.
This study has highlighted Kenya, South Africa, Sri Lanka, and Thailand as
countries where the private sector and nonbank entities have applied technology
and innovative thinking to successfully address inclusion issues, supported by
flexibly designed policies and regulations.
Kenya more than doubled the rate of financial inclusion in five years to reach
nearly 70 percent of the adult population as a direct result of innovations

202 Conclusions
associated with the M-Pesa mobile money application, which has evolved
into the country’s dominant retail payment platform. M-Pesa has especially ben-
efited the poor and unbanked, who previously had limited and costly access to
traditional bank and financial infrastructure.
South Africa has issued some 10 million biometrically secure debit MasterCards
as the platform for social transfer payments, thereby extending financial access to
16 million poor beneficiaries, with the country’s banked and financially included
population reaching 75 percent and 86 percent, respectively.
Sri Lanka’s government and central bank proactively developed the country’s
legislative framework to support establishment of an excellent payment systems
infrastructure, and possibly the best regulatory framework in the region to govern
e-money for e-commerce and e-government. The result is the world’s first
end-to-end interoperable mobile payment solution, reaching over 83 percent of
the population.
Thailand’s efficient coordination of strategies and policies toward payment
services and reduction of infrastructure costs—partly through the deployment of
thousands of multicapacity automated teller machines (ATMs) and automated
deposit machines (ADMs) throughout the country—has led to nearly 100 percent
financial inclusion.
These findings, complemented by experiences from several other countries
that are laying the foundations, reveal how e-money and other digital technologies
can transform the financial inclusion landscape for the poor and underserved.
This chapter summarizes the key lessons from the case study experiences that
can be applied broadly to expand financial inclusion throughout the developing
world.
Role of Governments and Regulators

While governments in principle have an interest in promoting financial inclusion
as one instrument of poverty reduction and growth, their ability to take the
lead may be constrained by lack of hard information on the results of new
interventions, and their views may be influenced by powerful vested interests.
Technologies that enable financial transactions to be conducted over mobile
phones, POS, and other digital devices are disruptive to traditional financial
systems because they bring in mobile network operators (MNOs) and other
agents who are not licensed or regulated by the central bank authorities. Since
the principal task of financial regulators is to minimize risks to the security and
stability of the financial system, they are often understandably reluctant to
introduce innovative technologies that might heighten such risks. Thus, the
starting point is to document the roles that governments and regulators have
played in promoting and facilitating the introduction and scaling-up of innova-
tive digital technologies for expanding access to financial transactions, as well
as cases in which lack of needed action has stalled development.
Three key roles for governments and regulators are to set the legal and
regulatory ground rules; establish a unique national identification (ID) system;

Conclusions 203
and incentivize or mobilize participation in digital payments, especially by using

social welfare grant programs to drive demand and use.
A Conducive Legal and Regulatory Environment

Kenya’s M-Pesa mobile money application would not have occurred had the
Central Bank of Kenya (CBK) not been willing to give a no-objection letter to an
experimental (and at the time, unproven) mobile money scheme in the interests
of financial inclusion—despite some resistance from commercial banks and
politicians. CBK then drew on experience with the scheme to eventually develop
an appropriate legal and regulatory framework, which facilitated the entry of
other nonbank players and their agents.
In Sri Lanka, the government and the Central Bank of Sri Lanka (CBSL)
adopted a different but also proactive approach by early on enacting laws and
regulations that created a level playing field, where both banks and nonbanks
(including MNOs) could offer digital money. CBSL established distinct guide-
lines for an MNO-led model, as well as a bank-led model, opening up the field
to a broader and growing range of providers with different value propositions.
Leveling the playing field has the advantage of enabling private sector players
such as MNOs to offer competitive products and services efficiently and at a
lower cost. This policy approach has facilitated the launch of the world’s first
end-to-end interoperable mobile payment solution.
The Philippines Ministry of Finance and Central Bank used a “test-learn-regulate”
model—although success has been constrained by overly restrictive know-your-
customer (KYC) registration requirements and lack of clarity on the regulatory
mandate regarding e-money, as well as the absence of a unique ID system.
The Bank of Thailand likewise is seeking an appropriate balance between extend-
ing outreach, managing risks to the system, and protecting consumers. It has
agreed to extend its supervisory and regulatory mandate to specialized financial
institutions that offer extensive coverage in rural and poor communities that lack
a commercial bank branch.
The conclusion is that the government and central bank must at least play a
supporting role in establishing conducive conditions—and sometimes can play a
lead, game-changing role—but that different approaches may be appropriate
in different situations. A flexible approach to innovation can allow experimenta-
tion with new technology, leading to well-adapted laws and regulations based on
experience. On the other hand, establishing clear rules that level the playing field
for both financial institutions and MNOs to apply digital technologies can foster
both competition and cooperation among private players to achieve the best
value proposition for both providers and consumers.
A Unique National ID System

