Innovation for Inclusion: A Roadmap for Inclusive Finance Policy to Navigate Rapid Technological Change

Part 1. Seizing a Pivotal Moment: Prioritizing Policy Action to Harness Technological Innovation for Inclusive Finance

Financial sector authorities have an opportunity to continue fostering financial inclusion—and, through it, drive broader economic growth and shared prosperity

Over the past three decades, inclusive finance has developed in waves, each one marked by breakthrough innovations and new ambitions. The first wave demonstrated that even the poorest are bankable, as microfinance unlocked livelihoods for millions. The second wave introduced e-money and the broader digitalization of financial services, expanding access and increasing efficiency across both the customer-facing and back-end processes of financial service providers (FSPs). Agent banking played a central role in this transformation, providing the cash-in and cash-out infrastructure that made e-money accessible to low-income customers and hard-to-reach communities.

As these waves unfolded, financial inclusion was able to scale rapidly when technological innovation, enabling regulation, and incentives aligned. Today, 79 percent of adults globally hold a transaction account, up from 51 percent in 2011. In low- and middle-income countries (LMICs), access has reached 75 percent. Further, there has been a 28-percentage point increase in the number of adults in LMICs who made or received a digital payment since 2011, as well as a 23-percentage point increase in the number of adults in LMICs who save money in either a formal financial institution account or mobile money account (Klapper et al. 2025). Much of this recent progress has been powered by the rise of mobile money and other digital financial services.

Yet the scale of this progress should not obscure how much remains to be done—or how qualitatively different the remaining challenges may be. Despite the headline gains, 1.3 billion adults worldwide remain without access to any formal financial account. These are, by definition, the hardest to reach: those in remote geographies, in the informal economy, with low digital and financial literacy or limited connectivity, and those who have historically been excluded by the very design of financial products, such as women.

In addition, the challenge goes beyond account access, with many individuals in LMICs also still lacking access to core financial products. For instance, up to 4 billion people in emerging economies are un- or under-insured (Kara et al. 2025), whilst only 35 percent of working-age individuals globally actively contribute to a pension (ILO 2024). In the past year, only about a quarter of adults in LMICs used formal credit (Klapper et al. 2025), and in 2023, the financing gap for formal MSMEs in emerging markets and developing economies—businesses that generate critical employment in these economies—was estimated at US$4 trillion (IFC forthcoming).

Moreover, many people who are considered financially included today still struggle to withstand shocks, smooth consumption, and invest in their futures. Nearly half of adults in LMICs cannot cover one month of household expenses in an emergency (Klapper et al. 2025). Having a bank account has not, for many, fully translated into improved livelihoods or financial health.

Looking ahead, continued progress in financial inclusion is not guaranteed: enabling meaningful financial inclusion in the coming years will require more than simply replicating the models that worked in the past. It will demand the smart use of next-generation technologies (Sirtaine and Schlein 2025a), forward-looking policy choices, and a broader menu of relevant financial services—savings, insurance, credit, pensions, investments—designed, priced, delivered, and regulated in ways that truly meet people's diverse needs, support their financial health, and ultimately increase economic growth and shared prosperity.

The world is now at a pivotal moment: amid rapid technological disruption, today's policy choices could impact progress in financial inclusion for years to come

Today, the world stands at the threshold of a new wave of inclusive finance—one defined not by incremental change, but by a sweeping transformation of the financial landscape. What sets this period apart is not only the scale and speed of change, but its very nature. Financial services are no longer discrete products delivered through isolated channels; they have become ubiquitous, modular, and deeply embedded in commerce and everyday life (Zetterli 2021; Mitha et al. 2022).

Platform-based finance, neobanks, and Banking-as-a-Service (BaaS) models are intensifying competition and spurring innovation in financial services (Jeník and Zetterli 2020). The expansion of customer data sharing through open finance frameworks has further pushed the frontier of business models and product offerings. Meanwhile, the boundaries between financial and non-financial activities are blurring, as embedded finance integrates into the daily lives of people across income levels and geographies. Policymakers have been grappling with these changes for several years already, but the horizon continues to expand with emerging capabilities such as agentic and generative AI, blockchain, decentralized finance, and tokenization.

