数字金融服务竞争：新兴市场与发展中经济体的监管策略与发展路径

Citation Please cite this study as: CCAF and Fii (2026).Competition in DigitalFinancial Services: Regulatory Strategies and Pathways for EmergingMarkets and Developing Economies. Contents PartIV: StrengtheningPrivateCapitalFormationthroughDFSCompetitionTools 61FoundationalFrameworks(Tier1)63ToolstoSupportEntry(Tier2)65ToolstoSupportandStrengthenScaling(Tier3)67AdvancedMarket-ShapingTools(Tier4)69TheCompetition-StabilityTrade-OffinCapitalFormation71Summary72 PartV:ImpactofDFSCompetition-EnhancingRegulatoryInterventions73–CaseStudiesCasestudy–Kenya/Nigeria74Casestudy-Malaysia/Vietnam78Summary81 PartVI:BuildingStrategiesforCompetitioninDFS82EmbeddingaCompetitionLensinPolicymakingandRegulation84IntroducingCompetition-FocusedPolicyandRegulatoryInterventions85Summary95 Endnotes100Bibliography108Abbreviations113 Foreword Effective competition in Digital Financial Services (DFS) can reduce the market power of incumbents, driving pricesdown, quality up, and raising the variety of services. Similarly, competition in DFS can also drive more effectiveprivate capital mobilization, with benefits for growth and the wider economy. However, DFS markets in manyEmerging Markets and Developing Economies (EMDEs) remain concentrated. Incumbent financial institutions andmobile network operators often benefit from preferential access to critical infrastructure, data, and regulatoryadvantages, while new entrants face structural, strategic and demand-side barriers that limit their ability to scale.This constrains the competitive pressure they exert on incumbents, dampens financial innovation, and can hinderthe mobilisation of domestic savings, private capital formation, and inclusive growth. At the same time, many public and financial authorities have access to a wide range of policy and regulatory tools,but these are not always designed or sequenced with an explicit competition lens, nor are their impacts on financialinclusion and capital formation systematically assessed. This report, developed by the Cambridge Centre for Alternative Finance (CCAF) at the University of CambridgeJudge Business School, and Financial Innovation for Impact (Fii) with the support of the UK Foreign, Commonwealth& Development Office (FCDO), responds to this gap. Building on the existing capacity-building programme oncompetition in DFS, the study considers how policy and regulatory tools can be leveraged to promote competitionin digital financial services (DFS) in EMDEs, and in particular their relation to capital formation. The report advances the literature and policy practice in three main ways. First, it proposes a conceptual frameworkto help public and financial authorities prioritise competition-enhancing interventions based on their jurisdictionalmarket and regulatory context, policy objectives, and the intended scope of action. Secondly, it systematicallymaps these tools to supply- and demand-side competition barriers, providing public and financial authorities withpractical approaches for developing tailored strategies for enhancing competition in DFS. Thirdly, it examines howmore effective competition in DFS can contribute to strengthening private capital formation in EMDEs, highlightinghow well-developed, pro-competition, policy and regulation can help overcome low savings mobilisation, inefficientfinancial intermediation, and capital misallocation. The analysis is grounded in comparative case studies across countries in Sub-Saharan Africa and the Asia-Pacificregion, highlighting that policy and regulatory tools, often introduced to achieve objectives beyond competition,can nonetheless shape competition dynamics for good. We hope the insights and analysis presented here will support public and financial authorities in designing andsequencing interventions that foster effective competition in DFS, while also contributing to a deeper academicunderstanding of the role of policymaking and regulation in shaping digital financial markets. Finally, we extend our gratitude to Keith Barnes and the UK Foreign, Commonwealth and Development Office(FCDO) for their support, and to the many participants in the capacity building online course whose perspectivesand insights helped ensure this report was both relevant and insightful. BryanZhang Philip Rowan Head of Competition, Cambridge Centre forAlternative Finance Judge Business School,University of Cambridge and FinancialInnovation for Impact Co-Founder and Executive Director, CambridgeCentre for Alternative Finance Judge BusinessSchool, University of Cambridge Research Team, Contributors,Acknowledgements Research Team Ana Odorović (CCAF/Fii), M. Konrad Borowicz (Tilburg University), Eleanor Jones (CCAF/Fii), PhilipRowan (CCAF/Fii), Douglas Arner (CCAF). Acknowledgements On behalf of the Cambridge Centre for Alternative Finance (CCAF) at the University of CambridgeJudge Business School, and Financial Innovation for Impact (Fii), the research team would like to thankKeith Barnes and the