India’s unique ID program has enabled direct benefit transfer programs to be
implemented through bank accounts. While not specifically linked to mobile
technologies, this opens up the space for both MNOs and financial institutions
to offer low-cost products to a huge, previously underserved market. In contrast,

204 Conclusions
the Philippines’ implementation difficulties were exacerbated by the lack of a

national ID.
Incentivizing and Mobilizing Widespread Participation

India’s Jan Dhan Yojana (JDY) program demonstrates the transformative power
of a highly publicized campaign plus incentives for people to open up bank
accounts. This built on the unique ID system, which was critical to overcoming
KYC challenges. Although the potential of the scheme is yet to be fully realized,
it has opened up a huge opportunity for India’s low-income population to be at
least nominally “banked,” making this market attractive for private providers of
both financial and telecommunications services.
The government of Thailand has taken advantage of widespread, publicly sup-
ported specialized financial institutions such as agricultural cooperatives and the
Village Fund to extend microcredit to the underserved population, especially in
rural areas.
The lesson is that, with sufficient political will, governments can undertake
direct actions that help transform the financial inclusion landscape. These include
a unique ID system; incentives and promotional efforts to get people to sign up
for bank, e-money, or other accounts that give them access to financial products;
and expanding the network of touchpoints accessible to the rural poor.
Digitizing Social Grant Programs: A Game Changer

Brazil’s Bolsa Família program built on a merger of four cash grant schemes
to become the world’s largest conditional cash transfer program, reaching
about 30 percent of the population. A single national registry system, man-
aged by a state bank, regularly reviews eligibility, substituting for a unique ID.
About 15 percent of beneficiaries obtain their grants through bank accounts
that can be opened under simplified conditions and offer more flexibility
than the “Social Cards.”
South Africa’s seven social security grant programs reach some 31 percent
of the population. The South African Social Security Agency brought together
a technology company, a bank, and MasterCard to develop a streamlined dis-
bursement and authentication methodology using biometric chip technology
embedded on a card that can operate offline as well as online, making it suit-
able for use in battery-operated smart card readers in rural areas. The card is
“open” and also allows its users to do other financial transactions using ATMs
and POS technology in retail outlets—thereby directly enhancing the financial
access of its 16 million users beyond just receiving grants. The system also
yielded significant efficiency gains and savings by eliminating duplicate and
ghost beneficiaries. The security of biometric and password protection is cited
by beneficiaries as a tremendous benefit that prevents theft and fraud.
Similar efforts in Mexico to deliver benefits through a “closed” debit card
proved less successful in terms of increasing financial access because of the
failure to authorize a large enough number of agencies for cash withdrawal to
make it sufficiently convenient to the beneficiaries. Unlike in South Africa,