This wave of transformation brings tremendous opportunities for LMICs. Digitalization can lower transaction costs, data-driven insights allow providers to better understand risk and customer needs, and new business models enable providers to reach populations that were previously costly or difficult to serve—opportunities that offer ways to unlock solutions to problems that once seemed intractable. For instance, transactional data can predict credit worthiness with accuracy comparable to, and in some cases outperforming, traditional credit scoring (Björkegren and Grissen 2020; Caire and Fernandez Vidal 2024). Voice interfaces and automated agents, powered by generative and agentic AI, can hyper-personalize financial journeys, expand consumer choice, and lower language barriers (Salman et al. 2024; Sirtaine and Schlein 2025b). Standardized APIs are reshaping competition, interoperability, and data sharing across industries, whilst blockchain has strong potential to disrupt traditional cross-border payments, financial contracts, and record-keeping. Such solutions can build on the progress in financial inclusion made by mobile money and digital financial services, strengthening positive customer outcomes and financial health.

Yet these same forces present significant new risks that could stall progress in financial inclusion or potentially reverse earlier gains. New technologies and innovations can deepen the digital divide—especially for women and other vulnerable groups—while heightening risks of frauds, scams, data misuse, and over-indebtedness. They can also introduce algorithmic bias and data-driven discrimination for individuals with limited digital footprints and outpace policy and supervisory frameworks. For instance, AI systems trained on historical data risk reinforcing existing biases, particularly where underrepresented populations and local languages are poorly captured (Appaya and Ng 2025); market concentration among a small number of technology and cloud providers heightens systemic risk, while business size increasingly determines who can afford new technologies, widening the digital divide (OECD 2025a); fraud and data misuse are becoming more sophisticated (Duflos 2025); and deployment of new innovations can be selective and uneven, with early adoption of more sophisticated digital financial services often skewing toward higher-income, better-connected customers (for example, see Youxue and Shimei 2022; CGAP n.d.-a).

At the system-level, the complexity of these emerging opportunities and risks calls for a deliberate policy response from financial sector authorities (FSAs)—one that enables innovation to advance financial inclusion while also strengthening consumer protection, financial integrity, and the stability and resilience of the financial system.

Furthermore, as this wave of transformation reshapes competition, value creation, and distribution in financial services, it is placing consumers at the center of a complex ecosystem where they may benefit or be more exposed to exclusion and harm. Regulatory and supervisory frameworks must evolve to keep pace with the speed, scale, and complexity of innovation and associated consumer risks, minimizing harm while building trust, supporting market development and growth, and strengthening financial inclusion, resilience, and opportunity. In this evolving landscape, policy choices made by FSAs—not technology itself—will be instrumental in determining whether this wave of transformation becomes a force for continued progress in financial inclusion or a pathway to deeper exclusion and entrenched vulnerability.

FSAs must proactively guide this transition to benefit the maximum number of people, especially the most vulnerable, while maintaining a strong financial system. Critically, technological developments driven by market forces alone are unlikely to serve core policy objectives (World Bank 2022) or address key market failures. FSAs have a critical role to play in establishing intentional, fit-for-purpose guidance, safeguards, and incentives for industry players to leverage technology in an inclusive manner and address remaining market failures, protect consumers, and foster equitable economic growth.

The implication for FSAs is clear: Only purposeful, timely policy will determine if accelerating digital transformation continues to be a force for shared prosperity rather than risk.

In this era of rapid change, financial sector authorities urgently need an action plan

Meeting this challenge is no small feat. FSAs in LMICs are navigating an increasingly complex landscape that is changing faster than ever before. The technological knowledge required is vast and multidisciplinary. The coordination needed—across central banks and financial sector-specific authorities, financial intelligence units, consumer protection bodies, competition authorities, data protection authorities, public sector agencies outside the financial sector, the private sector, international organizations, and the donor community—is substantial. And in many cases, regulatory and supervisory institutions are operating with limited staff capacity, constrained budgets, competing demands, and in a landscape where sectoral distinctions have become blurred (Coelho and Guerra 2024; Adrian et al. 2023).

