EIUGlobalMicroscope2019 PDF

Global Microscope 2019
The enabling environment

for financial inclusion
Supported by
GLOBAL MICROSCOPE 2019
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The enabling environment for financial inclusion and the expansion of digital financial serv ices
About this report
The Global Microscope assesses the enabling environment for financial

inclusion across 5 categories and 55 countries. In this 2019 edition, the
EIU examines how countries are promoting financial inclusion for both
women and men, 11 new gender-focused indicators have been added to
the framework.
The Microscope was originally developed for countries in the Latin

American and Caribbean regions in 2007 and was expanded into
a global study in 2009. Most of the research for this report, which
included interviews and desk analysis, was conducted between June and
September 2019.
This work was supported by funding from the Bill & Melinda Gates
Foundation, the
Center for Financial Inclusion at Accion, IDB Invest and IDB LAB.
The complete index, as well as detailed country analysis, can be viewed on

these websites:
www.eiu.com/microscope2019
www.eiu.com/microscope
https://publications.iadb.org
https://www.centerforfinancialinclusion.org/series/global-microscope
Please use the following when citing this report:
EIU (Economist Intelligence Unit), 2019; Global Microscope 2019: The

enabling environment for financial inclusion; New York, NY.
For further information, please contact:

Microscope@eiu.com
© The Economist Intelligence Unit Limited 2019

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About the Economist Intelligence Unit About IDB Lab
The Economist Intelligence Unit (EIU) is IDB Lab is the innovation laboratory of the
the research arm of The Economist Group, IDB Group, the leading source of development
publisher of The Economist. As the world’s finance and know-how for improving lives in
leading provider of country intelligence, it Latin America and the Caribbean (LAC). The
helps governments, institutions and businesses purpose of IDB Lab is to drive innovation for
by providing timely, reliable and impartial inclusion in the region, by mobilizing financing,
analysis of economic and development knowledge, and connections to co-create
strategies. Through its public policy practice, solutions capable of transforming the lives of
the EIU provides evidence-based research vulnerable populations affected by economic,
for policymakers and stakeholders seeking social or environmental factors. Since 1993 IDB
measureable outcomes, in fields ranging from Lab has approved more than US $2 billion in
gender and finance to energy and technology. projects deployed across 26 LAC countries. As of
It conducts research through interviews, October 29, 2018, IDB Lab is the new identity of
regulatory analysis, quantitative modelling the Multilateral Investment Fund (MIF).
and forecasting, and displays the results via www.idblab.org
interactive data visualisation tools. Through a
About the Center for Financial Inclusion at
global network of more than 650 analysts and
Accion
contributors, the EIU continuously assesses
and forecasts political, economic and business The Center for Financial Inclusion at Accion
conditions in more than 200 countries. For more (CFI) is an action-oriented think tank that
information, visit www.eiu.com engages and challenges the industry to better
serve, protect, and empower clients. We
About IDB Invest
develop insights, advocate on behalf of clients,
IDB Invest, the private sector institution of the and collaborate with stakeholders to achieve
Inter-American Development Bank (IDB) Group, a comprehensive vision for financial inclusion.
is a multilateral development bank committed We are dedicated to enabling 3 billion people
to supporting businesses in Latin America who are left out of—or poorly served by—the
and the Caribbean. It finances sustainable financial sector to improve their lives.
enterprises and projects to achieve financial www.centerforfinancialinclusion.
results that maximize economic, social and org@CFI_Accion
environmental development for the region.
About Bill & Melinda Gates Foundation
With a current portfolio of $11.2 billion under
management and 330 clients in 23 countries, The Bill & Melinda Gates foundation focuses on
IDB Invest works across sectors to provide human development, from poverty to health,
innovative financial solutions and advisory to education. The areas of focus offer the
services that meet the evolving demands of its opportunity to dramatically improve the quality
clients. As of November 2017, IDB Invest is the of life for billions of people. The Foundation
trade name of the Inter-American Investment builds partnerships that bring together resources,
Corporation. For more information visit expertise, and vision—working with the best
www.idbinvest.org organisations around the globe to identify
issues, find answers, and drive change. For more
information, visit www.gatesfoundation.org

3
Project teams Acknowledgements
The Economist Intelligence Unit The following researchers, country analysts and
Leo Abruzzese, Project Director: specialists contributed to this report. We thank
leoabruzzese@eiu.com them for their contributions:
Monica Ballesteros, Project Manager: Country analysis:
monicaballesteros@eiu.com
Diane Alarcon, Stephen Allen, Amila Desaram,
Shubha Bharadwaj, Research Analyst: Waqas Rana, Jamie Hitchen, Meryem Kabbaj,
Ankita Banerjea, Research Analyst Bernard Kennedy, MANAUS Consulting (Tamar
Jennifer Wells, Marketing Executive: Benzaken Koosed, Bryn Philibert, Ana Philibert,
jenniferwells@eiu.com; Joel Levesque), Susana Martinez, MicroCredit
+44(2)7 576 8224 Ratings International Ltd. (M-CRIL) (Sanjay
Sinha, Sana Zehra, Gaurav Prateek, Shayandeep
IDB LAB
Chakraborty, Abhinav Soni, Paritosh Singh,
Sergio Navajas, Senior Specialist: Sahib Sharma & Krishna Raj Pandey.), Andras
sergion@iadb.org; Radnoti, David Ramirez, Nick Wolf.
Gador Manzano, Communications Specialist:
We also thank Ricardo Toranzo from the
gadorm@iadb.org
Association of Supervisors of Banks of
IDB Invest the Americas (ASBA) for facilitating the
Terence Gallagher, Head of Financial Inclusion: questionnaire to regulators in Latin America and
terence@iadb.org the Caribbean.
Ana Lucía Escudero, Communications Specialist: Model and report production:
analuciae@iadb.org
Mike Kenny, Emma Ruckley, William Shallcross,
Center for Financial Inclusion at Accion Nick Wolf.
Mayada Elzoghbi,Managing Director
Virginia Moore, Director, Communications:
vmoore@accion.org;
+1 202 393 5113
Bill & Melinda Gates Foundation

Daniel Radcliffe, Deputy Director, Policy,
Regulation, & Research:
Daniel.Radcliffe@gatesfoundation.org
Thao Hong, Policy Advocacy and
Communications
Thao.Hong@gatesfoundation.org
Special thanks to Elisabeth Rhyne, former

managing director of the Center for Financial
Inclusion at Accion and a long-term partner of
the Global Microscope team.

4
Contents
About this report 1

Project teams 3
Executive Summary 5
Key findings 5
Overall results 8
Introduction 9
Key findings 12
The overall enabling environment for financial inclusion has improved globally. Latin 12
America and the Caribbean remain the the region with the most conducive regulatory
environment and infrastructure for financial inclusion.
Countries continue to adopt financial inclusion strategies and incorporate digital 18
approaches to inclusion.
Improved frameworks for digital financial services increase certainty for financial 18
innovators.
Box 1. Basic enablers for digital financial inclusion 20
Cyber-security and privacy laws are evolving to respond to challenges in the digital era. 21
Box 2. Case study on Kenya’s indebtedness crisis from digital loans 23
Nearly all countries have created a financial literacy strategy, and most are implementing 24
activities to educate consumers. However, few focus on building financial capabilities.
Gender-related findings 25
Men and women have similar legal requirements to open accounts in all but one of the 25
countries in the 2019 Microscope, but few governments actively collect data on women’s
financial inclusion or include specific actions targeting women in national strategies.
Box 3. Good practices from Chile 26
Practical impediments—such as access to ID, the Internet and mobile phones—limit 27
women’s ability to take advantage of growing digital channels for financial inclusion.
Most countries need to achieve greater gender balance in top decision-making positions 27
at financial-sector regulators.
Country summaries 29
Methodology 85
Appendix 1: Detailed scoring guidelines 95

5
Executive summary
The 2019 Global Microscope analyses the Key findings

practices used by governments and regulators
The overall enabling environment for
around the world to increase financial inclusion
financial inclusion has improved globally.
among their populations. The index focuses
Latin America remains the region with
on the regulatory and policy environments
the most conducive regulatory and policy
exclusively and does not reflect financial
environment for financial inclusion.
inclusion outcomes. The 2019 Microscope also
incorporates a specific gender perspective While increases in countries’ scores across the
to better understand how financial inclusion index provide evidence of more favourable
policies affect women differently, and how environments for financial inclusion around the
policymakers can narrow the gender gap in world, Colombia, Peru and Uruguay maintained
financial inclusion. Although overall access to their rankings at the top of the 2019 Microscope.
the financial system has increased, the World These three countries improved their overall
Bank’s Global Findex shows that the gender gap scores, as well as their scores for specific
in access to financial accounts has also increased domains.
in Microscope countries over the past decade,
Countries continue to adopt financial
on average. To examine how countries are
inclusion strategies and incorporate digital
promoting financial inclusion for both women
and men, 11 new gender-focused indicators have
been added to this edition of the Microscope. One-fifth of the countries included in the
2019 Microscope improved their performance
Legal barriers continue to impede women’s
in the area of financial inclusion strategies.
access to financial services. According to the
Argentina and Costa Rica have both issued new
World Bank’s Women, Business and the Law
strategies. Russia also issued a national strategy
2019 report, women have three-quarters of the
on financial inclusion, which employs a digital
rights that are recognised for men in the average
approach and includes online resources related
economy. The 2019 Global Microscope considers
to financial literacy and a smartphone-based
some of these legal inequalities, as well as the de
instant payment system. Honduras’s strategy
facto barriers related to enablers such as access
also received credit for a digital approach in
to national IDs, the Internet and mobile phones.
2019, having set goals for e-wallets and other
digital financial services.
Improved frameworks for digital financial

services increase certainty for financial
innovators.
Ten of the 55 countries in the 2019 Microscope

improved their fintech frameworks. Rwanda
passed regulations governing payment
system providers, lifted barriers for remote

6
account opening and established a dedicated Gender-related findings

unit responsible for cyber-security and data
Men and women have similar legal
protection. Sierra Leone and Thailand also made
requirements to open accounts in all but
progress that increased their scores significantly
one of the countries in the 2019 Microscope,
in this area: Sierra Leone has established a
but few governments actively collect data
regulatory sandbox for fintech firms, and
on women’s financial inclusion or include
Thailand’s regulators have allowed innovations
specific actions targeting women in national
such as equity crowdfunding for Thai firms. As
strategies.
a result of these efforts, Rwanda, Sierra Leone
and Thailand join seven other countries from The 2019 Microscope added 11 indicators to
the previous edition of the Microscope who better assess what governments are doing to
have frameworks that provide legal certainty for address the gender gap in financial inclusion.
fintech innovations. Only one of the 55 countries included in this
year’s Microscope (Cameroon) places regulatory
Data protection and cyber-security laws
barriers on women opening accounts. However,
are evolving to respond to challenges in the
few governments take proactive steps to
digital era.
reduce the gender gap in account ownership
In 2018 and 2019 several countries introduced specifically, and in financial inclusion more
data protection and cyber-security laws that broadly. Collecting data on women’s use of
protect users of financial services. For instance, financial services can help governments to
Vietnam issued a cyber-security law that identify factors that prevent women from
applies to financial firms, fintech services and achieving greater financial inclusion. At present,
e-commerce, as well as Internet services, social however, just one-quarter of countries collect
networks, IT services and individuals. Uganda’s and publish comprehensive sex-disaggregated
Data Protection and Privacy Act became law in data on demand and supply for financial
February 2019 and applies to financial service products (nine countries in Latin America, four
providers as well as other entities. In October in Africa and one in South Asia) Only one-third
2018 the government of Uruguay issued a data of countries in the 2019 Microscope include a
protection law that applies to database owners gender approach in their financial inclusion
and data processors in all economic sectors. strategies, and even fewer have set clear,
In Rwanda, the newly established Information gender-related goals.
Society Authority is implementing data and
Practical impediments—such as access to
cyber-security laws and shares data protection
ID, the Internet and mobile phones—limit
and privacy enforcement responsibilities for
women’s ability to take advantage of growing
financial service providers with the central bank.
digital channels for financial inclusion.
Data from the 2019 Microscope and the Global

Findex show that women’s access to national ID
and mobile phones may have an effect in the
gender gap in account ownership. In countries
where women have better or similar access to
ID than men, the average gender gap in account
ownership is 8%, compared with an average of

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9% for all countries. When women have better

or similar access to mobile phones than men,
the average gender gap in account ownership
is 6%. Furthermore, in countries where women
have better access to mobile phones, the
average gender gap in account ownership has
fallen by 1% since 2011, compared with an overall
average increase of 1% across all countries.
Most countries need to achieve greater

gender balance in top decision-making
positions at financial-sector regulators.
In 37 of the 2019 Microscope’s 55 countries,

women accounted for less than 25% of decision-
makers at financial regulators. Women held
more than half of these decision-making
positions in just one country in the index:
Bolivia (where the national parliament also has
a female majority). The data on women leaders
in financial-sector regulators mirrors data from
the private sector. According to a 2016 study
by Oliver Wyman (a consultancy), women
accounted for just 20% of the membership of
financial service boards of directors, and just
16% of executive committee members. The
same study noted that at current growth rates,
executive committees would not achieve 30%
female representation until 2048.

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Overall results
Overall score
Rank Score Rank Score
1 ←→ Colombia 82 +1 =29 ▲ 11 Cameroon 51 +8
2 ←→ Peru 80 +2 =29 ▲7 Egypt 51 +6
3 ←→ Uruguay 76 +1 =29 ▲2 Morocco 51 +1
4 ▲2 Mexico 74 +4 32 ▲2 Trinidad and Tobago 50 +1
=5 ▼1 India 71 -1 =33 ▲2 Turkey 49 +1
=5 ▼1 Philippines 71 -1 =33 ▲4 Vietnam 49 +5
=7 ▲2 Argentina 70 +6 =35 ▼4 Ghana 48 -2
=7 ←→ Indonesia 70 +1 =35 ▼ 12 Jamaica 48 -6
9 ←→ Brazil 69 +5 37 ▼ 10 Senegal 47 -5
10 ▲1 Rwanda 68 +6 38 ▼1 Nicaragua 45 +1
=11 ▼3 Chile 65 -1 39 ▲2 Nepal 44 +4
=11 ▲2 China 65 +4 =40 ▲7 Madagascar 43 +7
=13 ▲ 10 El Salvador 63 +9 =40 ▼ 21 Nigeria 43 -13
=13 ▼2 South Africa 63 +1 42 ▼ 16 Sri Lanka 42 -11
15 ▼1 Tanzania 62 +2 43 ▲1 Guatemala 41 +2
16 ▼2 Paraguay 61 +1 44 ▲6 Lebanon 40 +7
17 ▲ 13 Costa Rica 58 +7 45 ▼1 Ethiopia 39 0
18 ←→ Bolivia 57 0 46 ▼5 Bangladesh 38 -2
=19 ▼3 Panama 56 -3 =47 ▼3 Cambodia 37 -2
=19 ▲8 Russia 56 +4 =47 ▲1 Uganda 37 +3
21 ←→ Pakistan 55 0 49 ▲3 Haiti 34 +8
=22 ▲ 15 Dominican Republic 54 +10 =50 n/a Côte d’Ivoire 33 n/a
=22 ▼1 Honduras 54 -1 =50 ▲1 Myanmar 33 +2
=22 ▲1 Kenya 54 0 52 ▼4 Venezuela 32 -2
=22 ▼6 Thailand 54 -5 53 ▼ 12 Tunisia 30 -10
=26 ▼7 Ecuador 53 -3 54 ▼1 Sierra Leone 28 +6
=26 ▲1 Mozambique 53 +1 55 ▼2 DRC 21 -1
28 ▲3 Jordan 52 +2

9
Introduction
The 2019 Global Microscope analyses the strategies), as well as factors that enable women
policies used by governments and regulators to take advantage of new channels into the
around the world to increase financial inclusion financial system (e.g. access to the Internet),
among their populations. Informed by the contribute to or diminish this persistent gender
vision of the Center for Financial Inclusion at gap. The 11 indicators measure the following:
Accion (CFI), the Microscope defines financial
inclusion as access to a full suite of quality Government collection of sex-disaggregated
1.
financial services for customers who possess financial inclusion data
financial capability, provided via a diverse and Inclusion of a gender approach in national
2.
competitive marketplace. The Microscope financial inclusion strategies
covers five domains:
Inclusion of a gender approach in financial
3.
1. Government and Policy Support literacy strategies and programmes
Inclusion of a gender approach in digital

2. Stability and Integrity 4.
literacy strategies and programmes
3. Products and Outlets
Women’s participation in decision-making at
5.
4. Consumer Protection financial regulators
6. Non-discrimination in account opening

5. Infrastructure
Diversity programmes for non-banking or
The 2019 Microscope also incorporates a specific 7.
correspondent agents
gender perspective to better understand
how financial inclusion policies affect women Gender gap in access to national identification
8.
(ID)
differently, and how policymakers can narrow
the gender gap in financial inclusion. Although 9. Non-discrimination in access to national ID
overall access to the financial system has 10. Gender gap in Internet access
increased, the World Bank’s Global Findex
11. Gender gap in access to a mobile phone
shows that the gender gap in access to financial
accounts has also increased in Microscope
countries over the past decade, on average. To These indicators are spread across the
examine how countries are promoting financial Microscope’s five domains but are mostly
inclusion for both women and men, 11 new concentrated within the Government and Policy
gender-focused indicators have been added to Support domain and the Infrastructure domain.
this edition of the Microscope.
Legal barriers continue to impede women’s
While a number of factors contribute to access to financial services. According to the
differences in access to financial services World Bank’s Women, Business and the Law
between women and men, the 2019 2019 report, women have three-quarters of the
Microscope’s gender-focused indicators rights that are recognised for men in the average
seek to document how policy and regulatory
approaches to financial inclusion (e.g. national

10
Table 1. Gender disparities in access to national ID, the Internet and mobile phones
Among the 55 countries in the Microscope, men’s access to the following key enablers outpaces women’s access:
National identification system Internet Mobile phone
21 countries 41 countries 34 countries
economy.1 Limitations on women’s movements, ID, the Internet and mobile phones continues to
ability to get a job, opportunities to start a outpace women’s in a majority of the countries
business and other rights inevitably affect their in the index.
ability to participate in the formal financial
Women also have less access to financial
system. The World Bank’s report examined
accounts than men, again despite a general lack
reforms undertaken between 2008 and 2017
of legal impediments. Although Cameroon was
to improve gender equality and found that
the only country in the 2019 Microscope where
progress was slowest in recognising women’s
legal requirements for opening an account
legal rights to manage assets. This indicates
are different for women and men, the average
that women still face important legal barriers to
gender gap in access to financial accounts in
participating in the financial system on an equal
Microscope countries remains at 9%, according
footing with men.
to the Global Findex.
The 2019 Global Microscope considers some
As financial inclusion policy shifts its focus
of these legal inequalities in its analysis of
towards the promotion of digital financial
the environment for financial inclusion in 55
services, regulators and policymakers
countries around the world. It also analyses
must address this digital gender gap or risk
other potential de facto barriers that might
contributing to even greater disparities in
affect potential users of digital financial services
access to financial services between women and
such as disparities in access to national ID, the
men. Although nearly four-fifths of countries
Internet and mobile phones (see Table 1). While
in the Microscope have strategies or initiatives
relatively few countries impose legal restrictions
to promote digital literacy, only one-fifth
on women’s access to these key enablers, these
incorporate a gender approach into these
disparities persist. For example, in legal terms,
programmes.
women and men have the same access to
national ID in all but five of the 55 countries in Providing access to digital tools, and developing
the index (Cameroon, Egypt, Haiti, Pakistan and individuals’ capability to use these tools, are
Tunisia). Despite this, men’s access to national important determinants of financial inclusion,
but they also introduce new risks for low-
income populations. In Kenya, for example—a
pioneer in mobile money—the 2019 FinAccess
1 World Bank Group. 2019. “Women, business and the law 2019.” [https://
openknowledge.worldbank.org/bitstream/handle/10986/31327/WBL2019. Household Survey found that reports of
pdf?sequence=4&isAllowed=y]. The report examines 187 economies, with
scores ranging from 25.63 (where women have approximately one-quarter of individuals losing money due to fraud or user
the rights of men) to 100 (full equality).

11
error were highest for mobile money, compared

with other financial institutions.2 For consumers
who connect to the formal financial system
for the first time via digital financial services,
negative experiences can affect their trust
in those specific channels and the broader
financial system.
As the landscape for financial inclusion

continues to evolve, and as financial service
providers adopt new technologies and
approaches, governments will need to
implement policies to ensure that potential
users develop the necessary capabilities
and possess key enablers to access and use
these products (such as national ID and
mobile phones). This includes developing and
implementing policies specifically designed to
address gender disparities in access to these
enablers. To support this effort, the 2019 Global
Microscope examines the policy and practice of
financial inclusion, and countries’ use of gender-
specific approaches, in order to identify ideas
and initiatives that promote more equitable
access to the financial system for low- and
middle-income individuals, and for women in
particular.
2 FinAccess. 2019. “2019 FinAccess household survey.” [https://s3-eu-central-1.

amazonaws.com/fsd-circle/wp-content/uploads/2019/04/09103904/2019-
FinAcces-Report-13-06-2019.pdf].