Conclusions 205
the “closed-loop” Oportunidades card can only be used to receive a cash-out of

the social grant benefit from a Bansefi Bank officer on a specified day and hour.
Because the bank accounts established in massive numbers under India’s JDY
program are linked to the unique Aadhaar ID, they now offer an efficient vehicle
for various state and national welfare schemes to deliver subsidies directly and
quickly to the authenticated beneficiaries. In addition, the program presents an
important potential market for the services of private mobile money and finan-
cial service providers.
The conclusion is that expansion of “e-government” to reach the bottom of
the pyramid by utilizing digital technologies such as mobile apps, prepaid cards,
and direct transfers into bank accounts can be a particularly effective way to
incentivize adoption of these digital means. Besides cost-effectively extending
financial inclusion, these technologies can also dramatically increase the admin-
istrative efficiency of identifying and targeting those eligible to receive social
grants, thereby reducing leakages during the disbursement process.
Coordinated Action, Common Platforms, and Interoperability

Although laws and regulations are part of the macro environment, they are
implemented by agencies that can be considered as meso-level institutions.
Part of Sri Lanka’s success is attributable to close collaboration between
CBSL and the Telecommunications Regulatory Commission of Sri Lanka.
By coordinating proactively and converging the service delivery and customer
protection paradigms of the telecommunications and banking sectors, the two
regulatory authorities developed a comprehensive yet flexible mobile money
regulatory and oversight framework. The National Payments Corporation of
India has facilitated greater adoption of mobile banking by establishing a
National Unified unstructured supplementary service data (USSD) Platform
that allows every customer to access banking services with a single number
across all banks—irrespective of the telecom service provider, mobile handset
make, or the region.
Although interoperability is not a required precondition—Kenya’s M-Pesa
succeeded without it, as a closed-loop proprietary system—it can facilitate
greater competition as a spur to outreach and price reduction. Indeed, Kenya
recently introduced regulations requiring interoperability with other pay-
ment systems, both national and international, leveling the playing field for
other providers. In Thailand, interoperability has been successfully achieved
through the National Interbank Transaction Management and Exchange
Company, which supports all types of electronic payments and funds transfer
from various channels including ATMs, counters, Internet, phone, and mobile
channels, utilizing a secure and very efficient open platform. This develop-
ment was strongly supported by the Thai Bankers’ Association, which has
proven to be a valuable meso-level organization that partners with the Bank
of Thailand to further financial inclusion. Pakistan likewise has taken a step
toward interoperability by linking its Easypaisa mobile money service with

206 Conclusions
the existing banking structure, enabling customers to transfer funds between

a number of banks.
In conclusion, how regulations are implemented proves to be more important
in facilitating or retarding development than how well they are drafted. E-money
is unique in that it overlaps different regulatory domains, thus running the risk
of a mismatch of regulations and how they are interpreted by different agencies.
Hence it is essential to establish coordination mechanisms for the regulatory
agencies governing both the financial and the telecommunications sectors.
Also, establishing a payments platform that is common to all banks instead of
each bank having to develop its own platform helps banks to focus on customers.
Furthermore, measures to promote interoperability are potential game changers
to hasten the spread of efficient, affordable mobile-phone and financial services
to the previously underserved masses.
Outreach by Retail Institutions

In Sri Lanka, the MNOs responded positively and cooperatively to the
favorable environment that had been established by the central bank, which
enabled the MNO-led mobile money system to work with complete neutral-
ity across MNO mobile money providers. In an unprecedented move, the
leading MNO, Dialog Axiata, invited the other MNOs to share its eZ Cash
platform and set up a system for separate mobile wallets to be managed and
interoperated on a common platform. The result is the first mobile money
system in the world to be end-to-end interoperable across multiple service
providers. The trustee bank arrangement protects consumer funds by
ring-fencing the trust account and holding it in receivership in case both the
MNO and the custodian bank fail.
In Indonesia, too, the three large MNOs decided to work together and pool
resources rather than try to compete with each other to cover the geographically
challenging terrain. Customers of the three MNOs can transfer and cash out
money from any location across each other’s network. In this case, however, they
decided to keep their own identities by way of a multi-wallet interoperable
arrangement.
The success of M-Pesa was due in large part to Safaricom already having an
extensive network of agents selling airtime and their effective management of
the recruitment and training of agents needed to support rapid scaling-up. A dif-
ferent approach was taken by the government of India, which decided to set up
special payment banks and small finance banks in unbanked and underbanked
regions. It remains to be seen whether this approach can be sufficiently
cost-effective to compete with other payment mechanisms and thereby draw
more of the population into these banks.
A key conclusion is that increasing accessibility of mobile money and finan-
cial services depends on the efforts of the retail institutions—banks and other
financial institutions as well as MNOs—to develop and deliver affordable services
that meet the needs of the previously unserved or underserved population.