The time to act on these emerging technological trends is now. FSAs that are proactive will be far better positioned to shape outcomes in their financial systems and safeguard progress in financial inclusion. Accordingly, some FSAs have begun rethinking their strategy and role in enabling innovation and technology in their financial systems, prioritizing enabling policies, adopting proactive, intentional risk frameworks, and strengthening internal policies, processes, resources, and workforce capabilities. But doing so demands clarity on priorities, an understanding of critical trade-offs, and a sustained focus on financial inclusion and customer outcomes.

This paper offers a roadmap for FSAs, in partnership with key stakeholders, to navigate this evolving financial landscape and develop policy approaches that incentivize and safeguard innovation to achieve greater financial inclusion and positive societal impact, while preserving financial stability and other core policy mandates. By identifying which technology-related policy choices matter most from an inclusion perspective, this roadmap helps FSAs prioritize their short- and medium-term actions that can have the greatest impact on inclusion.

Part 2. Turning Vision into Action: A Roadmap for Leveraging Innovation to Advance Inclusion

As outlined in Part 1, the future of inclusive finance will be intertwined with a set of emerging and disruptive innovations including big data, generative and agentic AI, data-sharing frameworks, quantum computing, blockchain,¹ and new forms of privately issued digital money or money-like instruments.² In this future, the ability for individuals and businesses to participate in the financial system will be increasingly determined by who can access—and benefit from—technology and innovation. Countries with strong digital public infrastructure and solid policy foundations will advance the fastest in creating inclusive financial systems, while the countries that fail to create inclusive digital foundations and enabling policies risk seeing widening financial inclusion gaps.

The next phase of inclusive finance will be shaped by whether individuals have the tools, the understanding, and the trust to fully participate in and benefit from financial ecosystems that are rapidly evolving. To advance financial inclusion in this new era, FSAs must anticipate change and steer innovation, rather than merely reacting to it. With rapid, concurrent innovation and limited resources, their challenge is to prioritize policy and regulatory actions that ensure innovation advances financial inclusion while safeguarding broader policy objectives.

The policy roadmap presented in this section is designed to guide FSAs, and those that support them, as they navigate this challenge. It aims to help them leverage technology and innovation to advance financial inclusion, mitigate subsequent risks to the broader financial system, and protect financial consumers. It culminates in six strategic policy priorities to harness innovation for inclusive finance. However, before arriving at these priorities, it provides guidance on implementing a number of recommended prerequisites: (i) defining a strategic vision with guiding principles to anchor subsequent policy decisions; (ii) investing in foundational infrastructure that shapes who can access and benefit from innovation and technology in finance; and (iii) strengthening critical guardrails to safeguard trust, stability, competition, and integrity across the broader financial ecosystem.

In this way, the roadmap helps FSAs prioritize a few transformative policy choices to improve financial inclusion through innovation while preserving financial stability and resilience. It is not an exhaustive list of every policy relevant for addressing existing market failures, nor does it cover all the tools necessary for FSAs to fulfill broader mandates, such as safeguarding stability and integrity and promoting market development. Rather, it is focused on those policy choices that are most likely to create inclusive financial sectors.

While the guiding principles, foundational infrastructure, and critical guardrails create the enabling environment for the six transformative policy priorities to be effective, they do not need to be implemented sequentially. This reflects the reality that countries operate under different institutional capacities, market conditions, and resource constraints. Although some elements are critical to long-term success, authorities can advance these three layers at different speeds and tailor implementation to their national context.

Define a Vision with Guiding Principles to Anchor Subsequent Policy Decisions

To effectively connect high-level objectives with policy decisions, FSAs should articulate a strategic vision supported by clearly defined principles that inform their policy choices (Jeník et al. 2025).³ This visioning exercise goes beyond developing aspirational statements; it requires establishing the guiding principles that will shape the future of inclusive financial ecosystems. While each country's vision should reflect its own institutional context, development goals, and barriers to inclusion, any effort to build an inclusive financial ecosystem that harnesses innovation and technology should follow three overarching principles. The ecosystem should strive to be customer-centric, responsible, and outcome-driven.