12
Key findings
The overall enabling environment for in the Consumer Protection domain for both
financial inclusion has improved globally. countries. In Colombia, data protection is
Latin America and the Caribbean remain overseen by both the competition regulator
the the region with the most conducive and the financial-sector supervisor. In Uruguay,
regulatory environment and infrastructure a new law was implemented in 2019 that
for financial inclusion. expanded its data protection regime.
While increases in countries’ scores across the Uruguay ranked third overall in the 2019
index provide evidence of more favourable Microscope. Compared with its scores in the
environments for financial inclusion around the previous edition of the Microscope, Uruguay
world, Colombia, Peru and Uruguay maintained showed the greatest improvement in the
their rankings at the top of the 2019 Microscope. Infrastructure domain. Women in Uruguay now
These three countries improved their overall have as much access to the Internet as men,
scores, as well as their scores for specific and they have slightly better access to mobile
domains. phones and the national ID system than men.
Access to these enablers ensures that women
Colombia ranked first overall in the 2019
can take advantage of new digital financial
Microscope. Compared with its scores in the
service offerings in the country. However,
previous edition of the Microscope, Colombia
Uruguay still lacks an automated know-your-
showed improvement in the Stability and
client (KYC) system, which would facilitate the
Integrity and Product Outlets domains.
adoption of digital financial services by both
Recent changes have lifted prior restrictions
women and men.
on the activities of banking and non-banking
institutions related to remote account Overall, the average scores for the 55 countries
opening and customer due diligence (CDD) included in the 2019 Microscope increased across
requirements. These changes have allowed four of the five domains included in the study.
financial institutions to issue simplified accounts Government and policy support was the only
with similar requirements than those imposed domain where the average score decreased,
on firms specialised in electronic deposits and driven down by the inclusion of new gender
payments (SEDPEs). indicators. This demonstrates that there are
opportunities for improvement in integrating
Peru ranked second overall in the 2019
a gender component into financial inclusion
Microscope. Compared with its scores in the
efforts worldwide. For example, while three-
previous edition of the Microscope, Peru
quarters of the countries in the 2019 Microscope
showed the greatest improvement in the
collect some data on financial inclusion, only
Consumer Protection domain—specifically,
one-quarter disaggregate that data by gender.
for its data protection framework for financial
Across all the countries included in the 2019
customers, which is enforced by a specialised
Microscope, Chile (ranked 11th overall) stands
agency housed in the Ministry of Justice.
out as the only country to have collected this
Colombia and Uruguay also performed well on
kind of data for more than a decade (see Box 3).
data protection, contributing to score increases

13
In focus: Government and policy support

The government and policy support category assesses the degree of coordination and
the incentives that governments are putting in place to create favorable environments for
financial inclusion.
1. Government and policy support
Indicator # Indicator name Sub-indicator # Sub-indicator name Question name
Intra-governmental Evidence of intra-

Broad strategies for
1.1 1.1.1 cooperation, strategy and government coordination and
financial inclusion
implementation implementation
Intra-governmental
Broad strategies for Data collection by the
1.1 1.1.2 cooperation, strategy and
financial inclusion government
implementation
Intra-governmental Evidence of intra-

Broad strategies for
1.1 1.1.3 cooperation, strategy and government coordination and
financial inclusion
implementation implementation
Broad strategies for Strategy to expand agent

1.1 1.1.4 Target agent network
financial inclusion networks
Support for financial

Promotion of financial and
1.2 1.2.1 Financial literacy literacy and/or stregthening
digital literacy
capabilities
Support for digital literacy

Promotion of financial and Digital literacy and
1.2 1.2.2 and/or stregthening
digital literacy stregthening capabilities
capabilities
Initiative for digitisation of

Incentives for digitisation Government payments (G2P
1.3 1.3.1 government payments (G2P
and emerging technologies and P2G)
and P2G)
Percentage of G2P recipients

Incentives for digitisation Government payments (G2P
1.3 1.3.1 that receive payments into an
and emerging technologies and P2G)
account
Incentives for digitisation Government payments (G2P Online portal for P2G or B2G
1.3 1.3.1
and emerging technologies and P2G) digital payments
Approach to authorization
Incentives for digitisation
1.3 1.3.2 Fostering innovation and oversight of financial
and emerging technologies
innovation
Compared with their scores in the previous also include a gender focus. In Argentina’s
edition of the Microscope, Pakistan and case, maintaining a gender perspective is a
Argentina showed the greatest improvement in cross-cutting objective in the strategy, and
the Government and Policy Support domain in the government has already taken steps to
2019. Pakistan has revised its financial inclusion develop and measure sex-disaggregated
strategy, with an emphasis on digital payments, financial inclusion indicators and to push
and Argentina has issued a draft of its financial forward a gender parity initiative in the national
inclusion strategy (after nearly two years in government. Pakistan’s strategy includes
development). Both countries’ strategies initiatives designed to increase women’s

14
financial literacy and capabilities, specific goals as ownership rules, initial capital requirements,
for account uptake among women (20m digital and licensing and operating requirements
accounts) and a specialised refinancing facility (e.g. the number of branches) for banks, non-
for women entrepreneurs. bank financial institutions, e-money issuers
and cross-border payment providers. Overall,
In the Stability and Integrity domain, the
about one-fifth of the countries in the index
average score increased in the 2019 Microscope
had proportionate market entry requirements
compared with the 2018 edition. Rwanda and
for these institutions, and a similar number had
Uruguay led the index in this area, thanks to
proportionate ongoing operating requirements.
proportionate market entry requirements such
In focus: Stability and integrity

The stability and integrity domain assesses the regulation, supervision and monitoring of financial services providers
that serve low and middle-income populations, to ensure prudential stability and financial integrity. The assessment
prioritizes a risk-based approach so that regulation does not unnecessarily inhibit market entry for products that can
advance financial inclusion.
2. Stability and integrity

2.1 Market entry 2.1.1 Market entry restrictions for banks Disproportionate initial requirements for banks
Market entry restrictions for non-bank financial Disproportionate initial requirements for non-bank
2.1 Market entry 2.1.2
institutions financial institutions
Disproportionate initial requirements for e-money
2.1 Market entry 2.1.3 Market entry restrictions for e-money issuers
issuers
Market entry restrictions for cross-border payment Disproportionate initial requirements for cross-
2.1 Market entry 2.1.4
providers border payment providers
2.2 Ongoing requirements 2.2.1 Ongoing requirements for banks Disproportionate ongoing requirements for banks
Ongoing requirements for non-bank financial Disproportionate ongoing requirements for non-
2.2 Ongoing requirements 2.2.2
institutions bank financial institutions
Disproportionate ongoing requirements for
2.2 Ongoing requirements 2.2.3 Ongoing requirements for e-money issuers
e-money issuers
Ongoing requirements on cross-border payment Disproportionate ongoing requirements for cross-
2.2 Ongoing requirements 2.2.4
providers border payment providers
2.3 Customer due diligence 2.3.1 Risk-based AML/CFT framework Harmonised framework with FATF guidelines
Disproportionate customer due diligence
2.3 Customer due diligence 2.3.2 Customer due dilligence requirements requirements for providers serving low-income
customers
2.4 Supervisory capacity 2.4.1 Political independence of financial regulation Influence of politics in financial regulation
Technical capacity to supervise financial services Technical expertise to supervise non-bank financial
2.4 Supervisory capacity 2.4.2
that facilitate financial inclusion institutions
Technical capacity to supervise financial services Technical expertise to supervise digital financial
that facilitate financial inclusion services
Technical capacity to supervise financial services Proportion of women in top decision making in the
that facilitate financial inclusion financial regulatory bodies
Technical capacity to supervise financial services
2.4 Supervisory capacity 2.4.5 Regulatory technology
that facilitate financial inclusion
Monitoring and data collection of financial services
2.4 Supervisory capacity 2.4.6 Market monitoring
providers not regulated as financial institutions
Commitment to
2.5 2.5.1 Government commitment to Cybersecurity Overall commitment to cybersecurity
Cybersecurity

15
In the Products and Outlets domain, Bolivia repayment obligations cannot exceed 25% of
remained the top scorer, with the only perfect monthly income; authorities have kept pace
score in any of the five domains. In Bolivia, with advances like digital financial services,
non-bank agents can open savings and e-money updating regulations in 2017; and an inclusive
accounts for customers; regulations restrict insurance framework has existed since 2000.
excessive borrowing by requiring that loan
In focus: Products and outlets

The product and outlets domain assesses the regulation of specific products and outlets that
focus and/or reach low income populations
3. Products and outlets

Accounts at financial
3.1 3.1.1 Account opening Account opening requirements
institutions and e-money
Accounts at financial Non-discrimination account
3.1 3.1.2 Account opening
institutions and e-money opening
3.1 3.1.3 Account opening Remote account opening
3.1 3.1.4 Safeguarding customer funds Deposit insurance
3.1 3.1.5 Safeguarding customer funds E-money safeguarding mechanisms
Credit portfolios for middle
and low-income customers
Risk-management framework for
3.2 (microcredit, consumer 3.2.1 Credit risk management
consumer credit
credit, digitally-delivered
nanocredit)
Credit portfolios for middle
and low-income customers
Restrictions for excessive
3.2 (microcredit, consumer 3.2.2 Overindebtedness
borrowing
credit, digitally-delivered
nanocredit)
Legal certainty for Fintech and
3.3 Emerging services 3.3.1 Fintech framework
other emerging services
Dedicated inclusive insurance
3.4 Inclusive insurance 3.4.1 Proportionate regulation
framework
Financial outlets (Agents,
Actors who can serve as financial
3.5 merchants and electronic 3.5.1 Ease of operation
outlets
channels)
Services that financial outlets can
3.5 merchants and electronic 3.5.2 Breadth of operations
offer
channels)
3.5 merchants and electronic 3.5.3 Liability Responsibility over outlets actions
channels)

16
In the Consumer Protection domain, Colombia belong to a small group of just nine countries
overtook South Africa to become the top scorer, that promote diversity among financial service
although both countries increased their scores. provider agents (Indicator 4.1.4). For example,
They are also the only two countries to achieve South Africa’s Black Economic Empowerment
perfect scores for protection for financial service programme includes quotas and targets for
users (Indicator 4.1 in the Microscope), and they workers in the financial sector.
In focus: Consumer protection

The consumer protection domain assesses consumer protection and privacy regulation and
enforcement capabilities
4. Consumer protection

Consumer protection framework Dedicated financial consumer
4.1 Financial services users 4.1.1
and enforcement protection framework
Disclosure of relevant product
4.1 Financial services users 4.1.2 Transparency
information
Aggressive sales and debt
4.1 Financial services users 4.1.3 Fair Treatment
collection practices
Non-discrimination in financial
4.1 Financial services users 4.1.4 Fair Treatment
services provision
Inclusive provision of financial
4.1 Financial services users 4.1.5 Diversity of agents
services
Standards for complaint
4.1 Financial services users 4.1.6 Dispute resolution
resolutions
Protections for financial outlets
4.1 Financial services users 4.1.7 Financial outlets and agents
and agents users
Digital financial services and Protection for digital financial
4.1 Financial services users 4.1.8
e-money services users
Protection for government
4.1 Financial services users 4.1.9 Government payments
payment recipients
Protection for inclusive insurance Harmonised requirements for
4.2 Inclusive Insurance users 4.2.1
providers inclusive insurance prodcuts
Data privacy and
4.3 4.3.1 Data protection and privacy Data privacy laws
cybercrime protection
Data privacy and
4.3 4.3.2 Cybercrime legal protection Law related to Cybercrime
Data privacy and
4.3 4.3.3 Privacy laws enforcement Data privacy enforcement entity

17
Infrastructure was the most improved domain submitted digital photos of identity documents
in the 2019 Microscope, with more than four- to verify customer identities. This method can
fifths of countries improving their scores. Costa also be used in Uganda to open mobile money
Rica, El Salvador, Kenya, Lebanon, Panama accounts (but not bank accounts; banks are
and Uganda received credit for improvements currently negotiating with the government
in their electronic KYC (e-KYC) systems. For to connect their systems to the national
example, banks in Costa Rica can now access identification registry). Electronic signatures
an international e-KYC registry, and institutions are accepted for identity verification in Kenya,
in El Salvador and Panama can use remotely Lebanon and Panama.
In focus: Infrastructure
The infrastructure domain assesses the infrastructure that facilitates financial inclusion as well as the policy and
regulatory actions that governments can take to improve these types of infrastructure
5. Infrastructure

Access to cash-in/cash-out and transaction
5.1 Payments infrastructure 5.1.1 ATMs per 10,000 people
points
Access to cash-in/cash-out and transaction
5.1 Payments infrastructure 5.1.1 POS terminals per 10,000 people
points
Mandated fair and non-discrimatory access to
5.1 Payments infrastructure 5.1.2 Access to retail payment infrastructure
payment infrastructure
Mandated fair and non-discrimatory access to
5.1 Payments infrastructure 5.1.3 Access to telecommunications bearer services
telecommunications infrastructure
5.1 Payments infrastructure 5.1.4 Interoperability Degree of interoperability
5.2 Digital IDs 5.2.1 Digital ID system National ID system with digital applications
Difference in access to an ID between men and
5.2 Gender gap in national IDs 5.2.1.b Gender Gap in ID system
women
5.2 Digital IDs 5.2.2 Automated KYC e-KYC verification systems
5.2 Digital IDs 5.2.3 Non discriminatory access to IDs Non discriminatory access to IDs
5.3 Connectivity 5.3.1 Internet access Percentage of households with Internet access
Difference in access to internet between men
5.3 Connectivity 5.3.2 Gender gap in internet access
and women
5.3 Connectivity 5.3.3 Network coverage Coverage of 2G network
5.3 Connectivity 5.3.3 Network coverage Coverage of 3G network
5.3 Connectivity 5.3.5 Mobile subscribers Mobile - cellular telephone subscribers
Difference in access to a mobile phone
5.3 Connectivity 5.3.6 Gender gap in mobile subscribers
between men and women
Credit information and other data-
5.4 5.4.1 Comprehensive information Information stored by credit-reporting systems
sharing systems
Credit information and other data- Correction of errors in credit-reporting
5.4 5.4.2 Access to records
sharing systems information
5.4 5.4.3 Coverage of credit reporting systems Coverage of public credit registry
sharing systems
5.4 5.4.3 Coverage of credit reporting systems Coverage of credit bureau coverage
sharing systems

18
El Salvador, Costa Rica, Argentina, Brazil Nicaragua and Sierra Leone both increased
and Rwanda demonstrated some of the implementation of their respective strategies:
most significant score increases in the 2019 Nicaragua has gradually developed regulations
Microscope, reflecting a number of important to reach financial inclusion goals, including
developments. Costa Rica and Argentina agent banking rules; and Sierra Leone has
have issued financial inclusion strategies, and established working groups involving important
El Salvador is working on the creation of a stakeholders to address financial inclusion
supervisory framework for financial technology measures included in its strategy.
(fintech). Since 2018 Brazil has eased account-
Improved frameworks for fintech and digital
opening requirements for e-money accounts
financial services increase certainty for
that use prepaid cards, requiring only the
financial innovators.
user’s full name, ID number and an online login
to manage the account. In Rwanda, banks, Beyond the overarching strategies mentioned
microfinance institutions and e-money issuers above, countries have also improved specific
can now use technology to provide remote regulations related to fintech and digital financial
account-opening services. services. In Brazil, a new national digital ID
system will facilitate growth and inclusion in the
Nigeria experienced the largest score decrease
sector. In El Salvador, regulators have eliminated
in the 2019 Microscope, in the Government and
a disproportionate tax on financial transactions
Policy Support domain. Its scores also decreased
and created a simplified bank account that
in the Consumer Protection domain and the
clients can open remotely.
Products and Outlets domain. Nigeria does not
incorporate a gender approach in its financial In addition, ten of the 55 countries in the 2019
inclusion or financial literacy strategies, does not Microscope improved their fintech frameworks.
collect data on financial services for low-income Rwanda’s framework promotes growth,
populations and does not have a digital literacy having passed regulations governing payment
strategy. system providers, lifted barriers for remote
account opening and established a dedicated
Countries continue to adopt financial
unit responsible for cyber-security and data
inclusion strategies and incorporate digital
protection. Sierra Leone and Thailand also made
progress that increased their scores significantly
One-fifth of the countries included in the 2019 in this area: Sierra Leone has established a
Microscope improved their performance in regulatory sandbox for fintech firms, and
the area of financial inclusion strategies. As Thailand’s regulators have allowed innovations
mentioned above, Argentina and Costa Rica such as equity crowdfunding for Thai firms. As
have both issued new strategies, although a result of these efforts, Rwanda, Sierra Leone
implementation has not yet begun. Russia also and Thailand join seven other countries from
issued a national strategy on financial inclusion, the previous edition of the Microscope who
which employs a digital approach and includes have frameworks that provide legal certainty
online resources related to financial literacy and for fintech innovations. In 2019 seven additional
a smartphone-based instant payment system. countries took initial steps to regulate the
Honduras’s strategy also received credit for a sector, which means that 20 countries in total
digital approach in 2019, having set goals for now have working groups for fintech. Despite
e-wallets and other digital financial services. this progress, however, 25 countries in the index

19
have not yet decided how to approach the fast- and proposals, which are then compiled into
evolving space of financial innovation. technical papers for review by regulators before
issuing new rules and supervisory guidelines.
However, even as fintech regulation matures
Pakistan has also achieved advanced capacity
in some countries, there is a need to improve
for supervision by establishing a public-private
the supervision capacity for digital financial
technical committee, and Colombia has
services.. In the 2019 Microscope, only nine
established both a specialised group and a
countries demonstrated having dedicated
regulatory sandbox for supervising emerging
technical experts with advanced capacity to
services. In Uruguay, regulators responsible for
supervise digital financial services. Argentina has
different aspects of supervision co-operate via a
demonstrated advanced capacity to supervise
financial stability committee.
these services, following the creation of working
groups where stakeholders present opinions

20
Box 1. Basic enablers for digital financial inclusion

Within the overall framework for promoting digital financial inclusion, the Consultative Group
to Assist the Poor (CGAP) has identified four basic enablers: allowing non-banks to issue
e-money, the presence of financial service agents, proportionate customer due diligence and
effective financial consumer protection.3 Indicators in the 2019 Microscope cover these four
enablers.
Only four countries scored perfectly across all four enablers: Colombia, India, Jamaica and
Uruguay. In these countries, a range of providers are capable of providing digital financial
services to populations on the margins of the formal financial system, regulations control
for some of the risks inherent in these services, and clear rules mark out spaces appropriate
for innovation to achieve greater financial inclusion. In countries without proportionate
regulations, the growth of unregulated or under-regulated digital financial services can have
deleterious effects.
Table 2. Key enablers of digital financial inclusion
E-money issuance Use of Agents Risk-Based Customer Due Consumer

by Nonbanks Diligence Protection
2.1.3) Market 3.5) Financial outlets 2.3.2.a) Disproportionate 4.1.7.a) Protection
entry restrictions (Agents, merchants due diligence requirements for digital
for e-money and electronic for providers serving low- financial services
issuers channels) income customers users
Colombia ● ● ● ●
India ● ● ● ●
Jamaica ● ● ● ●
Uruguay ● ● ● ●
Peru ● ● ● ●
Mexico ● ● ● ●
Argentina ● ● ● ●
Indonesia ● ● ● ●
Philippines ● ● ● ●
Brazil ● ● ● ●
Rwanda ● ● ● ●
Chile ● ● ● ●
China ● ● ● ●
South Africa ● ● ● ●
El Salvador ● ● ● ●
Tanzania ● ● ● ●
Paraguay ● ● ● ●
Costa Rica ● ● ● ●
Bolivia ● ● ● ●
Pakistan ● ● ● ●
Panama ● ● ● ●
Russia ● ● ● ●
3 Consultative Group to Assist the Poor. “Regulation for inclusive digital finance.” [https://www.cgap.org/topics/collections/regulation-inclusive-digital-
finance].

21
Cyber-security and privacy laws are evolving Society Authority is implementing data and
to respond to challenges in the digital era. cyber-security laws and shares data protection
and privacy enforcement responsibilities for
In 2018 and 2019 several countries introduced
financial service providers with the central bank.
data protection and cyber-security laws that
protect users of financial services. For instance, Overall, just 20 of the 55 countries in the 2019
Vietnam issued a cyber-security law that Microscope have comprehensive data privacy
applies to financial firms, fintech services and laws, but nearly three-quarters have some data
e-commerce, as well as Internet services, social privacy regulations that affect financial services.
networks, IT services and individuals. Uganda’s There are opportunities to improve both the use
Data Protection and Privacy Act became law in and the strength of government entities tasked
February 2019 and applies to financial service with enforcing data privacy. Just over half of the
providers as well as other entities. In October countries in the index have a government entity
2018 the government of Uruguay issued a data with the capacity to enforce data protection
protection law that applies to database owners laws, and this capacity is only considered strong
and data processors in all economic sectors. in 15 of those countries.
In Rwanda, the newly established Information
Table 3. Countries with comprehensive data protection framework and strong enforcement capacity
Countries with comprehensive data protection framework and strong enforcement capacity
4.3.1.a) Existence of data protection laws 4.3.3.a) Data privacy enforcement entity
Comprehensive legal framework for data Data privacy enforcement entity with strong
protection capacity
Argentina ● ●
Cameroon ● ●
Colombia ● ●
Dominican Republic ● ●
Ghana ● ●
Madagascar ● ●
Mexico ● ●
Morocco ● ●
Paraguay ● ●
Peru ● ●
Philippines ● ●
Russia ● ●
Rwanda ● ●
Senegal ● ●
South Africa ● ●
Trinidad and Tobago ● ●
Turkey ● ●
Uganda ● ●
Uruguay ● ●
Vietnam ● ●

22
Authorities in some countries in the 2019 innovators in Colombia to experiment, and the
Microscope have proposed updated data authorities have been quick to issue rules on
protection regulations but have not yet enacted relevant issues, such as regulating crowdfunding
them. Kenya’s government presented a data and allowing commercial banks to invest in
protection bill modelled on the European fintech.
Union’s General Data Protection Regulation
South Africa received the highest score on six of
in 2018, but it has not yet become law. The bill
the eight indicators, and India, Mexico, Tanzania
would also establish a data privacy enforcement
and Uruguay received the highest score on five
entity in the country. Similarly, Argentina’s
of the eight indicators.
executive branch proposed an updated data
protection law in 2018, but Congress has not Among these top performers, all countries
yet codified these changes into law. As Table 3 safeguard e-money via some sort of deposit
shows, Argentina’s data privacy agency lacks insurance or protection. This type of protection
strong capacity to enforce existing regulations. provides security to users of these new
technologies, avoids creating regulatory
In the 2019 Microscope, Colombia was the
imbalances between different types of
only country to achieve the highest score
institution, and ensures that digital financial
across all eight of these indicators. This result
inclusion does not place new consumers in the
is indicative of the level of financial consumer
financial system at a disadvantage compared
protection that users of digital financial services
with those transacting with more traditional
in Colombia receive. E-money issuers in the
institutions. Additionally, these countries
country are regulated by the same entity as
all require financial institutions to maintain
banks and must abide by the same consumer
liability for the actions of their agents, ensuring
protection regulations, and e-money deposits
that customers whose nearest access point is
receive pass-through deposit insurance. A
an agent do not receive less protection than
regulatory sandbox has allowed regulators and
customers who can visit a bank branch.