Conclusions 207
Experience shows that private providers can work cooperatively to make com-
mon elements of the system work cost-effectively while competing for custom-
ers on the retail end, when the infrastructure and incentives have been
established to level the playing field and provide neutrality across providers.
Hence it is incumbent on governments and central banks to lay the regulatory
and infrastructural foundation for private actors to do so profitably and to
facilitate market forces to drive the players toward the desired results.
Agents represent a further key element in utilizing e-money to extend the
outreach of financial services, given that the number of mobile money agents is
typically 4 to 10 times the number of bank branches. However, managing agent
networks requires a delicate balance between ensuring the profitability of each
agent and providing enough touchpoints that consumers can be served quickly
and efficiently.
Increasing Accessibility for Customers

Thailand’s use of retail stores has been a major factor in the rapid expansion
of mobile money by bringing services close to the customer. For example, at
every 7-Eleven store, which are widely distributed throughout remote rural
areas as well as in the city, one can send and retrieve money, pay utility bills,
purchase an airline ticket, or make a bank deposit. Kenya has had some suc-
cess with adapting the mobile-phone platform to facilitate microfinance
programs and various forms of insurance (life, accident, health, and crop),
as well as pensions for informal workers. Mobile POS devices offer the
potential to greatly expand access to financial services through branchless
banking.
On the other hand, countries that have rigidly applied KYC and customer due
diligence (CDD) requirements at the bottom of the pyramid have tended to have
disappointing rates of enrollment. More successful have been countries such as
Sri Lanka that have adopted a tiered approach, with much lighter requirements for
accounts with restricted uses and low-value transactions. Sri Lanka has also dealt
with concerns about the security of information by establishing the world’s first
multioperator Mobile Connect solution that provides an independent means for
authenticating a user to any service provider without requiring a password.
An important conclusion from the customer point of view is that the direct
cost of transactions is only one among several determinants of the value proposi-
tion of a mobile money or financial service. Proximity and convenience are often
overriding concerns. Simplicity and ease of registration are also important.
Although not yet a major concern to the low-end consumers, the security and
possible misuse of the information provided represents an important risk to
systems targeting millions of new customers—a risk that needs to be addressed
in moving toward a cash-lite economic ecosystem. Overall, the linkage of mobile
technologies with financial services offers many opportunities to improve the
customer experience and provide more (or more efficient) services through new
applications.