• CUSTOMER-CENTRIC: Who the ecosystem is designed for
  This principle ensures that innovation responds to the needs, capabilities, and realities of everyone in the country, including underserved populations. This is especially relevant in LMICs, where exclusion is often driven by supply-side and demand-side frictions (i.e., distance, costs, information asymmetries, literacy). A customer-centric vision can encompass accessibility, affordability, usability, relevance, and inclusion-by-design.
• RESPONSIBLE: How innovation should be governed
  This principle governs the quality and integrity of innovation and technology. It signals that FSAs encourage innovation while safeguarding trust and the soundness of the financial system. This principle ensures that supervisory capacity does not lag market innovation, that consumers are actively protected, that digital fraud is actively prevented, and that market integrity, operational resilience, and stability are safeguarded as public goods. Encouraging responsible financial ecosystems ensures that innovation does not come at the expense of fairness, safety, stability, and soundness.
• OUTCOME-DRIVEN: How success should be evaluated
  This is perhaps the most strategically important principle in developing a vision for harnessing financial innovation, because it prevents authorities from equating technology implementation with progress. An outcome-driven approach prioritizes measurable improvements in financial inclusion, customer financial health, and broader development outcomes, over technology adoption alone. This principle emphasizes use and utility rather than mere access and confers a central role to real economic, financial, and digital participation. In such ecosystems, innovation should enable financial services to measurably improve financial health and other development outcomes.

These are not abstract principles. They are practical lenses through which authorities can assess policy trade-offs, prioritize interventions, and measure success. The value of embedding these principles in the visioning exercise becomes evident as we move through this roadmap.

Invest in Foundational Infrastructure that Shapes Who Can Access and Benefit From Innovation and Technology in Finance

Innovation can make financial systems more inclusive when built on accessible, interoperable, efficient, and secure infrastructure. Investing in this foundational infrastructure is a critical first step in turning a customer-centric, responsible, outcome-driven vision into reality. Such investments often lie beyond the direct control of FSAs and require a multi-stakeholder effort across the public and private sectors.

Three key investments are particularly relevant from an inclusion perspective: hard infrastructure, digital public infrastructure, and soft infrastructure (Graf et al. 2026). Collectively, these investments lay the foundation for harnessing technology to deliver faster, more secure, and scalable financial services for all.

Hard Infrastructure

Investing in hard infrastructure to provide reliable electricity, broadband connectivity, 4G/5G mobile networks, and data centers enables active participation in the digital economy. Recognizing the strategic importance of hard infrastructure for growth and competitiveness, public authorities worldwide are increasingly adopting time-bound national digital technology strategies to expand connectivity, strengthen digital capabilities, and support the development of digital ecosystems (OECD 2025b; Quevedo-Vega et al. 2025b; Clark et al. 2025; Graf et al. 2026). To be effective, however, the infrastructure needs to not only be scalable, but also accessible, affordable, inclusive, and resilient.

For financial inclusion, these investments are foundational and make a positive impact on both the supply and demand of inclusive financial services. In many LMICs, exclusion persists even when financial services are available, because individuals and businesses lack reliable access to electricity, broadband connectivity, and mobile coverage. Expanding hard infrastructure into rural and underserved areas is therefore a critical priority for enabling participation in digital financial ecosystems. Improved connectivity and affordable access to digital technologies can reduce transaction costs; improve convenience; strengthen the reliability of mobile wallets, agent banking, and digital identity systems; and support broader participation in data-sharing frameworks. As financial ecosystems become increasingly data-driven, scalable cloud infrastructure and computing capacity are also becoming more important for supporting secure and efficient financial services delivery.

Emerging technologies, such as blockchain and artificial intelligence, further increase the importance of hard infrastructure. These technologies require reliable connectivity, data storage, and scalable computing capacity. When those are in place, these emerging technologies can support new forms of identification, reduce costs across the financial services value chain, enable new forms of credit assessment and collateral, and improve the price and speed of cross-border payments and record-keeping (World Bank 2019; World Bank n.d.-b).