23
Box 2. Case study on Kenya’s indebtedness crisis from digital loans

As digital financial services reach more individuals and enable them to transact more rapidly, both digital financial
consumer protection and financial literacy help to ensure that challenges such as over-indebtedness and predatory
lending do not undermine gains in financial inclusion. The growth of digital loans in Kenya provides an example of how
limited oversight, the need for increased financial literacy and insufficient consumer protection have contributed to a
market that is oversaturated with lenders (estimates of the number of lenders range from 49 to more than 200).4 This
hyper-competitive market may have lowered lending standards; 2.7m Kenyans were negatively listed in credit-reporting
bureaus between 2014 and 2017, and 400,000 of them were listed for loan amounts of less than US$2.5
Kenya’s experience highlights several important lessons:
• Financial literacy and capabilities are important. Reports on the situation in Kenya note that many borrowers lack
knowledge on key topics such as the cost of borrowing.6 For example, the 2019 FinAccess Household Survey tested
individuals’ ability to correctly calculate the interest on a loan and found that 39% calculated the interest incorrectly and
17% did not know how to calculate the interest at all. Just 43% calculated the interest correctly.7
• Insufficient consumer protection for digital financial services creates opportunities for fraud, unfair pricing and over-
indebtedness. In a review of the digital loan application process, MicroSave Consulting found irregularities including
requests for applicants to upload photos of themselves, requests for large and varied amounts of information that did
not appear to have been reviewed by a regulatory body, and a lack of mechanisms to verify customers’ self-reported
income.8
• Limited oversight creates opportunities for arbitrage and market bubbles. While mobile operators and banks are
subject to regulatory oversight, fintech firms are under-regulated.9 Additionally, interest rate caps on bank loans do
not apply to digital lenders. As banks reduced loans to low-income and high-risk borrowers, digital lenders were able
to fill the gap because they were not subject to the same requirements as banks.10
Recent information from MicroSave Consulting did show an improvement in credit quality for digital loans in 2018,
with the percentage of non-performing loans decreasing from nearly 25% of loans in 2016 to 9% at the end of 2018. The
consultancy attributes this improvement to several factors, including more detailed customer data for lenders who have
spent more time in the market, improvements in credit assessment, greater customer knowledge about the consequences
of defaulting on a loan, and changes to products to make them more suitable for specific customer groups.11
4 Mutungi, Angela. 2019. “Regulate digital loans to protect consumers from preying fintechs.” Business Daily. [https://www.businessdailyafrica.com/corporate/tech/Regulate-digital-loans-to-protect-
consumers/4258474-5117010-pbs01jz/index.html]. Patascore Ltd. 2019. “Patascore is changing the face of the digital lending space in Kenya.” Medium. [https://medium.com/@hello_54610/patascore-
is-changing-the-face-of-the-digital-lending-space-in-kenya-8bda24c511a8].
5 Mustafa, Zeituna, Mercy Wachira, Vera Bersudskaya, William Nanjero and Graham A. N. White. 2017. “Where credit is due: Customer experience of digital credit in Kenya.” MicroSave. [http://www.
microsave.net/wp-content/uploads/2018/10/Where_Credit_Is_Due_Customer_Experience_of_Digital_Credit_In_Kenya.pdf].
6 Business Daily. 2019. “Alarm as easy digital loans yoke more Kenyans to debt.” [https://www.businessdailyafrica.com/datahub/Alarm-as-easy-digital-loans-yoke-more-Kenyans-to-debt/3815418-
5063014-en2bp7z/index.html].
7 FinAccess. 2019. “2019 FinAccess household survey.” [https://s3-eu-central-1.amazonaws.com/fsd-circle/wp-content/uploads/2019/04/09103904/2019-FinAcces-Report-13-06-2019.pdf].
8 Mustafa, Zeituna, Mercy Wachira, Vera Bersudskaya, William Nanjero and Graham A. N. White. 2017. “Where credit is due: Customer experience of digital credit in Kenya.” MicroSave. [http://www.
microsave.net/wp-content/uploads/2018/10/Where_Credit_Is_Due_Customer_Experience_of_Digital_Credit_In_Kenya.pdf].
9 Obiero, Olivia, and Wanjiku Kiarie. 2019. “Is there room for optimism in the Kenyan digital credit sector?” MicroSave Consulting. [https://www.microsave.net/2019/09/19/is-there-room-for-optimism-
in-the-kenyan-digital-credit-sector/].
10 Sunday, Frankline, and Macharia Kamau. 2019. “Mobile loans: The new gold rush minting billions from the poor.” Standard Digital. [https://www.standardmedia.co.ke/article/2001331308/mobile-
loans-the-new-gold-rush-minting-billions-from-the-poor].
11 Obiero, Olivia, and Wanjiku Kiarie. 2019. “Is there room for optimism in the Kenyan digital credit sector?” MicroSave Consulting. [https://www.microsave.net/2019/09/19/is-there-room-for-optimism-
in-the-kenyan-digital-credit-sector/].

24
Nearly all countries have created a Brazil’s financial education programme for
financial literacy strategy, and most adults complements the country’s cash transfer
are implementing activities to educate programme to embed capacity-building into
consumers. However, few focus on building government-to-person (G2P) delivery. Through
financial capabilities. the programme, recipients receive customised
financial education and advice using educational
Nearly all countries in the 2019 Microscope
technologies. Educational innovations—
(with the exception of Lebanon, Nicaragua,
specifically, edutainment—have also played
Venezuela and Vietnam) have a financial
a role in Cambodia’s efforts to strengthen
literacy strategy, and almost three-quarters
financial capabilities. In 2017 the central bank
are actively implementing those strategies.
and partners launched a comic book for
However, expanding on education to strengthen
young people and their families that covers
financial capabilities among consumers
topics such as negotiating, selecting and using
requires innovative approaches that go
financial products responsibly and learning
beyond pamphlets, disclosures and short
to communicate effectively with financial
training sessions. Several countries in the 2019
institutions. An initiative in Egypt also targets
Microscope are implementing leading practices,
young people, working to improve financial
based on lessons learned in financial inclusion
literacy training for them, and combining
worldwide. For example, Chile, Argentina,
education with the development of financial
the Dominican Republic and Jordan have
products tailored to the needs of the country’s
incorporated financial literacy topics into their
children and youth.
national curricula, providing opportunities to
teach students, monitor learning results and
outcomes, and adjust approaches in future
iterations in order to effectively build financial
capabilities.

25
Gender-related findings
Men and women have similar legal to microcredit. In Peru, the government collects
requirements to open accounts in all but data on women’s location and use of savings
one of the countries in the 2019 Microscope, and credit products. Mexico publishes quarterly
but few governments actively collect data financial inclusion data, including for low-
on women’s financial inclusion or include income women, and regulators in Bolivia publish
specific actions targeting women in national sex-disaggregated data on satisfaction with
strategies. financial services (in addition to more general
statistics, such as the percentage of women
The 2019 Microscope added 11 indicators to
borrowers). In Pakistan, data demonstrated that
better assess what governments are doing to
53% of the population were financially excluded
address the gender gap in financial inclusion.
in 2015, and that exclusion was higher among
According to the World Bank´s Women Business
women, only 11% of whom had access to a bank
and the Law, only one of the 55 countries
account. Supply-side data can give regulators a
included in this year’s Microscope (Cameroon)
better understanding of usage by those already
places regulatory barriers on women opening
included in the financial system. Honduras for
accounts. However, few governments take
example, collects sex-dissagregared data on the
proactive steps to reduce the gender gap in
types of products and balance levels.
account ownership specifically, and in financial
inclusion more broadly. Despite the existence of data showing that
more women are financially excluded than
Collecting data on women’s use of financial
men, only one-third of countries in the 2019
services can help governments to identify
Microscope include a gender approach in their
factors that prevent women from achieving
financial inclusion strategies, and even fewer
greater financial inclusion. At present, however,
have set clear, gender-related goals. Madagascar
just one-quarter of countries collect and publish
is one of the few countries with gender-related
comprehensive sex-disaggregated data on
goals and is currently implementing a national
demand and supply for financial products (nine
financial inclusion project that aims to reach
countries in Latin America, four in Africa and
8,000 new female microfinance customers
one in South Asia). The World Bank’s Global
and provide mobile-based financial education
Findex includes disaggregated demand-side
to 30,000 women. Mozambique’s financial
data, but countries that collect their own
inclusion strategy sets targets for increasing
demand-side data can understand both
women’s access to savings, credit and e-money
women’s and men’s use of financial services
accounts by 2022. Pakistan aims to increase the
in greater detail. For example, since 2018
number of women-owned digital accounts to
Colombia has collected detailed information on
20m (although this is still less than one-third of
microloans (including loan amounts, enabling
the total), and a public-private agreement in
it to determine that women have loans for
South Africa aims to increase black women’s
smaller amounts than men), and it is currently
participation in the financial sector.
studying strategies to improve women’s access

26
Box 3. Good practices from Chile

Chile is one of the 14 countries in the 2019 Microscope that collects sex-disaggregated data on
financial services for low-income populations, and it is the only country in the world to have
continuously collected and published such data since 2002. A 2016 case study12 documented
how Chile began to collect this data and identified lessons learned during this process. The
case study reports that the collection of sex-disaggregated data on the use of financial
services began in the early 2000s as the result of a concerted effort by Chile’s national
government to insert gender issues into the agenda throughout government agencies.
Early in this process, policymakers identified the disaggregation of data sets as a priority
in order to inform public policy decisions and facilitate the monitoring of gender goals. The
government integrated this gender approach into its existing performance management
programme, and by 2005 gender goals had become part of the performance system
used to incentivise government employees. Crucially, the financial regulator decided to
concentrate responsibility for collecting sex-disaggregated data in a single unit, and to
publish an annual report that highlights women’s role and presence in the financial system.
This has contributed to a virtuous cycle in which growing amounts of data on women’s use
of financial services drive policymakers and others to ask more questions, and to collect
more data. The desire for sex-disaggregated data has spilled over into the co-operative
sector, and even the banking association has started to separate women and men in data it
collects on customer satisfaction.
As the 2019 Microscope documents, simply collecting data is not sufficient to increase
women’s financial inclusion. Data collection in Chile for example has not let to a reduction in
the gender gap which, according to the Global Findex actually saw an increase in its gender
gap between 2011 and 2017 from 2% to 6%. Although 14 countries in the index publish data on
women’s use of financial services, very few have included clear, gender-related goals in their
financial inclusion strategies.
12 Data2X. 2019. “Catalysing inclusive financial systems: Chile’s commitment to women’s data.” [https://data2x.org/wp-content/uploads/2019/05/Chile-
Case-study_English_Final.pdf].

27
Practical impediments—such as access innovations, even as many national regulators

to ID, the Internet and mobile phones— seek to spur their development and adoption.
limit women’s ability to take advantage
Data from the 2019 Microscope and the Global
of growing digital channels for financial
Findex show that women’s access to national ID
inclusion.
and mobile phones can affect the gender gap in
According to Women, Business and the Law account ownership. In countries where women
the requirements for obtaining a national ID have better or similar access to ID than men,
differ for women and men in five countries in the average gender gap in account ownership
the 2019 Microscope: Cameroon, Egypt, Haiti, is 8%, compared with an average of 10% for all
Pakistan and Tunisia. In addition, data from countries in the Findex. When women have
the UN World Population Prospects, shows better or similar access to mobile phones
that in 21 countries, men have better access to than men, the average gender gap in account
national ID than women. All countries in the ownership is 6%. Furthermore, in countries
Microscope require ID to open an account, and where women have better access to mobile
reduced access to national ID in countries such phones, the average gender gap in account
as Madagascar, Myanmar, Pakistan, Ethiopia ownership has fallen by 1% since 2011, compared
and Mexico serves as a de facto barrier to with an overall average increase of 1% across all
account opening for women. Women’s access countries.
to national ID exceeded men’s in just nine
Most countries need to achieve greater
countries, including five in Latin America and
gender balance in top decision-making
the Caribbean (Haiti, Guatemala, Colombia, El
positions at financial-sector regulators.
Salvador and Panama).
In 37 of the 2019 Microscope’s 55 countries,
The de facto barriers that impede women’s
women accounted for less than 25% of decision-
access to digital financial services are even
makers at financial regulators. Women held
greater. Men have better access to the Internet
more than half of these decision-making
than women in three-quarters of the countries
positions in just one country in the index:
in the index (41 of 55), while women have
Bolivia (where the national parliament also
better access than men in just four countries
has a female majority).13 The data on women
(the Philippines, China, Argentina and Jordan).
leaders in financial-sector regulators mirrors
Without sufficient access to the Internet,
data from the private sector. According to a 2016
women lose access to digital financial channels;
study by Oliver Wyman (a consultancy), women
these channels can reduce the financial and
accounted for just 20% of the membership of
physical transaction costs associated with
financial service boards of directors, and just
accessing the financial system. Women’s access
16% of executive committee members.14 The
to mobile phones is only slightly better than
same study noted that at current growth rates,
men’s: men have better access than women in
executive committees would not achieve 30%
34 countries, while women have better access
female representation until 2048.
than men in just three countries (Argentina,
Brazil and South Africa). As the technology
of choice for accessing e-money and mobile 13 Escudero, Irene, Carlos Heras, and Alice Campaignolle. 2018. “Las mujeres
bolivianas que ponen cara a la política.” El País. [https://elpais.com/
wallets, women’s reduced access to mobile elpais/2018/01/11/planeta_futuro/1515674514_106471.html].
phones limits their ability to access these 14 Oliver Wyman. 2016. “Women in financial services 2016.” [https://www.
oliverwyman.com/our-expertise/insights/2016/jun/women-in-financial-
services-2016.html].

28
A 2018 study by the International Monetary Fund

(IMF) noted that “women are underrepresented
at all levels of the global financial system,
from depositors and borrowers to bank board
members and regulators.”15 Corroborating the
2016 Oliver Wyman study, the IMF found that
fewer than 2% of CEOs at financial institutions
and less than 20% of executive board members
were women. The study provides a convincing
argument for increasing diversity in general,
and for increasing the proportion of women
in leadership roles at financial institutions
and regulators in particular. After controlling
for specific factors related to countries and
institutions, the study found that both the
presence of women as employees in banks and
a higher proportion of women serving on banks’
boards were associated with improved financial
resilience. For regulators, a higher proportion
of women on the boards of bank supervision
agencies was associated with increased bank
stability. The IMF study posits four possible
explanations for these associations: women
may be better risk managers than men,
discriminatory hiring practices could result
in only exceptionally well-qualified women
reaching regulatory boards, more women on
boards could promote increased diversity of
thought, and regulators that choose to hire
women for top decision-making positions may
be better managed.
The IMF’s findings have important implications

for the data collected as part of the 2019
Microscope. The Microscope showed that
women hold higher proportions of top decision-
making positions at financial-sector regulators
in Bolivia, Colombia, Ghana, Morocco, Peru,
Rwanda and Uruguay, among others, compared
with other countries.
15 Sahay, Ratna, and Martin Cihak. 2018. “Women in finance: A case for closing
gaps.” IMF. [https://www.imf.org/en/Publications/Staff-Discussion-Notes/
Issues/2018/09/17/women-in-finance-a-case-for-closing-gaps-45136].

29
Country summaries
Argentina 30 Mexico 58
Bangladesh 31 Morocco 59
Bolivia 32 Mozambique 60
Brazil 33 Myanmar 61
Cambodia 34 Nepal 62
Cameroon 35 Nicaragua 63
Chile 36 Nigeria 64
China 37 Pakistan 65
Colombia 38 Panama 66
Costa Rica 39 Paraguay 67
Côte d’Ivoire 40 Peru 68
Democratic Republic of Congo (DRC) 41 Philippines 69
Dominican Republic 42 Russia 70
Ecuador 43 Rwanda 71
Egypt 44 Senegal 72
El Salvador 45 Sierra Leone 73
Ethiopia 46 South Africa 74
Ghana 47 Sri Lanka 75
Guatemala 48 Tanzania 76
Haiti 49 Thailand 77
Honduras 50 Trinidad and Tobago 78
India 51 Tunisia 79
Indonesia 52 Turkey 80
Jamaica 53 Uganda 81
Jordan 54 Uruguay 82
Kenya 55 Venezuela 83
Lebanon 56 Vietnam 84
Madagascar 57

30
Argentina
Overview: In July 2017 the government of 1.

Government
Argentina created a Financial Inclusion Co- and policy support Argentina
Average
ordinating Committee under the Ministry of 100
Finance. In May 2018 Congress approved the 75
Productive Financing Law (No. 27440), which
50
2.
requires the government to create a financial 5. Stability
Infrastructure 25
and integrity
inclusion strategy.
0
Highlights: In November 2018 the Central Bank

issued regulations permitting the creation of
agent networks, which previous editions of the
4. 3.
Global Microscope had identified as one of the Consumer Products
protection and outlets
main areas for improvement. The Financial
Inclusion Co-ordinating Committee issued a
draft National Financial Inclusion Strategy for
public comment in April 2019.
Summary of Argentina’s performance
Category Score Rank Average score
Overall score 70 =7 52
1 Government and policy support 79 7 54
2 Stability and integrity 73 16 65
3 Products and outlets 70 =13 57
4 Consumer protection 83 7 60
5 Infrastructure 87 1 59
Argentina: strengths Argentina: areas for improvement
Indicator Rank Indicator Rank

Credit portfolios for middle- and low-
2.3 Customer due diligence =1 3.2 =43
income customers
3.4 Inclusive insurance =1 2.5 Commitment to cyber-security =31
Financial outlets (agents, merchants and
3.5 =1 3.3 Emerging services =11
electronic channels)

31
Bangladesh
Overview: The financial inclusion department 1.

Government
of the Bangladesh Bank oversees financial and policy support Bangladesh
Average
inclusion policy and has established a working 100
group to support the formulation of a national 75
financial inclusion strategy. The final draft of this
50
2.
strategy was submitted to the cabinet in 2019, 5. Stability
Infrastructure 25
and integrity
with an approved implementation period of
0
2019-24. However, as of June 2019 this strategy
had not yet been finalised.
Highlights: In 2019 the Bangladesh Post Office

4. 3.
launched a new mobile money service called Consumer Products
Nagad, in partnership with a private operator. In
addition to standard features (such as cash in/
cash out), Nagad allows individuals to sign up via
the digital Know Your Customer (KYC) system,
using a national identity card. This should help
to promote the adoption of financial services
within low-income segments of the population.
Summary of Bangladesh’s performance
Overall score 38 46 52
2 Stability and integrity 62 =29 65
5 Infrastructure 48 =42 59
Bangladesh: strengths Bangladesh: areas for improvement

3.2 =1 4.2 Inclusive insurance users =42
income customers
3.5 =1 3.4 Inclusive insurance =25
4.1 Financial services users =10 3.3 Emerging services =31

32
Bolivia
Overview: In 2013 Bolivia implemented the 1.

Government
Financial Services Law (FSL), which includes and policy support Bolivia
Average
provisions for increasing financial inclusion, 100
particularly by directly lending to certain sectors. 75

The FSL created the Committee on Financial 50
2.
Stability (CFS), which has members from 5.
25
Stability
Infrastructure and integrity
various government agencies. This committee is 0
responsible for monitoring financial stability and
issuing policy to promote the use of financial
services that serve all sections of society,
including the poor. 4. 3.
Consumer Products
Highlights: Use of financial services continues
to grow. The Supervising Authority of Financial
Institutions (ASFI) reported in June 2019 that
deposits grew by 3% and outstanding credits
grew by almost 11% year on year. The ASFI also
introduced a new travelling fair to promote
financial literacy, called Digital Financial City
(Ciudad Digital Financiera).
Summary of Bolivia’s performance
1 Government and policy support 41 =40 54
3 Products and outlets 100 1 57
Bolivia: strengths Bolivia: areas for improvement

Accounts at financial institutions and Incentives for digitisation and emerging
3.1 =1 1.3 54
e-money technologies
3.2 =1 2.5 Commitment to cyber-security =49
income customers
3.3 Emerging services =1 4.3 Data privacy and cybercrime protection =46

33
Brazil
Overview: Brazil established the National 1.

Government
Partnership for Financial Inclusion in 2012 and and policy support Brazil
Average
publishes annual reports on the partnership’s 100
goals. Brazil’s enabling environment for 75
financial inclusion has been strengthened by
50
2.
its extensive financial agent network, enabled 5. Stability
Infrastructure 25
and integrity
by proportionate regulations; its dedication to
0
advancing and maintaining the prevalence of
digital transactions and financial technology;
and its commitment to financial literacy.
4. 3.
Highlights: In 2019 the Central Bank of Brazil Consumer Products
launched Agenda BC#, a work agenda focused
on technological evolution to resolve structural
issues in the financial system. Inclusion is now
one of the four dimensions of Agenda BC#,
along with competitiveness, transparency and
education. Brazil’s overarching goal is to make it
easier for everybody—small and large companies,
investors and borrowers, Brazilian citizens and
foreigners—to access the financial market.
Summary of Brazil’s performance
4 Consumer protection 71 =23 60
Brazil: strengths Brazil: areas for improvement