208 Conclusions
The Journey toward a Cash-Lite Society: Coordination and Balance

Two key steps toward a cash-lite, financially inclusive system are digitizing the
payments and digitizing the money. The implied strategic question is whether to
begin by democratizing bank accounts through massive enrollment, or by making
e-money readily accessible over mobile-phone technology. In the countries stud-
ied, both bank-led and MNO-led models have been effective; either can create
conditions that facilitate expansion of the other. Whether the potential is then
realized depends heavily on other conditions, such as the existence of a unique
national ID and the regulations governing who can do what and how banks and
MNOs can link up (or compete).
Although governments and regulators clearly play a key role in the successful
expansion of financial inclusion by leveraging digital technologies, again, no single
strategic approach emerges: much depends on country circumstances. In Kenya,
regulatory flexibility to permit experimentation with mobile-phone technology
was the leading edge. In India, government incentives and the campaign for
opening bank accounts is the leading game changer, with establishment of a
unique national ID system as a fundamental precondition.
No matter how conducive the framework, the success of efforts to promote
financial inclusion ultimately depends on the readiness of the previously
unserved or underserved population to participate. Experiences in the countries
studied show that cost and convenience are the most critical factors. The key
challenge that digital technologies are helping to address is to make small transac-
tions feasible at prices that are both affordable to the users and profitable to the
suppliers. The equally critical factor of proximity to the client is being success-
fully addressed in some countries through low-cost options for the banking
system to reach out, such as agent banking and POS devices, and in others by
making financial “wallets” available through mobile phones, which already have
high penetration. Other factors affecting the value proposition to consumers
include the increased safety of going cashless, security of information, simplic-
ity (including formats readily accessible to the nonliterate population), and
reliability.
Where to begin or to target interventions depends very much on the country
context and the existing state of laws and regulations governing mobile money
and banking, the extent of penetration of bank accounts and mobile telephony,
the existence of national ID, and cultural and other factors. It also depends on
which technologies and innovations may be available at any given time to address
the needs of the targeted population and the challenges facing implementation.
So, each country that wishes to use the potential of e-money technologies to
advance financial inclusion will need to undertake an assessment of its current
policy, legal and regulatory framework, institutional environment, characteristics
of targeted consumer groups, and the state of technology in the country relative
to what is available internationally.
To move forward effectively, each country must also establish effective coor-
dination and consultation mechanisms among the key players at all levels: macro

Conclusions 209
(government policy makers, central banks, and other regulators); meso- and
micro-level institutions (financial institutions and MNOs, and their associations
and facilitating organizations); and consumers (through advocacy agencies and
survey data). Key objectives for such coordination are to balance the interests of
the different actors, ensure that the playing field is level, and, above all, strike the
right balance among expanding outreach, mitigating risks to the stability and
security of the system, and protecting the consumers.
The lessons provided in this study are intended to help flatten the learning
curve for taking advantage of e-money and other innovations to extend access
to financial services, especially for South Asian and other developing countries.
By establishing a conducive legal and regulatory framework and providing
appropriate incentives to both private providers and customers, countries can
accelerate financial inclusion to promote a more inclusive society and shared
prosperity.

APPENDIX A
Findex Data for Selected Countries
Table A.1 India against Benchmarks for South Asia and Lower-Middle-Income Countries
Percentage
South Lower-middle- World
Survey item India Asia income average
All adults 53.1 46.4 42.7 61.5
Women 43.1 37.4 36.3 58.1
Adults belonging to the poorest 40% 43.9 38.1 33.2 54.0
Young adults (ages 15–24 years) 43.2 36.7 34.7 46.3
Adults living in rural areas 50.1 43.5 40.0 56.7

All adults, 2014 52.8 45.5 41.8 60.7
All adults, 2011 35.2 32.3 28.7 50.6

All adults 2.4 2.6 2.5 2.0
Access to financial institution account (ages 15+ years)

Has debit card, 2014 22.1 18.0 21.2 40.1
Has debit card, 2011 8.4 7.2 10.1 30.5
ATM is the main mode of withdrawal (% with an account), 2014 33.1 31.1 42.4 —
ATM is the main mode of withdrawal (% with an account), 2011 18.4 16.9 28.1 48.3
Use of account in the past year (ages 15+ years)

Used an account to receive wages 4.0 3.5 5.6 17.7
Used an account to receive government transfers 3.6 3.1 3.3 8.2
Used a financial institution account to pay utility bills 3.4 2.7 3.1 16.7
Other digital payment in the past year (ages 15+ years)

Used a debit card to make payments 10.7 8.5 9.6 23.2
Used a credit card to make payments 3.4 2.6 2.8 15.1
Used the Internet to pay bills or make purchases 1.2 1.2 2.6 16.6

