An analysis of the Mobile Money Regulatory Index

In September 2018 we launched the Mobile Money Regulatory Index, an interactive tool that measures the effectiveness of mobile money regulatory frameworks.
Today, we are pleased to release a paper that provides a deep analysis on the findings of the Mobile Money Regulatory Index. We examine in detail the six key facets of regulation, notably:

  1. Authorisation: examining the eligibility to provide mobile money services; the relevant authorisation instruments such as legislation, regulation, guidelines and circulars; and the proportionality of capital requirements.
  2. Consumer protection: exploring the general consumer redress and disclosure mechanisms, and the provisions for safeguarding customer funds, including deposit insurance measures.
  3. Transaction limits: examining the proportionality of account balance and transaction limits (entry level and ceiling).
  4. Know Your Customer: examining the permitted identification requirements; the proportionality of KYC requirements; AML/CFT reporting obligations; and the guidance provided by regulators on ID requirements.
  5. Agent networks: exploring eligibility criteria for agents; their authorisation requirements; agent permitted activities; and the agent network condition, for example, whether formal notification or authorisation regimes are required for the appointment of individual agents.
  6. Investment and infrastructure environment: assessing external factors that are likely to affect the regulatory environment, such as sector-specific taxation; ID verification infrastructure, interoperability infrastructure, provisions on the utilisation of interest income and national financial inclusion policies.

We also highlight the broad range of approaches that countries have taken to regulate mobile money. It’s notable that not one size fits all, as an approach that is successful in one country often doesn’t suit another country, taking into account local market contexts. We find that countries with thriving or fast-growing mobile money markets generally adopt enabling regulatory frameworks that: (i) incentivise providers to invest and roll-out a wide range of services, and (ii) incentivise consumers to use mobile money, seen most prominently among underserved and unbanked populations.

Access the Mobile Money Regulatory Index at

Download the report