Accounts at financial institutions and
3.1 =1 2.4 Supervisory capacity =34
e-money
income customers
3.4 Inclusive insurance =1 4.1 Financial services users =40

34
Cambodia
Overview: Cambodia has a strategy to 1.

Government
promote financial-sector development but it and policy support Cambodia
Average
has not established specific financial inclusion 100
goals. The Financial Sector Development 75

Strategy (FSDS) has a section on microfinance 50
2.
that broadly covers financial inclusion. The 5.
25
Stability
government is currently working on framing a 0
financial inclusion strategy, and the National
Bank of Cambodia is working to promote
digital transformation in the financial services
sector. However, there is no evidence of a 4. 3.
Consumer Products
comprehensive strategy to achieve this. protection and outlets
Highlights: Banks and other financial

institutions have continued to expand their
outreach to the rural population. Initiatives to
promote digital literacy will continue, such as
the New Generation Schools (NGS) project,
which aims to improve the standard of schools
in co-operation with Microsoft.
Summary of Cambodia’s performance

Cambodia: strengths Cambodia: areas for improvement

2.1 Market entry =1 4.2 Inclusive insurance users =42
2.2 Ongoing requirements =11 3.4 Inclusive insurance =25
Incentives for digitisation and emerging
1.3 28 4.3 Data privacy and cybercrime protection =53
technologies

35
Cameroon
Overview: Cameroon continues to work on 1.

Government
developing its national strategy for financial and policy support Cameroon
Average
inclusion. With support from the French 100
government, the government of Cameroon has 75
commissioned two studies during the past year
50
2.
on financial services demand and supply among 5. Stability
Infrastructure 25
and integrity
the underserved.
0
Highlights: Banks, non-bank financial

institutions, e-money issuers and agents have
continued to expand their services to the
4. 3.
low-income population, especially in rural Consumer Products
and remote areas (although these efforts
have been affected by conflict in parts of the
country). Programmes to promote digital
literacy continue, such as the E-National Higher
Education Network Project and the Connect My
School Project.
Summary of Cameroon’s performance

Cameroon: strengths Cameroon: areas for improvement

Credit portfolios for middle and low- Incentives for digitisation and emerging
3.2 =1 1.3 52
income customers technologies
3.4 Inclusive insurance =1 3.3 Emerging services =31
4.2 Inclusive Insurance users =1 2.4 Supervisory capacity 25

36
Chile
Overview: In 2014 the government of Chile 1.

Government
created the Commission for Financial Inclusion, and policy support Chile
Average
but it has not yet developed a comprehensive 100
financial inclusion strategy. However, the 75

country has developed a comprehensive, sex- 50
2.
disaggregated database on financial services 5.
25
Stability
supply and demand, and this data is regularly 0
published in government reports (e.g. “Financial
Inclusion: Progress and Pending Challenges”).
In 2018 the commission presented the National
Strategy for Financial Education, which aims to 4. 3.
Consumer Products
boost access to financial services by promoting protection and outlets
well-informed decisions and co-ordination
among actors in the sector.
that it will present a fintech bill to Congress,
Highlights: In 2019 the Financial Markets proposing regulation for emerging forms of
Commission (CMF) became the unified financial technology. In January 2019 the new
regulator of the financial industry. It now Law to Modernise Banking Legislation began to
supervises over 70% of Chile’s financial activities. gradually take effect, aligning the banking sector
In April 2019 the Ministry of Finance announced with Basel III standards.
Summary of Chile’s performance

Chile: strengths Bolivia: areas for improvement

1.2 Promotion of literacy and capability =1 3.4 Inclusive insurance =25
4.2 Inclusive insurance users =1 1.3 45
technologies
4.1 Financial services users =3 4.3 Data privacy and cybercrime protection 36

37
China
Overview: China has a comprehensive and 1.

Government
co-ordinated strategy to promote financial and policy support China
Average
inclusion, reflected in the Plan for Promoting 100
the Development of Financial Inclusion (2016- 75
20). The strategy includes a forward-looking
50
2.
digital approach, as the country continues to 5. Stability
Infrastructure 25
and integrity
see new financial technology innovations as key
0
drivers of inclusion. China has made important
strides towards promoting greater competition
in the market. In 2018 it opened its payments
market, allowing foreign players to access its 4. 3.
Consumer Products
online payments and settlement system. This protection and outlets
has enabled qualifying institutions to provide
domestic and cross-border transaction services.
Highlights: The People’s Bank of China has them. The Fintech Committee has also stressed
mandated that non-bank payment companies the importance of strengthening guidance for
place 100% of their customer deposit funds in innovation and increasing regulation of fintech
centralised, interest-free accounts to protect companies to reduce financial risk.
Summary of China’s performance

China: strengths China: areas for improvement

2.3 Customer due diligence =1 2.4 Supervisory capacity =37
3.2 =1 1.1 Broad strategies for financial inclusion =31
income customers
3.3 Emerging services =1 4.3 Data privacy and cybercrime protection 39

38
Colombia
Overview: The government of Colombia 1.

Government
has been implementing its National Financial and policy support Colombia
Average
Inclusion Strategy since July 2014 via an inter- 100
institutional committee. This committee is 75

composed of key ministries that interact with 50
2.
the private sector. The strategy has primarily 5.
25
Stability
focused on increasing people’s access to the 0
banking system and their use of financial
products, and on enhancing financial literacy.
Highlights: Digital transformation has become

4. 3.
a key consideration in recent financial inclusion Consumer Products
efforts. A law passed in May 2019 formally
adopted a sandbox regulatory approach, adding
to prior regulations passed in July and December
2018 to facilitate crowdfunding and banks’
investments in fintech, respectively.
Summary of Colombia’s performance
Colombia: strengths Colombia: areas for improvement

1.1 Broad strategies for financial inclusion =1 2.5 Commitment to cyber-security 20
2.3 Customer due diligence =1 5.1 Payments infrastructure =18
3.1 =1 5.3 Connectivity 18
e-money

39
Costa Rica
Overview: In April 2019 the president, Carlos 1.

Government
Alvarado, launched a plan to promote financial and policy support Costa Rica
Average
inclusion via the state-owned banking system 100
(banca estatal). The plan aims to increase 75

access to banks by reducing transaction costs 50
2.
and encouraging individuals and microfinance 5.
25
Stability
institutions (MFIs) to create new accounts. The 0
strategy intends to increase financial inclusion
by over 6% over a four-year period, requiring
co-ordination between the Costa Rica National
Bank, the Ministry of Finance, the Popular Bank 4. 3.
Consumer Products
and the Community Development Bank. protection and outlets
Highlights: In January 2019 the government

launched a national financial education strategy, the most indebted segments of the population.
in collaboration with the private sector. The Other relevant efforts include the introduction
strategy includes a gender approach, and one of of simplified bank accounts in 2015 and the
the plan’s main actions targets women—one of launch of electronic wallets in 2019.
Summary of Costa Rica’s performance
Costa Rica: strengths Costa Rica: areas for improvement

Credit portfolios for middle and low-
3.4 Inclusive insurance =1 3.2 =43
income customers
3.5 =1 1.1 Broad strategies for financial inclusion =46
4.2 Inclusive insurance users =1 3.3 Emerging services =31

40
Côte d’Ivoire
Overview: In 2016 the West African Monetary 1.

Gobierno y apoyo
Unit’s (WEAMU) Council of Ministers adopted de políticas Costa de Marfil
Promedio
a regional financial inclusion strategy, and the 100
Ivorian government adopted a Financial Sector 75
Development Strategy (FSDS) to strengthen
50
2.
the stability of financial services and promote 5. Estabilidad
Infraestructura 25
e integridad
development of the sector. The government has
0
also taken steps to digitise payments, creating
public service payment platforms and digitising
school fees.
4. 3.
Highlights: In May 2018 the Agency for the Protección del Productos y puntos
consumidor de venta
Promotion of Financial Inclusion (APIF) was
created to lead the implementation of the
financial inclusion strategy. In May 2019 the
country adopted the first five-year financial
inclusion national strategy for the period 2019-24.
Summary of Cote d’Ivoire’s performance

Cote d’Ivoire: strengths Cote d’Ivoire: areas for improvement

3.4 Inclusive insurance =1 4.2 Inclusive insurance users =42
2.1 Market entry 27 3.3 Emerging services =31
2.2 Ongoing requirements =23 3.2 =50
income customers

41
Democratic Republic of Congo (DRC)
Overview: Under the former president, Joseph Democratic Republic

of Congo (DRC)
Kabila, the DRC launched the Roadmap to 1. Average
Financial Inclusion 2016-2021. In this plan, Government
and policy support
the government pledged to partner with 100
selected financial service providers, industry 75
associations, development agencies and donors 50
2.
to promote financial inclusion. The DRC also 5. Stability
Infrastructure 25
and integrity
has a National Strategy for Microfinance, which
0
was drafted in 2008. However, in 2016 the
Banque Central du Congo (BCC) reported that
microfinance activities had been negatively
affected by economic, political and security 4. 3.
Consumer Products
instability in the country. protection and outlets
Highlights: Political instability, persistent

security and public health challenges
(particularly in the eastern part of the DRC) and
poor infrastructure have hindered the Central
Bank’s microfinance activities and limited
progress in implementing the government’s
Roadmap to Financial Inclusion 2016-21.
Summary of DRC’s performance
DRC: strengths DRC: areas for improvement

Credit information and other data-sharing
systems
3.5 =39 4.3 Data privacy and cybercrime protection =39
2.2 Ongoing requirements =42 4.2 Inclusive insurance users =42

42
Dominican Republic
Overview: Improving financial inclusion is part 1.

Government
of a national strategy, and the government has and policy support Dominican
Republic
launched initiatives to expand credit, including 100 Average
cash transfer financing programmes. The 75
agent banking network is well established, and 50
2.
mobile payments are widely used by financial 5.
25
Stability
and microfinance institutions. Microfinance 0
regulations were passed in 2014. The Banco
Central de la República Dominicana (BCRD, the
central bank) has implemented financial literacy
programmes and a survey of financial culture. 4. 3.
Consumer Products
Highlights: In 2019 the BCRD launched a
“virtual classroom” to expand knowledge of
the country’s payments systems and other payments. Expansive monetary policy measures
financial concepts. It also passed cyber-security implemented in the past year have promoted
regulations that apply to all financial institutions credit growth, extending subsidised lending to
and has started to draft fintech regulations, manufacturing, agriculture and commerce, as
empowering an internal team to collaborate well as small and medium-sized enterprises,
with the private sector to promote digital consumers and low-income housing.
Summary of Dominican Republic’s performance

Dominican Republic: strengths Dominican Republic: areas for improvement

Financial outlets (agents, merchants, and
3.5 =26 2.2 Ongoing requirements =51
electronic outlets)
4.3 Data privacy and cybercrime protections =13 2.4 Supervisory capacity =30
4.1 Financial services users =10 3.4 Inclusive insurance =29

43
Ecuador
Overview: Ecuador does not have a financial 1.

Government
inclusion strategy or an official working and policy support Ecuador
Average
committee, and organisations in the private and 100
social sectors continue to push for a national 75
focus on financial inclusion. Non-bank financial
50
2.
institutions in the “popular and solidarity” sector 5. Stability
Infrastructure 25
and integrity
serve low-income populations, but there has
0
been a moratorium on creating new savings and
loan co-operatives in the sector since 2015, amid
concerns about solvency at some institutions.
4. 3.
Highlights: In June 2019 the Central Bank of Consumer Products
Ecuador announced that it is working with the
World Bank on a year-long technical assistance
programme to create and implement a national
financial inclusion strategy. Regulations
authorising banks to offer mobile wallets are
expected this year.
Summary of Ecuador’s performance

Ecuador: strengths Ecuador: areas for improvement

e-money
2.3 Customer due diligence =1 3.3 Emerging services =31
3.2 =1 2.4 Supervisory capacity 49
income customers

44
Egypt
Overview: In 2017 the government of Egypt 1.

Government
launched the Sustainable Development Strategy and policy support Egypt
Average
(SDS, “Egypt’s Vision 2030”), in which financial 100
inclusion is the main priority. The Central Bank 75

of Egypt also established a Financial Inclusion 50
2.
Unit. An independent central administration 5.
25
Stability
(the National Council for Payments) was 0
established by decree in 2017 to protect
consumers of financial services and begin the
move towards a cashless economy.
4. 3.
Highlights: Following approval by the Egyptian Consumer Products
parliament, the Electronic Payments Act came
into effect in June 2019. This law, drafted by the
Central Bank of Egypt, provides legal recognition
of e-money. It also requires government and
private-sector entities to make all payments
to subsidiaries, suppliers and contractors
electronically.
Summary of Egypt’s performance

Egypt: strengths Egypt: areas for improvement

3.4 Inclusive insurance =1 1.1 Broad strategies for financial inclusion =50
3.5 =1 5.2 Digital IDs 54
2.5 Commitment to cyber-security 2 4.1 Financial services users =53

45
El Salvador
Overview: In 2015 the government of El 1.

Government
Salvador passed the Law to Facilitate Financial and policy support El Salvador
Average
Inclusion. Subsequent efforts—undertaken 100
in co-ordination with public, private and 75
international actors—have expanded access to
50
2.
financial services through the introduction of 5. Stability
Infrastructure 25
and integrity
e-money providers, electronic wage payments
0
and larger agent networks.
Highlights: In January 2019 the Supreme

Court of El Salvador declared that the tax on
4. 3.
financial transactions greater than US$1,000 Consumer Products
was unconstitutional (previously authorised
by the Law of Tax on Financial Transactions
No. 764/2016). The use of electronic financial
services is growing, and in 2018 DaviPlata
introduced the first completely online/mobile
savings account in El Salvador, allowing users to
open and control accounts remotely.
Summary of El Salvador’s performance

El Salvador: strengths El Salvador: areas for improvement

1.2 Promotion of literacy and capability =1 3.4 Inclusive insurance =25
3.5 =1 2.5 Commitment to cyber-security =51
2.1 Market entry 19 4.3 Data privacy and cybercrime protection =29

46
Ethiopia
Overview: Ethiopia’s first National Financial 1.

Government
Inclusion Strategy was published in 2017. The and policy support Ethiopia
Average
prime minister, Abiy Ahmed, has been pushing 100
for economic reform and to open the financial 75

sector to foreign investment since he took office 50
2.
in April 2018. The state’s financial regulator (the 5.
25
Stability
National Bank of Ethiopia) is in the process of 0
reviewing its directives and identifying areas in
need of improvement, including digital banking,
which is significantly underdeveloped.
4. 3.
Highlights: The Central Bank of Ethiopia Consumer Products
announced the opening of an all-female branch
in Addis Ababa in April 2019. In the same month,
the United Nations secretary-general’s special
advocate for inclusive finance for development
visited the country and highlighted the need to
unlock economic opportunities for poor women
and rural communities. The government agreed
in June 2019 to end Ethio Telecom’s monopoly
of the telecommunications sector and grant
licences to foreign operators by the end of 2019.
Summary of Ethiopia’s performance
Ethiopia: strengths Ethiopia: areas for improvement

1.2 Promotion of literacy and capability =5 5.2 Digital IDs 55
3.5 =26 5.1 Payments infrastructure =52

47
Ghana
Overview: Ghana’s much anticipated Financial 1.

Government
Inclusion and Development Strategy came into and policy support Ghana
Average
effect in July 2019 and will drive efforts until 100
2023 in five key areas: financial stability; access, 75
quality and use of financial services; financial
50
2.
infrastructure; financial consumer protection; 5. Stability
Infrastructure 25
and integrity
and financial capability.
0
Highlights: Along with a clearly articulated

financial inclusion strategy, the passage of the
National Payments Systems and Services Act
4. 3.
in March 2019 brings regulation up to date with Consumer Products
the increasingly electronic environment and
is expected to support continued growth in
electronic payments in Ghana. Interoperability A second phase, launched at the end of 2018,
has improved significantly since the country’s will complete the financial inclusion triangle by
first Mobile Money Interoperability System allowing the movement of money between and
was launched in May 2018, through the Ghana among telecommunications companies, banks
Interbank Payment and Settlement Systems. and e-zwich accounts.
Summary of Ghana’s performance

Ghana: strengths Ghana: areas for improvement

2.3 Customer due diligence =1 4.2 Inclusive insurance users 42
e-money

48
Guatemala
Overview: The Superintendence of Banks (SIB) 1.

Government
and the Banco de Guatemala (Banguat, the and policy support Guatemala
Average
central bank) have been working on a national 100
financial inclusion strategy since 2017 and are 75

due to launch it soon. In April 2019 the Monetary 50
2.
Board ( Junta Monetaria) formally announced 5.
25
Stability
the establishment of the Commission on 0
Financial Inclusion.
Highlights: In July 2019 the SIB announced

the launch of the Unit of Innovation and
4. 3.
Development (UNIDE), which is co-ordinated Consumer Products
through the SIB Innovation Hub. The hub will act
as a regulatory sandbox for fintech companies
and will liaise between the government and
start-ups to identify trends in the market, study
new business models and develop appropriate
regulatory frameworks.
Summary of Guatemala’s performance
Guatemala: strengths Guatemala: areas for improvement

2.1 Market entry 30 3.3 Emerging services =31
2.3 Customer due diligence =25 4.3 Data privacy and cybercrime protection 52

49
Haiti
Overview: Haiti approved a national inclusion 1.

Government
document in 2015 (the Projet de Stratégie and policy support Haiti
Average
Nationale d’Inclusion Financière), outlining 100
short-, medium- and long-term implementation 75
plans, in conjunction with financial institutions,
50
2.
the private sector, government and civil society. 5. Stability
Infrastructure 25
and integrity
Highlights: In April 2019 the United States 0
Agency for International Development (USAID)

published the FinScope Consumer Survey, in
collaboration with the Banque de la République
4. 3.
d’Haiti (BRH) and other partners. Agent banking Consumer Products
networks have expanded, and the BRH hosted
a fintech seminar in May 2019, reiterating the
important role digital financial services will play
in deepening financial inclusion in the country.
Summary of Haiti’s performance
Haiti: strengths Haiti: areas for improvement

income customers
3.5 =1 2.5 Commitment to cyber-security 54
2.3 Customer due diligence =25 5.1 Payments infrastructure 52

50
Honduras
Overview: Honduras launched its financial 1.

Government
inclusion strategy in 2015. As part of this and policy support Honduras
Average
strategy, regulations for e-money have been 100
issued (via Central Bank of Honduras Agreement 75

No. 1/2016) and new financial education 50
2.
programmes have been launched. However, 5.
25
Stability
the decision to leave implementation of the 0
strategy to a special office in the executive
branch, instead of more established institutions
or regulators, has made its co-ordination more
difficult. 4. 3.
Consumer Products
Highlights: In February 2019 the National
Banking and Insurance Commission created
the Fintech and Technological Innovation
Committee to promote regulatory innovation
aimed at financial inclusion. Despite issuing
e-money regulations in 2016, the main
provider—which is active in the market—has not
completed the licensing process.
Summary of Honduras’s performance

Honduras: strengths Honduras: areas for improvement

income customers
4.2 Inclusive insurance users =1 4.3 Data privacy and cybercrime protection =42

51
India
Overview: The Reserve Bank of India (RBI) has 1.

Government
prepared a draft National Strategy for Financial and policy support India
Average
Inclusion to deepen financial services’ coverage 100
in the country. The long-awaited strategy is 75
expected to be finalised in 2019 and will cover a
50
2.
five-year period. 5. Stability
Infrastructure 25
and integrity
Highlights: The RBI set up a high-level 0
committee to review the existing status of

digitisation and devise a medium-term strategy
for increasing digital payments. In August 2019
4. 3.
the RBI released the Enabling Framework for Consumer Products
Regulatory Sandbox (RS), which creates the
basis for a regulatory sandbox that will allow
fintech start-ups to live-test innovative products
and services.
Summary of India’s performance
India: strengths India: areas for improvement

2.3 Customer due diligence =1 2.4 Supervisory capacity =29
3.2 =1 5.3 Connectivity =45
income customers
3.3 Emerging services =1 1.1 Broad strategies for financial inclusion =19

52
Indonesia
Overview: Indonesia launched the revised 1.

Government
National Strategy for Inclusive Finance (SNKI) and policy support Indonesia
Average
in 2016. To facilitate effective implementation, 100
a National Council of Inclusive Finance was 75

established, chaired by the president of 50
2.
Indonesia. The strategy promotes financial 5.
25
Stability
literacy and has a gender focus. 0
Highlights: The Financial Services Authority

(OJK) issued regulations on digital innovation in
financial services in 2018. Since 2018 users have
4. 3.
been able to access borrowers’ information Consumer Products
through a Debtor Information System (SID) by
visiting the OJK’s offices. Indonesia has adequate
regulations on customer protection, and these
regulations specify standards for complaint
resolution for the financial services sector.
Summary of Indonesia’s performance
Indonesia: strengths Indonesia: areas for improvement

2.3 Customer due diligence =1 1.1 Broad strategies for financial inclusion =31
3.3 Emerging services =1 4.3 Data privacy and cybercrime protection 19
3.4 Inclusive insurance =1 5.4 =25
systems