212 Findex Data for Selected Countries
Table A.1 India against Benchmarks for South Asia and Lower-Middle-Income Countries (continued)
Percentage

South Lower-middle- World
Survey item India Asia income average
Domestic remittances in the past year (ages 15+ years)
Sent remittances 9.9 10.7 14.2 —
Sent remittances via a financial institution (% senders) — 20.1 30.9 —
Sent remittances via a mobile phone (% senders) — 7.7 7.7 —
Sent remittances via a money transfer operator (% senders) — 13.7 18.3 —
Received remittances 9.8 12.2 17.8 —
Received remittances via a financial institution (% recipients) — 15.8 26.0 —
Received remittances via a mobile phone (% recipients) — 4.7 5.7 —
Received remittances via a money transfer operator (% recipients) — 9.8 16.6
Savings in the past year (ages 15+ years)

Saved at a financial institution, 2014 14.4 12.7 14.8 27.4
Saved using a savings club or person outside the family 8.8 8.8 12.4 —
Saved any money 38.3 36.2 45.6 56.5
Saved for old age 9.9 9.1 12.6 23.9
Saved for a farm or business 7.0 7.3 11.8 13.8
Saved for education or school fees 16.0 14.6 20.0 22.3
Credit in the past year (ages 15+ years)
Borrowed from a financial institution, 2014 6.4 6.4 7.5 10.7
Borrowed from family or friends 32.3 31.4 33.1 26.2
Borrowed from a private informal lender 12.6 10.9 8.5 4.6
Borrowed any money 46.3 46.7 47.4 42.4
Borrowed for a farm or business 9.0 8.6 9.2 7.1
Borrowed for education or school fees 9.7 8.9 10.1 7.7
Outstanding mortgage at a financial institution 3.7 3.8 4.7 10.4
Source: Global Findex 2014 Survey, http://datatopics.worldbank.org/financialinclusion/.
Note: ATM = automated teller machine; GNI = gross national income; — = not available.
Table A.2 Indonesia against Benchmarks for East Asia and Pacific and Lower-Middle-Income Countries
Percentage

East Asia Lower-middle- World
Survey item Indonesia and Pacific income average
All adults 36.1 69.0 42.7 61.5
Women 37.5 67.0 36.3 58.1

Findex Data for Selected Countries 213
Table A.2 Indonesia against Benchmarks for East Asia and Pacific and Lower-Middle-Income Countries (continued)
Percentage
East Asia Lower-middle- World
Survey item Indonesia and Pacific income average
All adults, 2014 35.9 68.8 41.8 60.7
All adults, 2011 19.6 55.1 28.7 50.6
All adults 0.4 0.4 2.5 2.0
Has debit card, 2014 25.9 42.9 21.2 40.1
Has debit card, 2011 10.5 34.7 10.1 30.5
Sent remittances via a financial institution (% senders) 52.4 36.9 30.9 —
Sent remittances via a mobile phone (% senders) 3.6 8.7 7.7 —
Sent remittances via a money transfer operator (% senders) 8.7 18.5 18.3 —
Received remittances via a financial institution (% recipients) 36.3 29.0 26.0 —
Received remittances via a mobile phone (% recipients) 0.2 4.9 5.7 —
Received remittances via a money transfer operator (% recipients) 7.9 15.8 16.6 —
Saved any money 69.3 71.0 45.6 56.5
Saved for old age 27.1 36.5 12.6 23.9

Table A.3 Kenya against Benchmarks for Sub-Saharan Africa and Low-Income Countries
Percentage
Sub-Saharan World
Survey item Kenya Africa Low-income average
All adults 74.7 34.2 27.5 61.5
Women 71.1 29.9 23.9 58.1

