In Sub-Saharan Africa, 12% of adults now report having a mobile money account, representing over a quarter of the share of those who have any kind of financial account at all. As mobile money expands, there is interest in how regulatory frameworks develop to support digital financial services (DFS) and also support broader financial inclusion. In theory, protecting consumers from risk, and ensuring that they have the information and understanding required to make informed decisions, may increase their confidence and trust in mobile money systems, leading to higher adoption and usage rates. However, consumer protection regulations may also carry certain trade-offs in terms of cost, usage, and innovation. The challenge, according to proponents of consumer protection, is to develop regulations that promote access and innovation, yet still offer an acceptable level of consumer protection. We review the literature on consumer protection institutions and regulatory documents for DFS (particularly mobile money) in 22 developing countries, and identify examples of specific consumer protection regulations relevant to mobile money in each country. Following an introduction to regulatory institutions and documents relating to consumer protection and DFS, we identify examples of regulations covering charges to consumers including fees, tariffs, and taxes for DFS in each country. We then review consumer protection regulations relating to costs from consumer losses resulting from system errors, erroneous transactions, agent misconduct, bankruptcy, and fraud. We further review regulations relating to transparency of provider terms and conditions, procedures for protecting consumers from harm, and complaints and dispute resolution.
This research was presented to the Consumer Experience and Protection Working Group of the International Telecommunications Union (ITU)'s Focus Group on Digital Financial Services (FG-DFS) on April 27, 2016, in preparation for the Fifth Meeting of the FG-DFS in Washington, DC.
View blog post summarizing this work.