53
Jamaica
Overview: Jamaica’s Financial Inclusion 1.

Government
Strategy of 2016-20 made financial inclusion a and policy support Jamaica
Average
priority through the creation of the National 100
Financial Inclusion Council, in collaboration with 75
various public- and private-sector actors. The
50
2.
2014 Banking Services Act, the 2016 Banking 5. Stability
Infrastructure 25
and integrity
Services Regulations and the 2013 Consumer
0
Protection (Amendment) Act provide the main
regulatory thrust behind financial inclusion in
Jamaica. The government has implemented a
regulatory sandbox framework to support the 4. 3.
Consumer Products
financial technology payment system, enabling protection and outlets
the development of financial technology that
can help to extend access to financial services to
low- and middle-income populations.
Highlights: Over the past year the Data providing comprehensive legal frameworks
Protection Act and Microcredit Act have both for data protection and microcredit. There are
been tabled as bills in parliament. If enacted also ongoing developments in fintech, with the
in their current form, they would represent central bank supporting the regulatory sandbox
major progress towards financial inclusion, framework.
Summary of Jamaica’s performance

Jamaica: strengths Jamaica: areas for improvement

2.1 Market entry =1 4.2 Inclusive insurance users 42

54
Jordan
Overview: The Central Bank of Jordan (the 1.

Government
country’s primary financial regulatory body) and policy support Jordan
Average
issued the National Financial Inclusion Strategy 100
2018-20 in December 2017. There is evidence 75

that this strategy is being implemented, with 50
2.
Jordan constantly issuing new regulations and 5.
25
Stability
laws in line with the strategy’s goals. 0
Highlights: This year the United Nations

(UN) communicated its readiness to support
Jordan’s financial inclusion plans. This major
4. 3.
development occurred following a visit by Consumer Products
Queen Maxima of the Netherlands, in her
capacity as the UN secretary-general’s special
advocate for inclusive finance.
Summary of Jordan’s performance
Jordan: strengths Jordan: areas for improvement

Credit portfolios for low- income
customers
4.2 Inclusive insurance users =1 3.4 Inclusive insurance =25

55
Kenya
Overview: Kenya’s parliament is currently 1.

Government
considering the draft Financial Markets Conduct and policy support Kenya
Average
Bill, which would regulate non-cash payments 100
and restrict predatory lending by fintech 75
companies—a major issue in recent years.
50
2.
The Central Bank of Kenya has also proposed 5. Stability
Infrastructure 25
and integrity
establishing a new regulator (the Financial
0
Markets Conduct Authority) to oversee fintech
companies.
Highlights: A number of bills that will affect

4. 3.
the provision of financial services were drafted Consumer Products
in 2018 and are currently under discussion. The
2018 Data Protection Bill would protect personal
financial information. The 2018 Microinsurance and introduce index-based insurance. Lastly, the
Regulations and the 2018 Insurance draft 2018 Microfinance (Amendment) Bill would
(Amendment) Bill would define microinsurance update the framework for microfinance for the
as a policy available to low-income populations first time since 2008.
Summary of Kenya’s performance

Kenya: strengths Kenya: areas for improvement

e-money
2.1 Market entry =1 3.2 =43
income customers

56
Lebanon
Overview: In 2017 the Banque Du Liban 1.

Government
(BDL, the primary financial regulatory body and policy support Lebanon
Average
in Lebanon) created a financial inclusion 100
strategy. However, there is very little evidence 75

of active implementation or updates, and 50
2.
the non-banking financial institutions (NBFI) 5.
25
Stability
sector remains largely unregulated, despite the 0
strategy calling for the creation of a regulatory
body.
Highlights: Progress has been slow this year in

4. 3.
Lebanon. However, there is movement towards Consumer Products
an official launch of the BDL’s crypto-currency,
which would potentially be used to facilitate
local payments.
Summary of Lebanon’s performance
Lebanon: strengths Lebanon: areas for improvement

3.3 Emerging services =1 3.4 Inclusive insurance =25
4.2 Inclusive insurance =1 4.3 Data privacy and cyberprotection =48
5.2 Digital IDs =10 1.2 Promotion of literacy and capability =45

57
Madagascar
Overview: In 2014 the government of 1.

Government
Madagascar transformed the existing and policy support Madagascar
Average
microfinance agency under the Ministry of 100
Finance into the National Coordination for 75
Financial Inclusion. As part of the country’s first
50
2.
National Financial Inclusion Strategy (2013-17), 5. Stability
Infrastructure 25
and integrity
the Making Access Possible (MAP) process was
0
launched, and a FinScope Consumer Survey was
conducted in 2015.
Highlights: In November 2018 the government

4. 3.
of Madagascar adopted a National Financial Consumer Products
Inclusion Strategy for 2018-22, which includes a
range of digitisation components. In the same
month the Madagascar Financial Inclusion
Project was launched, financed by the World
Bank. Its objectives include the digitisation
of government payments and microfinance
institutions, as well as a range of activities
focused on improving the financial inclusion of
women in Madagascar.
Summary of Madagascar’s performance

Madagascar: strengths Madagascar: areas for improvement

2.1 Market entry =1 3.4 Inclusive insurance =25
2.2 Ongoing requirements 1 3.3 Emerging services =31
1.2 Promotion of literacy and capability =5 3.2 =50
income customers

58
Mexico
Overview: The government of Mexico has been 1.

Government
implementing a National Financial Inclusion and policy support Mexico
Average
Policy since 2016. The National Council on 100
Financial Inclusion (CONAIF) co-ordinates 75

efforts across government agencies, financial 50
2.
institutions, and telecommunications and 5.
25
Stability
technology companies. 0
Highlights: The government, which was

inaugurated in December 2018, is placing
additional emphasis on the financial inclusion
4. 3.
of women and migrants. It has launched Consumer Products
new initiatives, such as granting interest-free
microloans, authorising minors aged 15 to 17
to open bank accounts and revamping state-
owned development banks. The government
and the private sector have recently joined
efforts to boost electronic payments through
the use of QR codes.
Summary of Mexico’s performance
Mexico: strengths Mexico: areas for improvement

4.2 Inclusive insurance users =1 5.1 Payments infrastructure 17
1.1 Broad strategies for financial inclusion =1 2.4 Supervisory capacity =18
e-money

59
Morocco
Overview: The Central Bank (Bank Al Maghreb) 1.

Government
initiated the development of a financial and policy support Morocco
Average
inclusion strategy in 2015, in collaboration 100
with the World Bank and the German Society 75
for International Co-operation (GIZ). At the
50
2.
beginning of 2016 a study was launched (using 5. Stability
Infrastructure 25
and integrity
a participative approach) to define the main
0
components of an appropriate strategy for the
Moroccan context.
Highlights: The Central Bank published the

4. 3.
key points of the National Financial Inclusion Consumer Products
Strategy in February 2019. The strategy includes
eight levers, with a particular focus on the most
excluded populations (unemployed women in
rural areas, youth and small businesses).
Summary of Morocco’s performance

Morocco: strengths Morocco: areas for improvement

2.3 Customer due diligence =1 4.2 Inclusive insurance users =42
Financial outlets (agents, merchants and Incentives for digitisation and emerging
3.5 =1 1.3 =48
electronic channels) technologies
4.3 Data privacy and cybercrime protection =7 2.4 Supervisory capacity 35

60
Mozambique
Overview: Mozambique’s government has 1.

Government
made considerable progress towards financial and policy support Mozambique
Average
inclusion following the implementation of 100
the 2016-22 Financial Inclusion Strategy, in 75

collaboration with both the public and the 50
2.
private sector. Led by the Bank of Mozambique, 5.
25
Stability
the strategy involves co-ordination with 12 0
government agencies, including the Institute for
Insurance Supervision, the Ministry of Economy
of Finance and the National Statistics Institute.
4. 3.
Highlights: In 2018 the government signed a Consumer Products
Financial Sector Deepening Memorandum of
Understanding with private-sector stakeholders
to increase levels of access to financial products.
In 2019 the Financial Inclusion Strategy
underwent its mid-term review. Mozambique’s
Finscope survey, last completed in 2014, is
being repeated in 2019 to update the available
information.
Summary of Mozambique’s performance

Mozambique: strengths Mozambique: areas for improvement

2.1 Market entry =1 3.3 Emerging services =31
2.2 Ongoing requirements =1 2.4 Supervisory capacity 55
2.3 Customer due diligence =1 2.5 Commitment to cyber-security =47

61
Myanmar
Overview: The National Financial Inclusion 1.

Government
Roadmap (2014-20) has guided efforts to and policy support Myanmar
Average
improve financial inclusion in Myanmar. 100
However, there is no evidence that the 75
strategy has incorporated a digital approach.
50
2.
The government of Myanmar has worked 5. Stability
Infrastructure 25
and integrity
with international donors to support financial
0
inclusion efforts. The United Nations Capital
Development Fund (UNCDF) Myanmar is
currently implementing the Expanding Financial
Access (EFA) programme, which aims to 4. 3.
Consumer Products
increase formal inclusion in Myanmar from 30% protection and outlets
to 40% by 2020. The government is also working
with the Livelihood and Food Security Fund
to allow taxpayers to pay taxes online. There
(LIFT) to provide financial literacy training.
have been changes in the regulations governing
Highlights: In August 2018 the Directorate open investment by foreign companies in the
of Investment and Company Administration financial services sector, with 35% foreign
(DICA) launched the MyCo online system, ownership now permitted in both local
which companies are now expected to register banks and insurance companies. A credit
with and use to pay fees. The Internal Revenue bureau is being established to strengthen risk
Department is also implementing an e-system management in the sector.
Summary of Myanmar’s performance

Myanmar: strengths Myanmar: areas for improvement

1.2 Promotion of literacy and capability =1 5.4 =54
systems
2.3 Customer due diligence =25 3.4 Inclusive insurance =25

62
Nepal
Overview: The Nepal Financial Inclusion 1.

Government
Roadmap (2017-22), released in July 2016, guides and policy support Nepal
Average
financial inclusion initiatives in the country. 100
The strategy aims to orient the banking system 75

towards universal banking, increasing the 50
2.
availability of financial services in rural and 5.
25
Stability
remote areas and initiating reforms to enhance 0
the regulatory framework and capabilities,
with the objective of developing more resilient
financial systems. The Nepal Rastra Bank’s
(NRB) Third Strategic Plan (2017-21) also 4. 3.
Consumer Products
identifies financial inclusion as a strategic protection and outlets
priority, and the Monetary Policy of 2017-18
focused on deepening financial inclusion by
enhancing financial literacy and access to
finance.
bank accounts for every Nepalese citizen within
Highlights: The first federal budget, for fiscal one year. The NRB’s regulation department
year 2018-19, aims to digitise government has upgraded its reporting system to ensure
payments and revenue collection. In 2018 the efficient compliance control, data analysis and
Finance Ministry launched a campaign to open policy formulation.
Summary of Nepal’s performance
Nepal: strengths Nepal: areas for improvement

technologies
Credit portfolios for middle- and low- Credit information and other data-sharing
3.2 =17 5.4 52
income customers systems

63
Nicaragua
Overview: Financial inclusion in Nicaragua 1.

Government
relates mainly to microfinance, which was and policy support Nicaragua
Average
regulated in 2011. Microfinance institutions 100
(MFIs) are under the aegis of the Comisión 75
Nacional de Microfinanzas (CONAMI), which
50
2.
has gradually improved its supervisory capacity. 5. Stability
Infrastructure 25
and integrity
Government-sponsored lending programmes
0
are channelled through two state-financed
institutions: the Cooperativa de Ahorro y
Credito Caja Rural Nacional (CARUNA, the
rural savings and loans co-operative) and Banco 4. 3.
Consumer Products
Produzcamos. These are key components of the protection and outlets
government’s efforts to increase inclusion.
Highlights: The government passed a tax account opening. In 2016 the Central Bank of
reform package in 2019, which levies a 15% tax Nicaragua launched a new ACH system, in
on capital gains, affecting the financial sector. co-operation with the six major banks, through
The Superintendencia de Bancos y Otras the UniRed network. Nicaragua published a
Instituciones (SIBOIF) issued a norm for a microinsurance norm in 2015, and MIFs offer
simplified account in 2017, which has enabled microinsurance products.
Summary of Nicaragua’s performance
Nicaragua: strengths Nicaragua: areas for improvement

3.4 Inclusive insurance =1 3.3 Emerging services =31
3.5 =1 1.2 Promotion of literacy and capability =54

64
Nigeria
Overview: In 2018 the government of 1.

Government
Nigeria revisited the National Financial and policy support Nigeria
Average
Inclusion Strategy (established in 2012), 100
which focused on agency banking, mobile 75

banking/mobile payments, linkage models 50
2.
and client empowerment. In the same year 5.
25
Stability
a memorandum of understanding (MOU) on 0
digital payment systems was signed between
the Central Bank of Nigeria (CBN) and the
Nigerian Communications Commission. This
suggests that a move towards a more coherent 4. 3.
Consumer Products
digital approach may be likely in the near future. protection and outlets
Highlights: The National Financial Inclusion

Strategy states that the government of Nigeria
aims to achieve full digitisation of federal operators to convert to payment service banks
government flows by 2020. In October 2018 in order to operate in the Nigerian market.
newly introduced guidelines from the Central Payment service banks are not authorised to
Bank of Nigeria enabled mobile money provide loans.
Summary of Nigeria’s performance

Nigeria: strengths Nigeria: areas for improvement

3.1 =14 2.4 Supervisory capacity =50
e-money
Financial outlets (agents, merchants and Credit portfolios for middle- and low-
3.5 =26 3.2 =43
electronic channels) income customers

65
Pakistan
Overview: In 2018 Pakistan revised its 2015 1.

Government
National Financial Inclusion Strategy (NFIS). and policy support Pakistan
Average
The revised strategy places an emphasis on 100
promoting digital payments, with the aim of 75
increasing the number of digitised accounts to
50
2.
65m by 2023. 5. Stability
Infrastructure 25
and integrity
Highlights: The State Bank of Pakistan (SBP, the 0
central bank) implemented reforms in 2019 that

will allow non-banking entities to directly issue
e-money, through the Regulations for Electronic
4. 3.
Money Institutions (EMIs). Previously, Pakistan Consumer Products
had a bank-led model, where mobile operators
set up microfinance banks in order to issue
e-money. This change is likely to enable further
innovation in digital finance.
Summary of Pakistan’s performance
Pakistan: strengths Pakistan: areas for improvement

income customers
3.4 Inclusive insurance =1 5.3 Connectivity 55
Financial outlets (agents, merchants and Accounts at financial institutions and
3.5 =1 3.1 =54
electronic channels) e-money

66
Panama
Overview: Panama has a series of standards 1.

Government
in place that permit the use of non-banking and policy support Panama
Average
agents, simplified accounts and digital payment 100
channels to facilitate access to financial services 75

among low-income populations. 50
2.
5. Stability
Highlights: In May 2019 the government Infrastructure 25
and integrity
proposed an official National Strategy 0
for Financial Inclusion. The 2018 Bill for

the Modernisation and International
Competitiveness of the Financial System (No.
4. 3.
629) is also expected to introduce a digital Consumer Products
transformation approach to the country’s
financial system. In June 2019 the Financial
Action Task Force (FATF) placed Panama back
on its grey list of countries that are high risk
for money laundering and the financing of
terrorism.
Summary of Panama’s performance

Panama: strengths Panama: areas for improvement

2.2 Ongoing requirements =11 1.1 Broad strategies for financial inclusion =50
technologies

67
Paraguay
Overview: In 2014 the government of Paraguay 1.

Government
created the National Committee on Financial and policy support Paraguay
Average
Inclusion (CNIF) and a National Strategy for 100
Financial Inclusion (ENIF). Successful co- 75
ordination within the public and private sectors
50
2.
has led to the implementation of financial 5. Stability
Infrastructure 25
and integrity
education programmes, e-money issuers and
0
simplified digital accounts. Paraguay’s existing
regulatory structure for non-banking financial
institutions remains weak.
4. 3.
Highlights: The CNIF is currently evaluating the Consumer Products
advancements and weaknesses of the 2014-18
ENIF and is expected to update the strategy to
cover the 2019-23 period. Following the 2018
creation of the Paraguayan Chamber of Fintech,
new legislation is expected later this year to
regulate sectors of the fintech industry.
Summary of Paraguay’s performance
Paraguay: strengths Paraguay: areas for improvement

2.3 Customer due diligence =1 1.1 Broad strategies for financial inclusion =31
4.3 Data privacy and cybercrime protection =3 5.4 36
systems

68
Peru
Overview: Peru’s regulatory framework for 1.

Government
financial inclusion is guided by the Multisectoral and policy support Peru
Average
Commission on Financial Inclusion and the 100
National Strategy for Financial Inclusion (ENIF, 75

first issued in 2015). Government stakeholders, 50
2.
the private sector and civil society co-operate 5.
25
Stability
to promote financial inclusion, but demand for 0
formal financial services has been weak due to a
lack of products that truly meet the needs of the
diverse population.
4. 3.
Highlights: In July 2019 the Ministry of the Consumer Products
Economy and Finances issued Supreme Decree
No. 255-2019-EF, which revises the 2015 ENIF,
recognises the structural challenges to financial
inclusion, and focuses on three pillars: access,
effective use and quality services.
Summary of Peru’s performance
Peru: strengths Peru: areas for improvement

income customers
2.1 Market entry =1 5.3 Connectivity =43
2.2 Ongoing requirements =1 3.3 Emerging services =11

69
Philippines
Overview: In 2016 the Office of the Presidency 1.

Government
institutionalised the Financial Inclusion Steering and policy support Philippines
Average
Committee (FISC)—the governing body 100
that provides strategic direction, guidance 75
and oversight in the implementation of the
50
2.
National Strategy for Financial Inclusion (NSFI). 5. Stability
Infrastructure 25
and integrity
The Philippines has increased its focus on
0
digital financial inclusion, with the launch of a
biometric national identification system and
a programme to provide a one-stop shop for
online government services. Efforts are being 4. 3.
Consumer Products
made to increase financial and digital literacy, protection and outlets
but they lack gender goals.
Highlights: Bangko Sentral ng Pilipinas has

created a support institution to focus on participating institutions and high transaction
digital financial technology for reaching the costs. The supervision of non-banks and MFIs
underserved. Interoperability in retail payments needs strengthening as do dispute resolution
is still constrained by a limited number of mechanisms for government payments.
Summary of Philippines’s performance
Philippines: strengths Philippines: areas for improvement

income customers
2.1 Market entry =1 5.3 Connectivity =43

70
Russia
Overview: In 2018 Russia adopted the Strategy 1.

Government
for Raising Financial Inclusion 2018-20. The and policy support Russia
Average
Central Bank of the Russian Federation is the 100
main body responsible for financial inclusion 75

and has a service for consumer protection and 50
2.
financial inclusion. 5.
25
Stability
Highlights: In 2019 a policy titled “Main 0
Directions of Development of the Financial

Market for 2019-21” was adopted, along with
an action plan for its implementation. These
4. 3.
documents both include measures to increase Consumer Products
financial inclusion. In addition, the Fast Payment
System (Sistema Bystrykh Platezhei) was
launched in February 2019. This system enables
instant payments between personal accounts
at 14 different financial institutions via a
smartphone application.
Summary of Russia’s performance

Russia: strengths Russia: areas for improvement

4.3 Data privacy and cybercrime protection 1 1.1 Broad strategies for financial inclusion =31

71
Rwanda
Overview: Rwanda adopted its Financial 1.

Government
Inclusion Programme (2016-20) in 2015. and policy support Rwanda
Average
The National Bank of Rwanda is steadily 100
implementing this programme, with the aim of 75
reaching 90% inclusion by 2020.
50
2.
5. Stability
Highlights: In December 2018 the National Infrastructure 25
and integrity
Bank adopted a new microinsurance regulation, 0
which encourages the development of products

targeting the informal sector and low-income
customers. The National Bank has also assumed
4. 3.
full responsibility for microfinance regulation, Consumer Products
improving the regulatory atmosphere by ending
double regulation. An initiative to create a
centralised agent system has been introduced,
and the system may be implemented by the end
of 2019.
Summary of Rwanda’s performance
Rwanda: strengths Rwanda: areas for improvement

Credit portfolios for middle and low-
3.3 Emerging services =1 3.2 =32
income customers
3.4 Inclusive insurance =1 5.1 Payments infrastructure =40
e-money

72
Senegal
Overview: The Central Bank of West African 1.

Government
States (BCEAO) has created an enabling and policy support Senegal
Average
environment for digital financial services that 100
includes the promotion of electronic payments, 75

microfinance institutions and other digital 50
2.
financial services. Non-banks can receive 5.
25
Stability
e-money issuer licences, which allows mobile 0
network operators and other agents to improve
access to financial services in Senegal. In 2016
the government began issuing e-IDs to citizens,
and as of 2017 an estimated 67% of adults had 4. 3.
Consumer Products
one. Mobile money continues to drive financial protection and outlets
inclusion in Senegal, and in 2018 the government
announced a new initiative to speed up
infrastructure development for the digitisation of
government operations throughout rural areas.
Highlights: Senegal’s Ministry of Finance, inclusion that aligns with regional standards.
Economy and Planning (MEFP) is in the process There have been no significant advances
of reviving a strategy to address financial towards financial inclusion since 2018.
Summary of Senegal’s performance
Senegal: strengths Senegal: areas for improvement

4.3 Data privacy and cybercrime protection 3 2.3 Customer due diligence =55
2.1 Market entry 18 4.2 Inclusive insurance users 42

73
Sierra Leone
Overview: Sierra Leone’s National Strategy for 1.

Government
Financial Inclusion (2017-20) is in its third year and policy support Sierra Leone
Average
of implementation. Discussions are already 100
underway to draft a second plan that builds on 75
progress made since 2017.
50
2.
5. Stability
Highlights: Aided by strong political support and Infrastructure 25
and integrity
continued technical support from international 0
partners, Sierra Leone has used a regulatory

sandbox approach to support innovative pilot
projects aimed at tackling financial inclusion
4. 3.
through two rounds of the Sierra Leone FinTech Consumer Products
Challenge. The creation of a Financial Inclusion
Secretariat within the Bank of Sierra Leone in
2019 has given renewed impetus to efforts aimed
at achieving greater interoperability, creating a
nationwide digital identification system (using
blockchain technology) and developing agency
banking guidelines. The secretariat is tasked
with achieving the goals outlined in the national
strategy.
Summary of Sierra Leone’s performance
Sierra Leone: strengths Sierra Leone: areas for improvement