All adults, 2014 55.2 28.9 22.3 60.7
All adults, 2011 42.3 23.9 21.1 50.6

All adults 58.4 11.5 10.0 2.0

Has debit card, 2014 34.7 17.9 6.6 40.1
Has debit card, 2011 29.9 15.0 6.3 30.5




Saved any money 76.1 59.6 46.5 56.5
Saved for old age 17.9 9.8 8.3 23.9

Table A.3 Kenya against Benchmarks for Sub-Saharan Africa and Low-Income Countries (continued)
Percentage
Sub-Saharan World
Survey item Kenya Africa Low-income average
Table A.4 The Philippines against Benchmarks for East Asia and Pacific and Lower-Middle-Income Countries
Percentage
Lower-
East Asia middle- World
Survey item Philippines and Pacific income average
All adults 31.3 69.0 42.7 61.5
Women 37.9 67.0 36.3 58.1
All adults, 2014 28.1 68.8 41.8 60.7
All adults, 2011 26.6 55.1 28.7 50.6
All adults 4.2 0.4 2.5 2.0
Has debit card, 2014 20.5 42.9 21.2 40.1
Has debit card, 2011 13.2 34.7 10.1 30.5

Table A.4 The Philippines against Benchmarks for East Asia and Pacific and Lower-Middle-Income Countries (continued)
Percentage
Lower-
Survey item Philippines and Pacific income average

Saved any money 67.3 71.0 45.6 56.5
Saved for old age 24.5 36.5 12.6 23.9

Table A.5 South Africa against Benchmarks for Sub-Saharan Africa and Upper-Middle-Income Countries
Percentage
Sub- Upper-
South Saharan middle- World
Survey item Africa Africa income average
All adults 70.3 34.2 70.5 61.5
Women 70.4 29.9 67.3 58.1

Table A.5 South Africa against Benchmarks for Sub-Saharan Africa and Upper-Middle-Income Countries (continued)
Percentage

Sub- Upper-
South Saharan middle- World
Survey item Africa Africa income average

All adults, 2014 68.8 28.9 70.4 60.7
All adults, 2011 53.6 23.9 57.4 50.6
Mobile account (age 15+ years)
All adults 14.4 11.5 0.7 2.0
Has debit card, 2014 54.9 17.9 45.9 40.1
Has debit card, 2011 45.3 15.0 38.5 30.5
Saved any money 66.4 59.6 62.7 56.5
Saved for old age 15.9 9.8 30.6 23.9

Table A.6 Sri Lanka against Benchmarks for South Asia and Lower-Middle-Income Countries
Percentage
Lower-
middle- World
Survey item Sri Lanka South Asia income average
All adults 82.7 46.4 42.7 61.5
Women 83.1 37.4 36.3 58.1

All adults, 2014 82.7 45.5 41.8 60.7
All adults, 2011 68.5 32.3 28.7 50.6
All adults 0.1 2.6 2.5 2.0
Has debit card, 2014 24.9 18.0 21.2 40.1
Has debit card, 2011 10.0 7.2 10.1 30.5
Saved any money 45.2 36.2 45.6 56.5
Saved for old age 13.8 9.1 12.6 23.9

Table A.6 Sri Lanka against Benchmarks for South Asia and Lower-Middle-Income Countries (continued)
Percentage
Lower-
middle- World
Survey item Sri Lanka South Asia income average
Table A.7 Thailand against Benchmarks for East Asia and Pacific and Upper-Middle-Income Countries
Percentage
Upper-
Survey item Thailand and Pacific income average
All adults 78.1 69.0 70.5 61.5
Women 75.4 67.0 67.3 58.1

All adults, 2014 78.1 68.8 70.4 60.7
All adults, 2011 72.7 55.1 57.4 50.6

All adults 1.3 0.4 0.7 2.0

Has debit card, 2014 54.8 42.9 45.9 40.1
Has debit card, 2011 43.1 34.7 38.5 30.5


Table A.7 Thailand against Benchmarks for East Asia and Pacific and Upper-Middle-Income Countries (continued)
Percentage
Upper-
Survey item Thailand and Pacific income average


