This timely report draws on 30 semi-structured interviews and extensive desk-based research across 9 EMDEs: Brazil, Egypt, Ghana, India, Indonesia, Nigeria, Saudi Arabia, South Africa and the Philippines. Much of open finance’s growth and greatest potential is concentrated in these markets, yet many face limited resources, stretched regulatory capacity and legal and data protection frameworks that are still being developed. They cannot simply replicate the models adopted in advanced economies. For the regulatory authorities pursuing open finance, the task becomes one of prioritisation under constraints: identifying the few design choices likely to carry the most far-reaching implications and sequencing them sensibly. Decisions of this nature call for a stronger evidence base, one that this report begins to develop.
The 3 pillars are interdependent, and that changes how regulators can sequence reform
The report’s central contribution is a framework, applicable well beyond the 9 countries studied, that considers incentives, liability and performance measurement together rather than as separate questions. Because the pillars interact, a gap in one can be at least partially offset by another, allowing regulators to rebalance over time rather than resolve everything at once. The report acknowledges the differences between the countries studied and the size of the sample behind its conclusions. Despite these differences, every open finance ecosystem must perform a common set of core functions, and it is in comparing how each market meets them that the report’s novel insights emerge
“Open finance is being shaped in emerging markets and developing economies as much as anywhere else, yet regulators there face choices that cannot simply be borrowed from advanced economies,” says Bryan Zhang, co-founder and executive director of CCAF. “This report shows that incentives, liability and performance measurement are interdependent, which means progress in one area can help offset constraints in another. That gives regulators a practical way to sequence reform under real-world constraints.”
Open finance is being shaped in emerging markets and developing economies as much as anywhere else, yet regulators there face choices that cannot simply be borrowed from advanced economies.
Mandates set the floor, but incentives, and customers, determine the impact
A recurring finding is that mandates alone may be unlikely to deliver meaningful participation. Whether an ecosystem is regulation-led or market-driven, its success depends on whether data holders, data users and customers perceive genuine value in taking part. Incentive design needs to reflect local market structure rather than default to bank-centric assumptions, particularly where mobile network operators dominate transactional data. On liability, the report finds that open finance builds upon existing financial, data protection and consumer protection frameworks rather than creating accountability mechanisms from scratch. However, open finance–specific reforms or supplementary regulations may be required to address the novel risks and challenges arising from the implementation of open finance. On performance measurement, it argues that frameworks must go beyond technical and adoption metrics to track the policy objectives that motivated reform in the first place.
“Mandates can set the floor for participation, but they rarely deliver meaningful participation on their own,” comments Pavle Avramovic, director of Research and Policy at Financial Innovation for Impact. “What sustains an ecosystem is whether data holders, data users and, above all, customers see real value in taking part. Too often the customer is the missing piece, and our evidence suggests that placing them at the centre of design is what ultimately allows open finance to function.”
Too often the customer is the missing piece, and our evidence suggests that placing them at the centre of design is what ultimately allows open finance to function.
A practical, evidence-based foundation for design choices
Alongside its analysis, the report offers regulators concrete tools, including a typology of commercial models, four broad liability models, and a catalogue of technical and policy outcome metrics mapped to the data-sharing lifecycle. This launch is part of CCAF and Fii’s broader mission to support evidence-based financial regulation and the inclusive growth of digital financial ecosystems worldwide.
Download the report
‘Enabling Open Finance in EMDEs: Incentives, Liability, and Performance Measurement’ was produced by the Cambridge Centre for Alternative Finance (CCAF) in collaboration with Financial Innovation for Impact.
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