3.3 Emerging services =1 3.2 =50
income customers
technologies

74
South Africa
Overview: Although South Africa does not 1.

Government
have an overarching national financial inclusion and policy support South Africa
Average
strategy, it has developed a series of strategies 100
to promote and encourage financial inclusion. 75

Compared with other countries in Africa, 50
2.
South Africa has high levels of financial literacy, 5.
25
Stability
as well as high levels of Internet and mobile 0
phone penetration. Despite this, public trust in
the banking sector and its high fee structures
present obstacles to financial inclusion. South
Africa also mandates that e-money can only 4. 3.
Consumer Products
be issued by South African banks, which has protection and outlets
stunted development of the e-money sector.
Highlights: 2019 is an election year, so there

have been no major public-sector developments
regarding financial inclusion. The latest version
of the National Credit Act passed the National
Assembly in September 2018 but is awaiting a
presidential signature.
Summary of South Africa’s performance

South Africa: strengths South Africa: areas for improvement

4.1 Financial services users =1 3.3 Emerging services =31
4.2 Inclusive insurance users =1 3.2 =43
income customers

75
Sri Lanka
Overview: In January 2018 the Central Bank 1.

Government
of Sri Lanka (CBSL) partnered with the and policy support Sri Lanka
Average
International Finance Corporation (IFC) to 100
develop the country’s first National Financial 75
Inclusion Strategy, with the support of the
50
2.
Ministry of National Policies and Economic 5. Stability
Infrastructure 25
and integrity
Affairs and the Ministry of Finance and Mass
0
Media. The strategy’s main focus is digital
finance, including a national payment platform.
The strategy is expected to come into effect in
2019. 4. 3.
Consumer Products
Highlights: In 2018 the Central Bank of Sri Lanka
conducted 154 programmes on financial literacy,
entrepreneurship development and skills Code Standard for Local Currency Payments and
development, with a special focus on those who the Payment and Settlement System Circulars
lack access to the formal financial sector. The of 2019 have contributed to financial inclusion.
government also conducted financial inclusion The former allows low-value merchants to
programmes that targeted women in various accept QR codes, and the latter requires SMS
parts of the country. In terms of legislation, the notifications to be sent to consumers for
Establishment of a National Quick Response financial transactions.
Summary of Sri Lanka’s performance
Sri Lanka: strengths Sri Lanka: areas for improvement

2.1 Market entry =20 3.2 =50
income customers

76
Tanzania
Overview: In 2017 Tanzania’s Financial Inclusion 1.

Government
National Council (a policymaking body for and policy support Tanzania
Average
the national agenda in the area of financial 100
inclusion) published the National Financial 75

Inclusion Framework 2018-22. This framework 50
2.
guides policy implementation and structural 5.
25
Stability
changes aimed at achieving greater financial 0
access and interoperability.
Highlights: The Bank of Tanzania has

developed and is currently implementing
4. 3.
a new payment switch programme (the Consumer Products
Tanzania Instant Payment System), which will
connect all banks, e-money providers and
financial institutions. Over the past two years
the government has also provided all adult
Tanzanians with basic national IDs, and efforts
are underway to provide them with digital IDs.
Summary of Tanzania’s performance
Tanzania: strengths Tanzania: areas for improvement

income customers
systems
electrical channels)

77
Thailand
Overview: Thailand has specific institutions 1.

Government
that promote financial inclusion, but there is no and policy support Thailand
Average
single, comprehensive strategy document. The 100
Bank of Thailand (the central bank) published its 75
Financial Sector Master Plan Phase III (2016-20)
50
2.
in 2016, which promotes electronic financial 5. Stability
Infrastructure 25
and integrity
and payment services and aims to enhance the
0
efficiency of the financial system. Thailand is
also taking steps to become a cashless society
through its National e-Payment Master Plan.
4. 3.
Highlights: The regulatory environment Consumer Products
for financial inclusion remains unchanged.
The authorities encourage the expansion of
commercial banks into microfinance, but their
microloan portfolio is still tiny. The authorities
say they favour the entry of new (private)
providers, but highly subsidised government
programmes and stringent regulations preclude
the entry of new microfinance institutions.
Summary of Thailand’s performance

Thailand: strengths Thailand: areas for improvement

3.3 Emerging services =1 3.4 Inclusive insurance =25
4.2 Inclusive insurance users =1 2.3 Customer due diligence =53
2.5 Commitment to cyber-security 5 1.1 Broad strategies for financial inclusion =39

78
Trinidad and Tobago
Overview: Trinidad and Tobago’s Strategic 1.

Government
Plan for 2016-17 to 2020-21 is the main policy and policy support Trinidad and
Tobago
document for financial inclusion, and the 100 Average
Central Bank of Trinidad is responsible for 75
leading policy co-ordination. The 2008 Financial 50
2.
Institutions Act, the 2014 Moneylenders Act and 5.
25
Stability
the 2007 Consumer Protection and Safety Act 0
provide the main regulatory thrust for financial
inclusion, with the Central Bank acting as the
primary regulator of all financial institutions.
The government continues to move towards 4. 3.
Consumer Products
improving its payments platform, with the aim protection and outlets
of transitioning from the existing online portal
(TTConnect) to a fully digital government funds
of the Financial Ombudsman, Trinidad and
transfer system by the end of 2019. The country
Tobago has implemented financial literacy
continues to lack a comprehensive regulatory
and digital literacy programmes designed to
framework for agent banking, remote account
increase financial inclusion. Overall capacity
opening, microcredit and inclusive insurance.
remains an issue, as the central bank does not
Highlights: Following the launch of the have sufficient technical expertise to regulate
National Financial Education Committee in emerging services, and the variety of mobile
March 2018, led by the Central Bank’s Office money platforms remains limited.
Summary of Trinidad and Tobago’s performance
Trinidad and Tobago: strengths Trinidad and Tobago: areas for improvement

2.1 Market entry =1 3.5 =55
electrical channels)
income customers

79
Tunisia
Overview: In 2018 the government of Tunisia 1.

Government
introduced a new Banking Law (2016-48) for and policy support Tunisia
Average
financial service providers, which was further 100
strengthened by the Central Bank Circular 2018-16. 75
Highlights: In 2018 the Ministry of Finance 50

2.
5. Stability
introduced the National Financial Inclusion Infrastructure 25
and integrity
Strategy for 2018-22, which is to be 0
implemented by a multi-stakeholder National

Committee of Financial Inclusion. The Ministry
of Finance and the Committee for Financial
4. 3.
Sector Reform developed a nationwide action Consumer Products
plan for the de-cashing strategy, furthering the
development of electronic payment systems
in Tunisia. The Central Bank Circular 2018-
16, issued on December 31, 2018, authorised
payment institutions to carry out digital
payments.
Summary of Tunisia’s performance
Tunisia: strengths Tunisia: areas for improvement

5.2 Digital IDs =14 4.2 Inclusive insurance users =42
5.3 Connectivity 19 3.4 Inclusive insurance =25
e-money

80
Turkey
Overview: Turkey developed a Financial 1.

Government
Inclusion Strategy in 2014. However, the action and policy support Turkey
Average
plans attached to the strategy—which focused 100
on financial education and financial consumer 75

protection—expired in 2017, and no new plans 50
2.
have been drafted. 5.
25
Stability
Highlights: There have been no changes 0
in the regulatory environment for financial

inclusion. The financial sector in general has
faced increased risks since mid-2018, due to the
4. 3.
lira slide and subsequent economic recession. Consumer Products
The Financial Technologies Permanent Sub-
Committee, established by the main financial
regulatory bodies in July 2018, has continued to
discuss a strategy and road map for the fintech
industry, with potential benefits for financial
inclusion.
Summary of Turkey’s performance

Turkey: strengths Turkey: areas for improvement

income customers
2.5 Commitment to cyber-security 1 1.1 Broad strategies for financial inclusion =50
2.3 Customer due diligence =1 5.1 Payments infrastructure 48

81
Uganda
Overview: The Ministry of Financial Planning 1.

Government
and Economic Development and the Bank and policy support Uganda
Average
of Uganda (BoU) continue to spearhead 100
implementation of the National Strategy for 75
Financial Inclusion, which will drive the process
50
2.
until 2022. 5. Stability
Infrastructure 25
and integrity
Highlights: The roll-out of agency banking 0
regulations in 2018 has expanded access to

financial services at a time when taxation of the
mobile money sector has negatively affected
4. 3.
financial inclusion efforts. Data protection was Consumer Products
strengthened in February 2019 when the Uganda
Data Protection and Privacy Act was signed into
law. After broad consultation on the National
Payment Bill in 2018, the BoU is confident that
legislation to improve interoperability will be in
place by the end of 2019.
Summary of Uganda’s performance

Uganda: strengths Uganda: areas for improvement

5.2 Digital IDs =9 3.4 Inclusive insurance =25
3.2 =17 5.1 Payments infrastructure 55
income customers

82
Uruguay
Overview: In 2014 Uruguay implemented the 1.

Government
Law for Financial Inclusion (Ley de Inclusion and policy support Uruguay
Average
Financiera), which created various incentives 100
for users to access formal bank accounts and 75

electronic payment services. The Ministry of 50
2.
the Economy and Finances (MEF) oversees 5.
25
Stability
implementation of the law. 0
Highlights: The MEF continues to launch

initiatives to promote financial inclusion. In
April 2019 it announced that all government
4. 3.
entities would accept electronic payments from Consumer Products
August 2019. Following the passage of the Law
for Financial Inclusion, 1.1m electronic money
instruments and almost 800,000 new debit
cards have been issued, allowing more than 1m
people (approximately 40% of the population
aged 15 years and above) to access a free
electronic money account or instrument, with a
set of associated services, at no cost.
Summary of Uruguay’s performance
Uruguay: strengths Uruguay: areas for improvement

2.3 Customer due diligence =1 5.2 Digital IDs =23

83
Venezuela
Overview: The environment for financial 1.

Government
inclusion in Venezuela has deteriorated and policy support Venezuela
Average
significantly due to a combination of 100
inadequate legislation and a severe economic 75
crisis. Financial inclusion has not been a
50
2.
priority in the government’s development 5. Stability
Infrastructure 25
and integrity
agenda, and shortages of cash have deeply
0
affected all economic sectors. In August 2017
the Superintendence of Banks (SUDEBAN)
prohibited non-banking agents from conducting
a number of cash transactions, forcing banks 4. 3.
Consumer Products
and other financial providers to shut down protection and outlets
branches in remote areas and reduce their
network of agents. The outdated regulatory
framework exacerbates this situation.
transformation did not aim to achieve greater
Highlights: In 2018 the government of financial inclusion, and it has been non-existent
Venezuela became the first country to launch in practice. In 2019 the International Monetary
its own cryptocurrency (the Petro), in an Fund (IMF) estimated that Venezuela’s annual
attempt to save itself from high levels of foreign inflation rate would reach 10,000,000 % by the
debt and hyperinflation. However, this digital end of the year.
Summary of Venezuela’s performance
Venezuela: strengths Venezuela: areas for improvement

technologies
5.3 Connectivity =22 1.1 Broad strategies for financial inclusion =55

84
Vietnam
Overview: The State Bank of Vietnam (SBV) 1.

Government
has not issued policies or legislation as part of and policy support Vietnam
Average
a national financial inclusion strategy. In 2018, 100
however, the government issued Decision No. 75

986/QD-TTg on the Development Strategy 50
2.
of Vietnam Banking Sector to 2025, with 5.
25
Stability
Orientations to 2030. This outlines goals for 0
modernising the SBV, improving financial
supervision, promoting competition in financial
services and developing modern products for
financial inclusion. The SBV is currently working 4. 3.
Consumer Products
with international entities to develop a financial protection and outlets
inclusion strategy.
Highlights: In 2016 the government announced

a plan to increase the percentage of cashless
payments to over 90% by 2020. However,
data from 2019 shows that less than 12% of all
payments are cashless, and nearly all small-value
payments (under US$5) are still made in cash.
The government is considering tax incentives to
increase the use of electronic payments.
Summary of Vietnam’s performance

Vietnam: strengths Vietnam: areas for improvement

technologies
4.3 Data privacy and cybercrime protection =9 2.2 Ongoing requirements 55

85
Methodology
The Global Microscope is a benchmarking 2) Stability and integrity: This category

tool created in 2007 to evaluate the enabling assesses the regulation, supervision and
environment for financial inclusion in countries monitoring of financial services providers that
across the globe. The 12th iteration of the study serve low and middle-income populations. The
is sponsored by the Bill and Melinda Gates evaluation of this category incorporates a risk-
Foundation, IDB Lab and IDB Invest members based approach to balance financial inclusion
of the Inter-American Development Bank and goals with financial stability and integrity goals
the Center for Financial Inclusion at Accion. In
3) Products and Outlets: This category
2018, the Global Microscope framework was
assesses the regulation of a selection of
completely redesigned to reflect the changes
products and outlets that focus and/or reach
in the field of financial inclusion after the
low and middle-income populations
emergence of digital financial services. The 2018
framework evaluates how policy, regulation and 4) Consumer Protection: This category
infrastructure enables the provision of financial assesses consumer protection and privacy
services to low and middle income population. regulation and enforcement
The framework looks at a broad suite of
5) Infrastructure: This category assesses the
financial services including deposits, savings,
infrastructure that facilitates financial inclusion
credit, insurance and remittances. This year we
as well as the policy and regulatory actions that
added 11 new indicators to document policy
governments can take to improve these types of
and regulatory approaches to financial inclusion
infrastructure
(e.g. national strategies), as well as factors
that enable women to take advantage of new Regional Representation
channels into the financial system. The results
Like the previous iterations of the Microscope
are broadly comparable with the 2018 findings
beginning 2011, the Microscope covers 55
with the exception of indicators noted below in
countries. In 2018 the EIU selected a revised set
this methodology paper. The results however
of countries where financial inclusion reflecting
are not comparable with previous editions of the
a varied combination of emerging markets, and
Microscope as the framework was completely
to reflect countries that have had interesting or
overhauled in 2018.
unexpected financial inclusion outcomes. Chad
Categories is the only country from last year’s edition that
was excluded from the 2019 Global Microscope.
The index contains 20 indicators and 71
Cote d’Ivoire was included in this year’s study for
questions organised across five categories:
the first time.
1) Government & Policy Support: This
category assesses the degree of coordination Scoring Criteria
and the incentives that governments are putting The scoring criteria (see Appendix 1) is detailed
in place to create favourable environments for but also subjective in nature. The Economist
financial inclusion Intelligence Unit research team reviewed each
response thoroughly, calibrated scores and

86
conducted cross-country comparisons, so as to 5.3.3.c) Coverage of 4G network

ensure that scores were properly justified and Percentage of the population covered by at least
consistent across all countries. Consequently, a 4G mobile network
scores are best understood by reading both the
Changes to indicator framework:
scoring criteria and the written justifications
New indicators
provided for each indicator found in the
The following eight indicators were added to the
accompanying excel model available at: www.
index in 2019:
eiu.com/microscope2018
1.1.3.a) Gender approach included in national
Changes to indicator framework strategy
Various changes were made to the indicator Does the national strategy include a gender
framework in 2019. In addition to general approach?
refinements, several indicators were added
1.1.4.a) Existence of targets on agent networks
or modified to capture issues around gender
Does the government strategy include a target
equality in financial inclusion. 3 indicators were
on the size of agent networks?
removed from the index, 8 indicators were
added, and changes were made to 15 existing 2.4.2.c) Female representation in decision
indicators. Full details of all these changes follow making process
below. Are there any women occupying top decision-
making positions in the financial regulatory
Changes to indicator framework:
bodies?
Deleted indicators
Four questions were removed from the index 3.1.1.b) Non-discrimination account opening
in 2019. Questions shown here are those Does the law place any restrictions to account
referenced in 2018 index. opening based on sex?
1.1.3.a) Evidence of public-private coordination 4.1.4.a) Diversity of agents

and implementation Are there programmes or strategies to
Is there evidence of coordination between the encourage diversity (of gender, race, religion,
government and a variety of service providers in caste, ethnicity) among providers and agents of
the private sector to promote financial inclusion? financial services?
1.3.1.d) Targeted transfers 4.1.6.a) Protections for financial outlets and

Has the government established a targeting agents’ users
method to avoid exclusion errors in government Are outlets and agents subject to similar
transfers? transparency, fair treatment and dispute
resolution requirements as banks and other
3.2.1.b) Risk-management framework for
non-bank financial institutions?
microcredit
Is there a differentiated and comprehensive 5.2.1.b) Gender Gap in ID system
risk-management framework for microcredit Percentage difference between women without
portfolios that cover most of the market for access to an ID compared to men
middle and low-income customers?
5.2.3.a) Non-discriminatory access to IDs
Note: Microcredit is now incorporated in
Do laws or regulations place any restrictions to
indicator 3.2.1.a)
access of digital ID’s and/or eKYC verification
systems based on sex?

87
Changes to indicator framework: Modified indicators

The wording and/or scoring system was modified for 15 indicators in 2019.
1.2.1a) Support for financial literacy

Scoring change. Becomes score 0-3 (was 0-2). Additional scoring point available if government
strategy includes a gender approach.
2018 2019
Is there evidence of government efforts to promote and/or Is there evidence of a government strategy or government
achieve financial literacy and capability? Is there evidence programs to promote financial literacy and/or strengthen
of their implementation either in the public or the private capabilities? Does it include a gender approach?
sector? 0 = There is no evidence of a government strategy or
0 = There is no evidence of government or private sector programs to promote financial literacy and capabilities
efforts to promote financial literacy 1 = There is a government strategy to promote financial
1 = There is a government strategy to promote financial literacy but no evidence of implementation
literacy but no evidence of implementation OR there is 2 = There is a government strategy to promote financial
evidence of private sector efforts to promote financial literacy and it is being implemented, but it does not have a
literacy but no coordination with the government gender approach
2 = There is a government strategy to promote financial 3 = There is a government strategy to promote financial
literacy and it is being implemented either by the literacy, it is being implemented and it has a gender
government, the private sector or both approach
1.2.2.a) Support for digital literacy

Scoring options change. Point awarded for gender component. Indicator remains 0-3, unchanged
from 2018.
2018 2019
Does the government have a plan or strategy that addresses Is there evidence of a government strategy or program to
digital literacy, especially for students, as well as training for promote digital literacy and/or strengthening capabilities?
teachers? Does it include a gender approach?
0 = No, the government does not have a plan or strategy 0 = There is no evidence of a government strategy or
that addresses digital literacy for students and training for programs to promote digital literacy and capabilities
teachers 1 = There is a government strategy to promote digital
1 = Yes, the government’s plan or strategy addresses digital literacy but no evidence of implementation
literacy for students, but it does not include training for 2 = There is a government strategy to promote digital
teachers, or the plan is outdated literacy and it is being implemented, but it does not have a
2 = Yes, the government’s plan or strategy is current, gender approach
addresses digital literacy for students and includes training 3 = There is a government strategy to promote digital
for teachers literacy, it is being implemented and it has a gender
3 = Yes, the government’s plan or strategy is current, approach
addresses digital literacy for students and includes training
for teachers and is introduced at the primacy school level

88
1.3.1.b) Percentage of G2P payments deposited into an account

Scoring change. In 2018 the % value was banded into a qualitative score 0-4. In 2019 the score is
calculated as a min/max on the % value.
1.3.2.a) Approach to authorization and oversight of financial innovation

Wording change
2018 2019
Have financial authorities fostered innovation in the Has the government mandated and created formal spaces
financial sector through a ‘test and learn’, ‘wait and see’ for financial innovation? (for example, a sandbox, office
or ‘regulatory sandbox’ approach for authorization and hours with regulators, test and learn financial regulation)
oversight of innovative financial services? Are there explicit 0 = There are no formal spaces or mechanisms for financial
protocols to foster innovation for any of these approaches? innovation
0 = No 1 = There are formal spaces or mechanisms for financial
1 = Yes innovation
2.1.4.a) Disproportionate initial requirements for cross-border payment providers

Scoring change. Was score 0-4 in 2018, now score 0-2.
2018 2019
Do cross-border payment providers face disproportionate Do cross-border payment providers face disproportionate
restrictions in the following areas that affect the entrance restrictions in the following areas that affect the entrance
of new providers who serve low and middle-income of new providers who serve low and middle-income
customers? customers?
1. Overall licensing framework for cross-border payments 1. Overall licensing framework for cross-border payments
2. Funding or ownership of domestic and/or foreign (Here the important questions is if non-banks can get
institutions that perform financial services licenses for cross border payments)
3. Initial capital requirements 2. Funding or ownership of domestic and/or foreign
institutions that perform financial services.
4. Initial operational requirements such as number of
branches, location, entry fee, and/or data housing if 0 = Cross-border payment providers face disproportionate
relevant restrictions in all of these areas
1 = Cross-border payment providers face disproportionate
restrictions in one of these areas
2 = Cross-border payment providers do not face
disproportionate restrictions in any of these areas

89
2.2.4.a) Disproportionate ongoing requirements for cross-border payment providers

2018 2019
Do cross-border payment providers face disproportionate Do cross-border payment providers face disproportionate
requirements in the following areas? requirements in the following areas?
1. Restrictions on the vehicles to receive remittances (e.g. 1. Restrictions on the vehicles to receive remittances (e.g.
can they be delivered to local e-money or mobile money can they be delivered to local e-money or mobile money
accounts, basic accounts, savings accounts?) accounts, basic accounts, savings accounts?)
2. Market distorting pricing control 2. Market distorting pricing controls
3.Taxation of operations 3.Taxation of operations
4. Ongoing capital requirement
5. Ongoing operational requirements such as number restrictions in all of these areas
of branches, location, entry fee, and/or data housing if
relevant 1 = Cross-border payment providers face disproportionate
restrictions in two of these areas
6. Differences in transaction and balance limits between
countries 2 = Cross-border payment providers face disproportionate
0 = Cross-border payment providers face disproportionate 3 = Cross-border payment providers don’ t face
restrictions in all of these areas disproportionate restrictions in any of these areas
restrictions in five of these areas
restrictions in four of these areas
restrictions in three of these areas
restrictions in two of these areas
6 = Cross-border payment providers don’ t face
disproportionate restrictions in any of these areas
2.4.2.a) Technical expertise to supervise non-bank financial institutions