Saved any money 80.5 71.0 62.7 56.5
Saved for old age 59.2 36.5 30.6 23.9

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Moving toward universal access to financial services is within reach, thanks to new technologies, transformative
business models, and ambitious reforms. Instruments such as e-money accounts and mobile accounts, along
with debit cards and low-cost traditional bank accounts, can significantly increase financial access for those
who are excluded.
Bringing E-money to the Poor: Successes and Failures examines the lessons of success from four country case
studies of “gazelles”—Kenya, South Africa, Sri Lanka, and Thailand—that leapt from limitation to innovation by
successfully enabling the deployment of e-money technology. These countries have thereby transformed the
landscape of financial access to their poor. In addition, two country case studies (Maldives and the Philippines)
yield lessons learned from constraints that stalled e-money deployments. Because technology is not a silver
bullet, the case studies also explore other strategic elements that need to be in place for a country to expand
access to financial services through digital technology.
ISBN 978-1-4648-0462-5
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DIREC TIONS IN DE VELOPMENT

Bringing E-money to the Poor

Thyra A. Riley and Anoma Kulathunga

Bringing E-money to the Poor

Thyra A. Riley and Anoma Kulathunga

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ISBN (paper): 978-1-4648-0462-5

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Bringing E-money to the Poor • http://dx.doi.org/10.1596/978-1-4648-0462-5

PART I Journey toward a Cash-Lite Society and

Chapter 1 The Challenge of Financial Inclusion 17

Chapter 2 Digitizing Financial Inclusion through Innovations 37

Bringing E-money to the Poor • http://dx.doi.org/10.1596/978-1-4648-0462-5 v

Risks in Digital Finance 46

Chapter 3 Stakeholders in Digital Financial Inclusion 53

PART II Critical Enablers That Are Game Changers in

Chapter 4 Policy Leadership and Enabling Regulatory

Chapter 5 Innovative Uses of Infrastructure and Digital Ecosystems 105

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Chapter 6 Unique Identification 155

PART III South Asia Digital Landscape, Future

Chapter 7 Digital Landscape in South Asia 179

Chapter 8 Opportunities, Challenges, and Future Options

Chapter 9 Conclusions 201

Appendix A Findex Data for Selected Countries 211

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Bringing E-money to the Poor • http://dx.doi.org/10.1596/978-1-4648-0462-5

5.7 Number of Financial Access Points across Developing

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4.2 Financial Service Providers in Thailand, by Customer and

Bringing E-money to the Poor • http://dx.doi.org/10.1596/978-1-4648-0462-5

Financial inclusion can almost be taken as a given in high-income countries, but

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money, interoperable and multifunctional automated teller machines (ATMs),

• In Sri Lanka, a proactive development of the legislative framework enabled

• In Thailand, 88 percent financial inclusion of households has been achieved

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Bringing E-money to the Poor • http://dx.doi.org/10.1596/978-1-4648-0462-5

Anoma Kulathunga is a senior financial sector specialist in the World Bank’s

Bringing E-money to the Poor • http://dx.doi.org/10.1596/978-1-4648-0462-5 xv

ACH automated clearinghouse

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CNIC Computerized National Identity Card

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KCB Kenya Commercial Bank

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ROSCA rotating savings and credit association

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Bringing E-money to the Poor • http://dx.doi.org/10.1596/978-1-4648-0462-5 1

Map O.1 Universal Financial Access 2020 Focus Countries

Achieving Universal Financial Access by 2020

26–50% Mozambique 0.4%

Bringing E-money to the Poor • http://dx.doi.org/10.1596/978-1-4648-0462-5

Demirgüç-Kunt, Beck, and Honohan (2008) show evidence that financial

Motivation and Evidence

Bringing E-money to the Poor • http://dx.doi.org/10.1596/978-1-4648-0462-5

population as a direct result of innovations associated with a mobile money