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GSMA Intelligence GSMA The GSMA represents the interests of mobileoperators worldwide, uniting more than 750operators with nearly 400 companies in the broadermobile ecosystem, including handset and devicemakers, software companies, equipment providers GSMA Intelligence is the definitive source of globalmobile operator data, analysis and forecasts, andpublisher of authoritative industry reports andresearch. Our data covers every operator group,network and MVNO in every country worldwide – GSMA Intelligence is relied on by leading operators,vendors, regulators, financial institutions and third-party industry players, to support strategic decision-making and long-term investment planning. The data For more information, please visit the GSMAcorporate website at www.gsma.com Our team of analysts and experts produce regularthought-leading research reports across a range of GSMA Mobile Money The GSMA’s Mobile Money programme works toaccelerate the development of www.gsmaintelligence.com info@gsmaintelligence.com @GSMAi For more information, please contact us:Web: www.gsma.com/mobilemoneyTwitter: @GSMAMobileMoneyEmail: mobilemoney@gsma.com Authors Kalvin Bahia, Principal Economist,GSMA Intelligence Kennedy Kipkemboi Sawe,Mobile Money Regulatory Lead, GSMA Winnie Wambugu,Mobile Money Regulatory Specialist, GSMA Published December 2022 Contents 4Conclusions List of figures Figure 1Mobile Money Regulatory Index structureFigure 2MMRI Index scores in 2021 and change in Index scores since 2018Figure 3Countries that have seen the greatest improvements in MMRI scores between 2018 and 2021Figure 4Value of agent cash-in, cash-out transactions in KenyaFigure 5Number of countries with maximum score for each Authorisation indicatorFigure 6Mobile transactions in NigeriaFigure 7Number of countries with the maximum score for each Consumer Protection indicatorFigure 8Number of countries with benchmark score for each KYC indicator Executive summary Over the past decade, mobile money has become a mainstreamfinancial service, moving millions of households in low- and However, despite significant expansion of financial inclusionworldwide, there remain 1.4 billion unbanked adults in the world. The link between an enabling regulatory frameworkand a thriving mobile money market has beendemonstrated through empirical research.Regulation affects the ease with which newcustomers can enrol in a mobile money service,the range of services offered, and the commercial The financial inclusion gap is larger for underservedpopulations, including women, the poor and thoseoutside the workforce.1 Mobile money affords an Since 2018, 48 countries in the Index have improved their MMRI score, with only one country recording amaterial reduction. At the end of 2021, the majority of countries had effective and enabling regulations in A level playing field:78 countries nowpermit non-banks to issue e-moneyand offer mobile money services. Thisis important as the vast majority ofsuccessful mobile money marketshave been led by mobile operators. Consumer protection:The vastmajority of countries in the MMRI havecomprehensive consumer protectionrules that provide for disclosure Agent networks:Almost all countriesin the MMRI permit non-bank agents,allowing providers to developdistribution networks, especially inunderserved rural areas. The vast Safeguarding of funds:Every countrythat does not follow a bank-basedmodel requires e-money issuers toset aside funds equal to 100% ofoutstanding e-money liabilities in Most countries have enabling regulation, but there remain a significant number that can improve in thefollowing areas: International remittances:21 countriesdo not permit the sending or receivingof international money transfers(IMT) using mobile money. This is Affordability:14 countries imposeeither pricing regulation on mobilemoney services or a mobile money tax.Taxes increase the cost of provision Interest payments:An increasingnumber of countries have explicitlypermitted mobile money providersto earn and utilise interest on mobile Know-your-customer (KYC)requirements:16 countries in the MMRI allow operators flexibility in setting theminimum KYC requirements, and 48require that the customer only needsto present a form of ID and mobilenumber. However, the remaining 28 Financial inclusion strategy:Therehas been a significant increase inthe number of countries that haveformulated a financial inclusion Transaction limits:32 countries have atleast one set of limits assessed as lowand restrictive, either on entry-level or Deposit insurance:Only 15 countriesprovide deposit insurance protectionfor each mobile money account. Thisprovides for customer funds to be KYC identification and automatedKYC:52 countries in the MMRI do nothave ubiquitous rollout of national orgovernment-issued ID, and regulationsdo not allow documents other thanthese to access mobile money services.Such requirements will continue to Settlement access:In 48