Wording and scoring option changes
2018 2019
Is there a specialised capacity in the regulatory agency Is there a dedicated unit or dedicated technical experts in
to supervise non-bank financial institutions that serve the regulatory agency and/or Central Bank to supervise
middle and low-income customers? By capacity we refer to non-bank financial institutions like MFIs?
regulators with technical expertise. 0 = There is no evidence of a unit or dedicated technical
0 = Regulators do not have technical expertise to supervise experts to supervise non-bank financial institutions
non-bank financial institutions 1 = There are dedicated technical experts with sufficient
1 = Regulators have sufficient technical expertise to capacity to supervise non-bank financial institutions
supervise non-bank financial institutions 2 = There are dedicated technical experts with advanced
2 = Regulators have advanced technical expertise to capacity to supervise non-bank financial institutions
supervise non-bank financial institutions

90
2.4.2.b) Technical expertise to supervise digital financial services

Wording and scoring option changes
2018 2019
Is there a specialised capacity in the regulatory agency Is there a dedicated unit or dedicated technical experts in
to supervise DFS that serve middle and low-income the regulatory agency and/or Central Bank to supervise
customers? By capacity we refer to regulators with digital financial services?
technical expertise. 0 = There is no evidence of a unit or dedicated technical
0 = Regulators do not have technical expertise to supervise experts to supervise digital financial services
digital financial services 1 = There are dedicated technical experts with sufficient
1 = Regulators have sufficient technical expertise to capacity to supervise digital financial services
supervise digital financial services 2 = There are dedicated technical experts with advanced
2 = Regulators have advanced technical expertise to capacity to supervise digital financial services
supervise digital financial services
2.4.2.d) Regulatory technology

Wording change (question only, not scoring options).
2018 2019
Are supervisors’ regulators leveraging technology, that is, Are supervisors and/or regulators leveraging regtech, that
using new tools or approaches to supervise non-banks in is, using technology tools or approaches to supervise the
the provision of digital financial services? provision of financial services?
0 = Regulators are not leveraging technology for digital 0 = Regulators are not leveraging technology for digital
supervision supervision
1 = Regulators are leveraging technology for digital 1 = Regulators are leveraging technology for digital
supervision supervision
3.1.1.a) Account opening requirements

Wording change (question only, not scoring options)
2018 2019
Are account-opening requirements proportionate for Are account-opening requirements proportionate for
accounts at financial institutions and e-money? accounts at financial institutions and e-money based on the
0 = Account opening requirements are not proportionate amounts these accounts hold?
1 = Account opening requirements are either proportionate 0 = Account opening requirements are not proportionate
for accounts or for e-money but not for both 1 = Account opening requirements are either proportionate
2 = Account opening requirements are proportionate for for accounts or for e-money but not for both
both accounts at financial institutions and e-money 2 = Account opening requirements are proportionate for
both accounts at financial institutions and e-money

91
3.2.1.a) Risk-management framework for consumer credit

Scope change: Question now covers both consumer credit and micro-credit.
2018 2019
Is there a differentiated and comprehensive risk- Is there a differentiated and comprehensive risk-
management framework for consumer credit portfolios management framework for credit portfolios (including
that cover most of the market for middle and low-income microcredit) that cover most of the market for middle and
customers? low-income customers?
0= There is no differentiated risk-management framework 0= There is no differentiated risk-management framework
for consumer credit for consumer credit
1= There is a differentiated risk-management framework 1= There is a differentiated risk-management framework
for consumer credit, but supervision of its status is limited for consumer credit, but supervision of its status is limited
2= There is a differentiated risk-management framework 2= There is a differentiated risk-management framework
for consumer credit and the regulator supervises its status for consumer credit and the regulator supervises its status
3.4.1.a) Dedicated inclusive insurance framework

Wording change (question and scoring options)
2018 2019
Is the regulation for inclusive insurance proportionate? In Is there dedicated regulation for inclusive insurance and
this context, proportionate regulation is commensurate are requirements for providers proportionate to those
with the nature, scale and complexity of the risks involved established for other financial services providers?
and does not overreach. 0 = There is no dedicated regulation for inclusive insurance
0 = There is no dedicated regulation for inclusive insurance products
products 1 = There is dedicated regulation for inclusive insurance
1 = There is dedicated regulation for inclusive insurance products, but the requirements are not proportionate
products, but the requirements are not proportionate 2 = There is a dedicated and proportionate regulation for
2 = There is a dedicated and proportionate regulation for inclusive insurance
inclusive insurance

4.3.1.a) Existence of data protection laws and privacy bills

2018 2019
Does the country have a data protection law and/or privacy Are there data privacy laws?
bill? 0 = The country does not have any data protection
0 = The country does not have a data protection law and/ regulations that impact the provision of financial services.
or privacy bill 1 = The country has some data protection regulations that
1 = The country has a data protection law and/or privacy bill impact the provision of financial services but does not
have a comprehensive legal framework governing data
protection and privacy.
2 = The country has a comprehensive legal framework
governing data protection that applies both to financial
service providers and to other entities and individuals.

92
5.1.4.a) Degree of interoperability

2018 2019
What are the main payment networks (i.e. Visa, What are the main payment networks (i.e. Visa,
Mastercard, Safaricom, Tigo)? Are there major barriers for Mastercard, Safaricom, Tigo)? Are there major barriers for
interoperability among these networks? Possible barriers interoperability among these networks? Possible barriers
include policy (e.g. there is no mandate for networks to include policy (e.g. there is no mandate for networks to
provide access for low income populations), competition provide access for low income populations), competition
(e.g. there are a few major players with exclusive access (e.g. there are a few major players with exclusive access
to these networks) and cost (e.g. the networks are open to these networks) and cost (e.g. the networks are open
but prohibitively expensive for MFIs and other low income but prohibitively expensive for MFIs and other low income
providers) providers)
0 = There are major barriers to interoperability in the retail 0 = There are major barriers to interoperability in the retail
payments system payments system
1 = There are some barriers to interoperability in the retail 1 = There are some barriers to interoperability in the retail
payment system payment system
2 = The are no barriers to interoperability in the retail 2 = The are no barriers to interoperability in the retail
payments system and interoperability serves as a major payments system and interoperability serves as a major
driver of an inclusive retail payments market driver of an inclusive retail payments market
5.2.1.a) National ID system with digital applications

2018 2019
Is there a national identification system and does it have Is there a national identification system and does it have
digital applications (e-ID)? digital applications (e-ID)?
0 = A reliable national ID system does not exist 0 = No national ID system
1 = There is a reliable national ID that is sufficient to address 1 = National ID exists but it is not e-ID
most KYC concerns but most low-income people do not 2 = National ID exists and it is at least partially an e-ID
have such IDs
2 = There is a reliable national ID that is sufficient to
address most KYC concerns and the majority of the low-
income population has one
3 = There is a reliable national e-ID that is sufficient to
address most KYC concerns
4 = There is a national e-ID that is multi-purpose and is
used in most e-services, including digital signature and/or
remote online services

93
Sources
There are 51 questions in the framework that were scored by the EIU research team based on 143 in-
depth personal interviews with regional and country experts, as well as practitioners and regulators.
Interviews were complemented with secondary research and analysis of laws, regulations and other
legal documents, Economist Intelligence Unit proprietary country rankings and reports, scholarly
studies, websites of governmental authorities and international organisations, websites of industry
associations, and local and international news-media reports.
The EIU leveraged secondary sources to score the remaining 23 indicators to provide the most up-
to-date and comprehensive analysis of the financial inclusion environment. The Global Microscope
2018 uses data collected from the following databases.
Secondary sources
Indicator Source
1.3.1.b Percentage of G2P recipients that receive payments The World Bank (WB). The Global Findex Database, 2017
into an account https://globalfindex.worldbank.org/
2.5.1.a Overall commitment to cybersecurity The International Telecommunication Union (ITU). The
4.3.2.a Law related to Cybercrime Global Cybersecurity Index (CGI), 2017. https://www.itu.int/
en/ITU-D/Cybersecurity/Pages/GCI.aspx
3.2.2.a Restrictions for excessive borrowing The World Bank (WB). Global Financial Inclusion and
4.1.2.a Disclosure of relevant product information Consumer Protection Survey (FICP), 2017. https://www.
worldbank.org/en/topic/financialinclusion/brief/ficpsurvey
4.1.3.a Non-discrimination in financial services provision
4.1.3 b Aggressive sales and debt collection practices
4.1.4.a Standards for complaint resolutions
4.3.1.a Data protection laws and privacy bills The World Bank (WB). Identification for Development
5.2.1.a National ID system with digital applications (ID4D), 2017. http://id4d.worldbank.org/global-dataset
5.2.1.b Gender gap in ID system The World Bank (WB). ID4D-Findex Survey, 2018.
https://id4d.worldbank.org/global-dataset
5.1.1.a ATMs per 10,000 people The World Bank (WB). Global Payments Systems Survey
5.1.1.b POS terminals per 10,000 people (GPSS), 2015. http://www.worldbank.org/en/topic/
financialinclusion/brief/gpss
5.3.2.a Difference in access to internet between men and The Gallup World Poll, 2018. https://www.gallup.com/
women analytics/232838/world-poll.aspx
5.3.6.a Difference in access to a mobile phone between men
and women
5.3.1.a Percentage of households with Internet access The International Telecommunication Union (ITU). World
5.3.3.a Coverage of 2G network Telecommunications/ICT Indicators Database, 2018.
https://www.itu.int/pub/D-IND-WTID.OL-2018
5.3.3.b Coverage of 3G network
5.3.5.a Mobile - cellular telephone subscribers
5.4.3.a Coverage of public credit registry The World Bank (WB). Doing Business Project, 2018.
5.4.3.b Coverage of credit bureau coverage https://data.worldbank.org/products/wdi
For the general and specific-country bibliography, please visit: www.eiu.com/microscope2019

94
Estimating missing data points and a raw data value of 100 gives a score of 100.
If the indicator is in a 0–4 range, a raw data value
Some of the sources used to score the 23
of 0 gives a score of 0, and a raw data value of 4
quantitative indicators did not cover the same
gives a score of 100.
countries than the 2019 Microscope and had
data limitations as a result. The EIU conducted For the purpose of this research we have
primary and secondary research to score the assigned equal weights to each of the categories
countries where data was missing. in the Index. These weights were determined
given that there is no consensus on whether one
For data gaps on the Global Findex we assumed
of the categories is more important than others
missing values were equal to 0 based on primary
to enable financial inclusion. Different countries
and secondary research that revealed that these
may have different challenges and priorities.
countries had no initiatives to digitise payments
For this reason, the user is able to customise the
or very recent initiatives which would result in a
weights in the excel model available in
low percentage of digitised payments.
www.eiu.com/microscope2019
For data gaps on the Word Bank Global
Adjustment factor
Payment Systems data on the number of point-
of-sale (POS) terminals per 10,000 people, an Like in previous editions of the study, the
estimation method was used to score missing overall scores of the 2019 Global Microscope
countries using averages based on income are adjusted to reflect a country’s political
groups as per World Bank’s classification for environment. Political risk can be an important
Cameroon, El Salvador, Nicaragua, Chad, barrier to the provision of affordable and quality
Cameroon, Haiti, Madagascar, Nepal, Senegal financial services. The study uses the EIU’s Risk
Sierra Leone, Panamá, Ecuador, Guatemala, Briefing research to score the extent to which
Ghana, Kenya. In the case of Venezuela this was political institutions are sufficiently stable to
scored based on secondary research. support the needs of businesses and investors.
If the country has a perfect score for political
For data gaps on ITU’s World
stability, no reduction is applied. For a country
Telecommunications/ICT Indicators the gap for
with the worst possible political stability score,
Sierra Leone was filled using an estimate based
the overall score is reduced by 25%.
on a regional average of Sub Saharan Africa
from GSM intelligence.
Normalization and Weights

Once the raw scores are assigned, each score
is then normalised to a 0–100 range and then
aggregated across indicators. Normalisation
rebases the raw indicator data to a common
unit, to make them comparable. The data in
the Microscope are already in a fixed range,
for example, 0–100, 0–4, so they have been
transformed using the min/max of the fixed
range. For example, if the indicator is in a 0–100
range, a raw data value of 0 gives a score of 0,

95
Appendix 1: Detailed scoring guidelines
Sub-indicator Question 2019 Source Scoring guidelines

name
1.1.1 Intra- Is there evidence of EIU 0 = There is no evidence of coordination between government agencies
governmental coordination and active 1 = There is either a strategy or a working committee that promotes
cooperation, implementation between financial inclusion but no evidence of implementation or a digital
strategy and government agencies to approach
implementation promote financial inclusion?
Does it include a digital 2 = There is either a strategy or a working committee that promotes
transformation approach? financial inclusion and evidence of implementation but no digital
approach
3 = There is either a strategy or a working committee that promotes
financial inclusion with a digital approach and there is tangible evidence of
the strategy´s implementation
1.1.2 Data collection Does the government EIU 0 = The government does not collect comprehensive data about financial
regularly collect and publish services for low-income populations or collects data but does not publish
comprehensive data about it
financial services for low- 1 = The government collects and publishes data about financial services
income populations? Is for low-income populations but it is not comprehensive or it is not
the data disaggregated by published regularly
gender?
2 = The government regularly collects and publishes data about financial
services for low-income populations that is comprehensive but it is not
disaggregated by gender
3 = The government regularly collects and publishes comprehensive data
about financial services for low-income populations that is disaggregated
by gender
1.1.3 Intra- Does the national strategy EIU 0= There is no evidence of a financial inclusion strategy or no evidence of
governmental include a gender approach? a gender approach in the existing financial inclusion strategy
cooperation, 1 = There is evidence of a gender approach in the existing financial
strategy and inclusion strategy
implementation
1.1.4 Target agent Does the government EIU 0= There is no evidence of a financial inclusion strategy or no evidence of
network strategy include a target on a target to expand agent networks
the size of agent networks? 1 = There is evidence of a target for expanding agent networks
1.2.1 Financial literacy Is there evidence of a EIU 0 = There is no evidence of a government strategy or programs to
government strategy or promote financial literacy and capabilities
government programs 1 = There is a government strategy to promote financial literacy but no
to promote financial evidence of implementation
literacy and/or strengthen
capabilities? Does it include 2 = There is a government strategy to promote financial literacy and it is
a gender approach? being implemented
3 = There is a government strategy to promote financial literacy, it is
being implemented and it has a gender approach

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1.2.2 Digital Is there evidence of a EIU 0 = There is no evidence of a government strategy or programs to
literacy and government strategy promote digital literacy and capabilities
strengthening or program to promote 1 = There is a government strategy to promote digital literacy but no
capabilities digital literacy and/or evidence of implementation
strengthening capabilities?
Does it include a gender 2 = There is a government strategy to promote digital literacy and it is
approach? being implemented
3 = There is a government strategy to promote digital literacy, it is being
implemented and it has a gender approach
1.3.1 Government Does the government have EIU 0 = The government does not have an initiative, strategy, committee or
payments an initiative to digitise action plan to digitise payments
(G2P and P2G) government payments? 1 = The government has an initiative, strategy, committee or action plan
Are digital accounts fully to digitise payments
mandated or is digitization
limited to some areas?
1.3.1 Government What percentage of World Bank

payments government to person (G2P) Global Findex
(G2P and P2G) recipients received these 2017
payments into a financial
institution account, into
a card, or into a mobile
money account?
1.3.1 Government Does the government have EIU 0 = The government does not have online portals to allow users to make
payments an online portal for digital tax payments and payments for other government services digitally
(G2P and P2G) P2G or B2G tax payments 1 = The government has online portals to allow users to make some tax
and payments for other payments or payments for other government services digitally but not all
government services?
2 = The government has online portals to allow users to make all
government payments digitally
1.3.2 Fostering Has the government EIU 0 = There are no formal spaces or mechanisms for financial innovation
innovation mandated and created 1 = There are formal spaces or mechanisms for financial innovation
formal spaces for financial
innovation (for example a
sandbox, office hours with
regulators, test and learn
financial regulation)

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2.1.1 Market entry Do banks face EIU 0 = Banks face disproportionate restrictions in all of these areas
restrictions for disproportionate 1 = Banks face disproportionate restrictions in three of these areas
banks restrictions in the following
areas that affect the 2 = Banks face disproportionate restrictions in two of these areas
entrance of new providers 3 = Banks face disproportionate restrictions in one of these areas
who serve low and middle- 4 = Banks do not face disproportionate restrictions in any of these areas
income customers?
1. Funding or ownership of
domestic and/or foreign
institutions that perform
financial services
2. Licensing requirements
3. Initial capital
requirements
4. Initial operational
requirements such as
number of branches,
location, entry fee, and/or
data housing if relevant
2.1.2 Market entry Do non-bank EIU 0 = Non-bank financial institutions face disproportionate restrictions in
restrictions financial institutions all of these areas
for non-bank disproportionate 1 = Non-banks financial institutions face disproportionate restrictions in
financial restrictions in the following three of these areas
institutions areas that affect the
entrance of new providers 2 = Non-bank financial institutions face disproportionate restrictions in
who serve low and middle- two of these areas
income customers? 3 = Non-banks financial institutions face disproportionate restrictions in
1. Funding or ownership of one of these areas
domestic and/or foreign 4 = Non-bank financial institutions do not face disproportionate
institutions that perform restrictions in any of these areas
financial services
2. Licensing requirements
3. Initial capital
requirements
number of branches,

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2.1.3 Market entry Do e-money issuers EIU 0 = There is no legal recognition of e-money and there is no evidence of
restrictions for face disproportionate e-money issuers operating legally
e-money issuers restrictions in the following 1 = There is legal recognition of e-money but banks are the only actors
areas that affect the allowed to issue e-money
entrance of new providers
who serve low and middle- 2 = There is legal recognition of e-money and a variety of actors is
income customers? allowed to issue money, but there are disproportionate requirements in
all of the areas described in further restrictions
1. No legal recognition
3 = There is legal recognition of e-money and a variety of actors is allowed
2. Restrictions on the range to issue money, but there are disproportionate requirements in three of
of actors who can act as the areas described in further restrictions
e-money issuers (e.g. only
banking institutions) 4 = There is legal recognition of e-money and a variety of actors is
allowed to issue money, but there are disproportionate requirements in
3. Further restrictions: two of the areas described in further restrictions
a. Funding or ownership of 5 = There is legal recognition of e-money and a variety of actors is allowed
domestic and/or foreign to issue money, but there are disproportionate requirements in one of the
institutions that perform areas described in further restrictions
financial services
6 = There is legal recognition of e-money and a variety of actors is
b. Licensing requirements allowed to issue money, and there are no disproportionate requirements
c. Initial capital in any of the areas described in further restrictions
requirements
d. Initial operational
number of branches,
2.1.4 Market entry Do cross-border EIU 0 = Cross-border payment providers face disproportionate restrictions in
restrictions for payment providers all of these areas
cross-border face disproportionate 1 = Cross-border payment providers face disproportionate restrictions in
payment restrictions in the following one of these areas
providers areas that affect the
entrance of new providers 2 = Cross-border payment providers do not face disproportionate
who serve low and middle- restrictions in these areas
income customers?
1. Overall licensing
framework for cross-
border payments (Here the
important questions is if
non-banks can get licenses
for cross border payments)
2. Funding or ownership of
domestic and/or foreign
institutions that perform
financial services

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2.2.1 Ongoing Do banks face EIU 0 = Banks face disproportionate restrictions in all of these areas
requirements disproportionate 1 = Banks face disproportionate restrictions in three of these areas
for banks requirements in the
following areas that hinder 2 = Banks face disproportionate restrictions in two of these areas
the operation of providers 3 = Banks face disproportionate restrictions in one of these areas
who serve low and middle- 4 = Banks do not face disproportionate restrictions in any of these areas
income customers?
1. Market distorting pricing
controls
2. Taxation of operations
3. Ongoing capital
requirements
4. Ongoing operational
number of branches,
2.2.2 Ongoing Do non-bank financial EIU 0 = Non-bank financial institutions face disproportionate restrictions in
requirements institutions serving low and all of these areas
for non-bank middle-income customers 1 = Non-banks financial institutions face disproportionate restrictions in
financial face disproportionate three of these areas
institutions requirements in the
following areas? 2 = Non-bank financial institutions face disproportionate restrictions in
two of these areas
controls 3 = Non-banks financial institutions face disproportionate restrictions in
one of these areas
2. Taxation of operations
4 = Non-bank financial institutions do not face disproportionate
3. Ongoing capital restrictions in any of these areas
requirements
number of branches,
2.2.3 Ongoing Do e-money issuers EIU 0 = E-money issuers are not legally recognized or face disproportionate
requirements face disproportionate restrictions in all of these areas
for e-money requirements in the 1 = E-money issuers face disproportionate restrictions in three of these
issuers following areas? areas
1. Market distorting pricing 2 = E-money issuers face disproportionate restrictions in two of these
controls areas
2. Taxation of operations 3 = E-money issuers face disproportionate restrictions in one of these
3. Ongoing capital areas
requirements 4 = E-money issuers do not face disproportionate restrictions in any of
4. Ongoing operational these areas
number of branches,

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2.2.4 Ongoing Do cross-border EIU 0 = Cross-border payment providers face disproportionate restrictions in
requirements payment providers all of these areas
on cross-border face disproportionate 1 = Cross-border payment providers face disproportionate restrictions in
payment requirements in the two of these areas
providers following areas?
2 = Cross-border payment providers face disproportionate restrictions in
1. Restrictions on the one of these areas
vehicles to receive
remittances (e.g. can 3 = Cross-border payment providers don’ t face disproportionate
they be delivered to local restrictions in any of these areas
e-money or mobile money
accounts, basic accounts,
savings accounts?)
controls
3.Taxation of operations
2.3.1 Risk-based AML/ Does the country have an EIU 0 = AML/ CFT framework is not harmonized with FATF guidelines
CFT framework Anti-Money Laundering/ 1 = AML/CFT framework is harmonized with FATF guidelines or has a risk
Combating the Financing of based approach
Terrorism legal framework
harmonised with FATF 2 = AML/CFT framework is harmonized with FATF and it has a risk based
guidelines? Does it adopt approach.
the risk-based approach?
2.3.2 Customer Are either banks, non-bank EIU 0 = Customer due diligence requirements are unduly constraining the
due diligence financial institutions serving market for providers serving low and middle-income customers
requirements low and middle-income 1 = Customer due diligence requirements are unduly constraining the
customers, e-money market for some providers serving low and middle-income customers
issuers, and/or cross-
border payment providers 2 = Customer due diligence requirements are not unduly constraining the
disproportionately market for providers serving low and middle-income customers
constrained by customer
due diligence requirements?
2.4.1 Political Is financial regulation EIU 0= Financial regulation is often swayed by political dynamics
independence heavily swayed by political 1= Financial regulation is sometimes swayed by political dynamics
of financial dynamics?
regulation 2 = Financial regulation is independent from political dynamics
2.4.2 Technical Is there a dedicated unit EIU 0 = There is no evidence of a unit or dedicated technical experts to
capacity to or dedicated technical supervise non-bank financial institutions
supervise experts in the regulatory 1 = There are dedicated technical experts with sufficient capacity to
financial services agency and/or Central Bank supervise non-bank financial institutions
that facilitate to supervise non-bank
financial financial institutions like 2 = There are dedicated technical experts with advanced capacity to
inclusion MFIs? supervise non-bank financial institutions
2.4.3 Technical Is there a dedicated unit or EIU 0 = There is no evidence of a unit or dedicated technical experts to
capacity to dedicated technical experts supervise digital financial services
supervise in the regulatory agency 1 = There are dedicated technical experts with sufficient capacity to
financial services and/or Central Bank to supervise digital financial services
that facilitate supervise digital financial
financial services? 2 = There are dedicated technical experts with advanced capacity to
inclusion supervise digital financial services
2.4.4 Technical Are there any women EIU 0 = 0 - 10% of top decision making positions are held by women
capacity to occupying top decision 1 = 10% - 25% of top decision making positions are held by women
supervise making positions in the
financial services financial regulatory bodies? 2 = 25% - 50% of top decision making positions are held by women
that facilitate 3 = > 50% of top decision making positions are held by women
financial
inclusion

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2.4.5 Technical Are supervisors and/ EIU 0 = Regulators are not leveraging technology for digital supervision
capacity to or regulators leveraging 1 = Regulators are leveraging technology for digital supervision
supervise regtech, that is, using
financial services technology tools or
that facilitate approaches to supervise
financial the provision of financial
inclusion services?
2.4.6 Monitoring and Do authorities regularly EIU 0 = Regulators are not monitoring the market to reduce the risk from non-
data collection monitor the market for regulated financial institutions
of financial providers that are not 1 = Regulators are monitoring the market to adequately reduce the risk to
services regulated as financial the financial system from non-regulated financial institutions in operation
providers not institutions but provide but it is not on a regular basis
regulated financial services that can
as financial impact the financial system 2 = Regulators are regularly monitoring the market to adequately reduce
institutions and pose a risk for stability the risk to the financial system from non-regulated financial institutions in
and integrity? operation
2.5.1 Government What is the level United Nations An overall score based on commitment to five pillars:
commitment to of commitment of - Global 1. Legal: Measured based on the existence of legal institutions and
Cybersecurity governments to Cybersecurity frameworks dealing with cybersecurity and cybercrime.
cybersecurity, taking into Index 2018
account the legal, technical, 2. Technical: Measured based on the existence of technical institutions
organizational, capacity and frameworks dealing with cybersecurity.
building and cooperation 3. Organizational: Measured based on the existence of policy coordination
recommendations identified institutions and strategies for cybersecurity development at the national
by specialist agencies? level.
4. Capacity Building: Measured based on the existence of research and
development, education and training programmes; certified professionals
and public sector agencies fostering capacity building.
5. Cooperation: Measured based on the existence of partnerships,
cooperative frameworks and information sharing networks.
3.1.1 Account opening Are account-opening EIU 0 = Account opening requirements are not proportionate
requirements proportionate 1 = Account opening requirements are either proportionate for accounts
for accounts at financial or for e-money but not for both
based on the amounts these 2 = Account opening requirements are proportionate for both accounts
accounts hold? at financial institutions and e-money
3.1.2 Account opening Does the law place any EIU 0 = There are different requirements to open accounts based on sex
restrictions to account 1 = The same requirements apply to open accounts regardless of sex
opening based on sex?
3.1.3 Account opening Do regulations contain EIU 0= There are substantial barriers for remote account opening by banks,
provisions that allow non-banks, e-money issuers and agents
remote account opening by 1 = There are no substantial barriers for remote account opening by banks
banks, non-banks, e-money but there are barriers for non-banks and e-money issuers and/or agents
issuers and/or agents? OR remote account opening is permissible for e-money issuers but not
for banks
2 = There are no substantial barriers for remote account opening by
banks, non-banks, e-money issuers and agents
3.1.4 Safeguarding Does deposit insurance EIU 0 = Deposit insurance is not available or only available to deposits
customer funds exist and is it available to safeguarded in banks
all deposit-holding financial 1 = Deposit insurance is available to all deposit-holding financial
institutions? institutions

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3.1.5 Safeguarding Are funds held in e-money EIU 0 = Funds held in e-money accounts are not protected through any of the
customer funds accounts adequately three mechanisms.
protected through the 1 = One of the three mechanisms listed is in place to protect funds held in
following mechanisms: (i) e-money accounts
prefunding and storage
of funds in safe, liquid
investments; (ii) isolation
of customer funds using
a trust or similar fiduciary
arrangement; and (iii)
application of direct or
pass-through deposit
insurance to e-money
account balances?
3.2.1 Credit risk Is there a differentiated EIU 0= There is no differentiated risk-management framework for consumer
management and comprehensive risk- credit
management framework for 1= There is a differentiated risk-management framework for consumer
credit portfolios (including credit, but supervision of its status is limited
microcredit) that cover
most of the market for 2= There is a differentiated risk-management framework for consumer
middle and low-income credit and the regulator supervises its status
customers?
3.2.2 Over Do specific legal provisions EIU 0 = There is no specific legal provision to restrict excessive borrowing
indebtedness exist to restrict excessive 1 = There is a specific legal provision to restrict excessive borrowing
borrowing by individuals?
3.3.1 Legal certainty Is there a proportionate EIU 0 = There is no framework or working group on fintech or there is a
for Fintech and dedicated legal framework framework but the requirements are disproportionate to the services
other emerging that contemplates provided
services regulation and/or 1 = There is a working group on fintech but no specific requirements have
monitoring of emerging yet been established
services such as P2P lending
and crowd-funding? 2 = There is a proportionate legal framework is in place
3.4.1 Proportionate Is there dedicated EIU 0 = There is no dedicated regulation for inclusive insurance products
regulation regulation for inclusive 1 = There is dedicated regulation for inclusive insurance products but the
insurance and are requirements are not proportionate
requirements for providers
proportionate to those 2 = There is a dedicated and proportionate regulation for inclusive
established for other insurance
financial services providers?
3.5.1 Ease of Do regulations allow a wide EIU 0 = There are both limits on who can serve as an agent, and
operation range of actors to serve disproportionate restrictions that affect commercial viability
as financial outlets and 1 = There are either limits on who can serve as an agent or
are they conducive to the disproportionate restrictions that affect commercial viability
creation of commercially
viable models? 2 = Regulations allow a wide range of actors and are conducive to the
creation of commercially viable models
3.5.2 Breadth of Are agents and other EIU 0 = Outlets face disproportionate restrictions that limit the range of
operations financial outlets allowed services to customers
to offer a wide range of 1 = Outlets are allowed to offer a wide range of services to their
services to their customers customers
on behalf of providers?
3.5.3 Liability Do agent regulations EIU 0 = Financial institutions do not retain any responsibility for the actions of
state that the provider is agents, outlets, and electronic channels
responsible for the actions 1= Financial institutions retain responsibility for some of the actions of
performed by the agent on their agents, outlets, and electronic channels
behalf of the providers?
2= Financial institutions retain responsibility for all of the actions of their
agents, outlets, and electronic channels

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4.1.1 Consumer Is there a framework and a EIU 0= No consumer-rights framework is in place

protection specialised capacity in place 1= Consumer-rights framework exists, but no specialised capacity is in
framework and for financial-consumer place
enforcement protection?
2= Consumer-rights framework exists and some specialised capacity is in
place
3= Consumer-rights framework exists and specialised capacity is in place
4.1.2 Transparency Are there clear rules EIU 0 = There are no requirements
that require providers of 1 = There are requirements
financial services to disclose
information about the
overall cost of the products
and consumer rights and
obligations?
4.1.3 Fair Treatment Are there clear rules set EIU 0 = There are not clear rules to prevent aggressive sales or unreasonable
by the regulator aimed at collection practices
preventing aggressive sales 1 = There are clear rules to prevent aggressive sales or unreasonable
or unreasonable collection collection practices
practices?
4.1.4 Fair Treatment Are there clear EIU 0 = There are not clear rules requiring non-discrimination
rules requiring non- 1 = There are clear rules requiring non-discrimination
discrimination in financial-
services provision in terms
of gender, race, religion,
caste, ethnicity, etc.?
4.1.5 Inclusive Are there programmes or EIU 0 = There is no evidence of programmes or strategies to encourage
provision of strategies to encourage diversity among providers
financial services diversity (of gender, race, 1 = There is evidence of programmes or strategies to encourage diversity
religion, caste, ethnicity) among providers
among providers and agents
of financial services?
4.1.6 Dispute Are there standards in place EIU 0 = The law does not set any standards for complaints resolution
resolution requiring financial-service 1 = The law sets some standards for complaints resolution in these areas
providers to deal with
consumer complaints? 2 = The law sets most of the standards for complaints resolution in these
areas
4.1.7 Financial outlets Are outlets and agents EIU 0 = Agents are not subject to the same consumer protection
and agents subject to similar requirements
transparency, fair treatment 1 = Agents are subject to some of the same consumer protection
and dispute resolution requirements but not all
requirements as banks and
other non-bank financial 2 = Agents are subject to the same consumer protection requirements as
institutions? banks and non-bank”
4.1.8 Digital financial Are e-money providers and EIU 0 = E-money providers and other DFS providers are subject to few or no
services and other DFS providers subject consumer protection requirements that are the same as or similar to the
e-money to similar transparency, requirements for banks and other NBFIs.
fair treatment and dispute 1 = E-money providers and other DFS providers are subject to some
resolution requirements as consumer protection requirements that are the same as or similar to the
banks and other non-bank requirements for banks and other NBFIs, but not all.
financial institutions?
2 = E-money providers and other DFS providers are subject to all
consumer protection requirements that are the same as or similar to the
requirements for banks and other NBFIs.

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4.1.9 Government Are government payments EIU 0 = Government payments are not subject to the same consumer
payments subject to transparency, protection requirements
fair treatment and dispute 1 = Government payments are subject to some of the same consumer
resolution requirements protection requirements but not all
that are similar to those
for banks and non-bank 2 = Government payments are subject to the same consumer protection
financial institutions? requirements as banks and non-bank financial institutions
4.2.1 Protection Does consumer protection EIU 0 = The regulation does not stipulate requirements for insurance
for inclusive regulation stipulate customers
insurance requirements for 1 = The regulation stipulates requirements but they are not proportionate
providers insurance customers? Do to the requirements of financial services providers
requirements resemble
those of financial services 2 = The regulation stipulates requirements and they are proportionate to
providers? the requirements of financial services providers
4.3.1 Data protection Are there data privacy laws? EIU 0 = The country does not have any data protection and privacy
and privacy regulations that impact the provision of financial services.
1 = The country has some data protection and privacy regulations
that impact the provision of financial services but does not have a
comprehensive legal framework governing data protection and privacy.
2 = The country has a a comprehensive legal framework governing data
protection and privacy that applies both to financial service providers and
to other entities and individuals.
4.3.2 Cybercrime legal Does the country have a law United Nations EIU team will answer
protection related to cybercrime? - Global
Cybersecurity
Index 2018
4.3.3 Privacy laws Is there a government EIU 0 = There is no government entity with a mandate to enforce data
enforcement entity that enforces privacy protection laws
laws and does it have the 1 = There is a government entity but its capacity to enforce data
capacity to enforce them? protection laws is limited
2 = There is a government entity with strong capacity to enforce data
protection laws
5.1.1 Access to cash- How accessible is the World Bank Automatic teller machines (ATMs) per 10,000 people
in/cash-out payments infrastructure
and transaction to low and middle-income
points populations? (Branches,
ATMs, PoS devices, and
mobile money/banking
agents)
5.1.1 Access to cash- How accessible is the World Bank Point-of-sale (POS) terminals per 10,000 people
in/cash-out payments infrastructure
and transaction to low and middle-income
points populations? (Branches,
ATMs, PoS devices, and
mobile money/banking
agents)

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5.1.2 Access to Do regulations mandate EIU

retail payment fair and non-discriminatory
infrastructure commercial access to retail
payment infrastructure
including:
1. National payment systems 0 = Regulations do not mandate fair and non-discriminatory commercial
and switches access to national payment systems and switches
1 = Regulations mandate fair and non-discriminatory commercial access
to national payment systems and switches
2. ATMs 0 = Regulations do not mandate fair and non-discriminatory commercial

access to ATMs
to ATMs
3. Automatic Clearing 0 = Regulations do not mandate fair and non-discriminatory commercial

Houses access to ACHs
to ACHs
4. Credit and debit card 0 = Regulations do not mandate fair and non-discriminatory commercial
networks access to credit card networks
to credit card networks
5.1.3 Access to Do regulations mandate EIU 0 = Regulations do not mandate fair and non-discriminatory commercial
telecommunica- fair and non-discriminatory access to telecommunications bearer services such as USSD, SMS, and
tions bearer commercial access to internet
services telecommunications bearer 1 = Regulations mandate fair and non-discriminatory commercial access
services such as USSD, SMS, to telecommunications bearer services such as USSD, SMS, and internet
and internet?
5.1.4 Interoperability What are the main EIU 0 = There are major barriers to interoperability in the retail payments
payment networks (i.e Visa, system
Mastercard, Safaricom, 1 = There are some barriers to interoperability in the retail payment
Tigo)? Are there major system
barriers for interoperabilty
among these networks? 2 = The are no barriers to interoperability in the retail payments system
Possible barriers include and interoperability serves as a major driver of an inclusive retail
policy (e.g. there is no payments market
mandate for networks
to provide access for
low income popuations),
competion (e.g. there are
a few major players with
exclusive access to these
networks) and cost (e.g.
the networks are open but
prohibitely expensive for
MFIs and other low income
providers)
5.2.1 Digital ID system Is there a national World Bank 0 = No national ID system

identification system ID4D Dataset 1 = National ID exists but it is not e-ID
and does it have digital
applications (e-ID)? 2 = National ID exists and it is at least partially an e-ID
5.2.1.b Gender Gap in Percentage difference ID4D Findex Calculated by subtracting the share of women without and ID indicator
ID system between women without Survey Data from share of men without an ID in the ID4D Findex Survey Database
access to an ID compared
to men

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5.2.2 Automated KYC Is there an automated EIU 0 = No, the government does not provide an automated mechanism for
mechanism for e-KYC e-KYC or has not approved one
verification (like an 1 = Yes, there is an automated mechanism for e-KYC verification provided
e-signature) provided or approved by the government
or approved by the
government?
5.2.3 Non- Do laws or regulations place EIU 0 = Laws and/or regulations place additional restrictions to access of IDs
discriminatory any restrictions to access based on sex
access to IDs of digital ID’s and/or eKYC 1 = Laws and/or regulations do not place additional restrictions to access
verification systems based of IDs based on sex
on sex?
5.3.1 Internet access Percentage of households ITU Internet users as a % of households

with Internet access
5.3.2 Gender gap in Percentage difference Gallup World Percent of females whose home has access to the internet
internet access between women who Poll
stated that they had access
to the internet in their
homes compared to men
5.3.3 Network Percentage of the ITU Network coverage (minimum 2G), % of population
coverage population covered by at
least a 2G mobile network
5.3.3 Network Percentage of the ITU Network coverage (minimum 3G), % of population
coverage population covered by at
least a 3G mobile network
5.3.5 Mobile Mobile-cellular telephone ITU Mobile subscribers, per 100 inhabitants
subscribers subscriptions per 100
inhabitants
5.3.6 Gender gap Percentage difference Gallup World Percent of females whose home has access to a cellular phone
in mobile between women who Poll
subscribers stated that they had a
mobile phone for personal
calls compared to men
5.4.1 Comprehensive Is the information stored by EIU 0= Credit-reporting systems do not exist OR credit bureaus store
information credit-reporting systems information that has none of the items required for a score of “3”
comprehensive, regularly 1= Credit-reporting systems store information that has one of the items
updated and accessed by needed for a score of “3”
providers?
2= Credit-reporting systems store information and it is both
comprehensive and accessed by providers, but not updated regularly OR
regularly updated but not comprehensive
3= Credit-reporting systems store information that is comprehensive,
regularly updated and accessed by providers
5.4.2 Access to Can individuals access their EIU 0= Individuals cannot access their records or correct any errors
records records and are they able to 1= Individuals may access their records, but may not correct any errors
correct any errors? Is there
a fee to access the records? 2= Individuals may access their records, but the error-correction process
is difficult OR expensive
3= Individuals may access their records and the error-correction process
is easy and inexpensive

107

name
5.4.3 Coverage of Public credit registry World Bank Public credit registry coverage reports the number of individuals and
credit reporting coverage (% of adults) firms listed in a public credit registry with current information on
systems repayment history, unpaid debts, or credit outstanding. The number is
expressed as a percentage of the adult population.
5.4.3 Coverage of Private credit bureau World Bank Private credit bureau coverage reports the number of individuals or firms
credit reporting coverage (% of adults) listed by a private credit bureau with current information on repayment
systems history, unpaid debts, or credit outstanding. The number is expressed as a
percentage of the adult population.

108
While every effort has been taken to verify the

accuracy of this information, The Economist
Intelligence Unit Ltd. cannot accept any
responsibility or liability for reliance by any
person on this report or any of the information,
opinions or conclusions set out in this report.
The findings and views expressed in the report
do not necessarily reflect the views of the
sponsor.
Cover image: Shutterstock

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Global Microscope 2019

The enabling environment

About this report

The Global Microscope assesses the enabling environment for financial

The Microscope was originally developed for countries in the Latin

The complete index, as well as detailed country analysis, can be viewed on

Please use the following when citing this report:

EIU (Economist Intelligence Unit), 2019; Global Microscope 2019: The

For further information, please contact:

© The Economist Intelligence Unit Limited 2019

About the Economist Intelligence Unit About IDB Lab

© The Economist Intelligence Unit Limited 2019

Project teams Acknowledgements

Bill & Melinda Gates Foundation

Special thanks to Elisabeth Rhyne, former

© The Economist Intelligence Unit Limited 2019

About this report 1

© The Economist Intelligence Unit Limited 2019

The 2019 Global Microscope analyses the Key findings

Improved frameworks for digital financial

Ten of the 55 countries in the 2019 Microscope

© The Economist Intelligence Unit Limited 2019

account opening and established a dedicated Gender-related findings

Data from the 2019 Microscope and the Global

© The Economist Intelligence Unit Limited 2019

9% for all countries. When women have better

Most countries need to achieve greater

In 37 of the 2019 Microscope’s 55 countries,

© The Economist Intelligence Unit Limited 2019

Rank Score Rank Score

1 ←→ Colombia 82 +1 =29 ▲ 11 Cameroon 51 +8

2 ←→ Peru 80 +2 =29 ▲7 Egypt 51 +6

3 ←→ Uruguay 76 +1 =29 ▲2 Morocco 51 +1

4 ▲2 Mexico 74 +4 32 ▲2 Trinidad and Tobago 50 +1

=5 ▼1 India 71 -1 =33 ▲2 Turkey 49 +1

=5 ▼1 Philippines 71 -1 =33 ▲4 Vietnam 49 +5

=7 ▲2 Argentina 70 +6 =35 ▼4 Ghana 48 -2

=7 ←→ Indonesia 70 +1 =35 ▼ 12 Jamaica 48 -6

© The Economist Intelligence Unit Limited 2019

Inclusion of a gender approach in digital

6. Non-discrimination in account opening

© The Economist Intelligence Unit Limited 2019

National identification system Internet Mobile phone

21 countries 41 countries 34 countries

© The Economist Intelligence Unit Limited 2019

error were highest for mobile money, compared

As the landscape for financial inclusion

2 FinAccess. 2019. “2019 FinAccess household survey.” [https://s3-eu-central-1.

© The Economist Intelligence Unit Limited 2019

© The Economist Intelligence Unit Limited 2019

In focus: Government and policy support

1. Government and policy support

Indicator # Indicator name Sub-indicator # Sub-indicator name Question name

Intra-governmental Evidence of intra-

Intra-governmental Evidence of intra-

Broad strategies for Strategy to expand agent

Support for financial