For LMICs, investing in hard infrastructure can be costly. This is why innovations such as edge computing⁴ and cloud-based computing-as-a-service (CaaS)⁵ have gained importance. They can reduce the cost, complexity, and infrastructure requirements associated with deploying advanced digital and financial technologies at scale. For example, in rural areas, where internet reliability often remains uneven, edge computing can support offline operations, while CaaS can significantly reduce the upfront capital costs associated with accessing cloud services. However, authorities should avoid the temptation to treat these tools as substitutes for long-term investments in reliable hard infrastructure. Instead, they should be understood as tools that help countries with resource constraints to progressively scale innovation (Graf et al. 2026).

Digital Public Infrastructure (DPI)⁶

DPI are the digital building blocks that go on top of hard infrastructure and that enable interoperable digital financial systems. DPI typically includes three core layers: identity verification and authentication, instant payments, and data-sharing frameworks. Together, they provide the digital rails that enable inclusive financial ecosystems to scale. Investing in DPI is a shared responsibility among public authorities,⁷ the private sector, and funders, including regional development banks. However, FSAs have a central role to play in ensuring that DPI is governed as a public good, mandating interoperability, promoting broad participation, and aligning infrastructure design with inclusion objectives rather than just efficiency.

Ensuring that everyone has a digital identity is foundational to inclusive finance⁸ as it simplifies customer onboarding, know-your-customer (KYC) and anti-money laundering (AML) compliance, as well as reducing the need for physical documentation and cost of travel, which is particularly important in remote areas. India's Aadhaar system demonstrates how digital identification (ID) can accelerate financial inclusion (see Box 1).

Fast payment systems constitute another critical layer of DPI. They enable individuals and businesses to transfer funds securely and reduce the reliance on cash. In many LMICs, fast payment systems, along with digital identity frameworks, have enabled authorities to digitize government-to-person (G2P) transfers, social protection payments, pensions, and wages, creating entry points for many new customers into the formal financial system. This is particularly beneficial for women, informal workers, and rural populations. In addition, the transaction histories and digital data trails created by fast payment systems can help financial service providers better assess customer needs, risk profiles, and financial behavior, thereby supporting access to additional services beyond just payments, such as credit, savings, and insurance.

In addition to fulfilling key functions in digital financial systems, digital IDs and fast payment systems generate valuable financial data, creating a need for data-sharing frameworks. These are the third layer of a DPI and help optimize the flow and use of data in the digital economy (Clark et al. 2025). At a minimum, they need to include several components: consent management systems, open APIs / standardized protocols, security and encryption protocols, and interoperable data registries. Once these data-sharing frameworks are in place, they provide the foundation for FSAs to create the market architecture for open finance systems.

Just a decade ago, open finance did not exist. Today, active initiatives are underway in 60 countries, with a further 22 in development or planned (CCAF n.d.). Open finance frameworks are quickly becoming the new baseline standard for data-sharing frameworks and are becoming an important component of DPI. They improve financial inclusion by enabling consumers to voluntarily share their financial data with regulated third parties in order to access more tailored financial services, thereby delivering greater utility to underserved or poorly served customers. Inclusive open finance frameworks should be built around 10 key principles⁹ (CGAP et al. 2024a).

In particular, FSAs should focus on establishing the following:

i. Clear reciprocity and economic and non-economic incentives for data-sharing to help avoid "free rider" problems and shift the burden of data portability from consumers to financial institutions (Mazer 2026). While data sharing should be free for customers, between providers pricing should balance the operational costs incurred by data holders (e.g., API maintenance and securing information) with the affordability barriers of data users.¹⁰

ii. Technical standards for interoperability and data quality to increase the value of shared data, encourage customer-centric solutions, and foster innovation.

iii. Customer-centric safeguards to build customers' trust through explicit consent, data portability, recourse mechanisms, and clear liability rules.

iv. Controlled experimentation environments¹¹ to explore relevant use cases and build know-how under secure and auditable conditions (Lema et al. 2025; Financial Conduct Authority 2026).

For FSAs wanting to implement or scale DPI, there are well-documented benchmarking practices that they can follow and that include specific considerations for LMICs (World Bank 2021; GPFI and World Bank Group 2018; CGAP et al. 2024b; Clark et al. 2025; Gates Foundation n.d.).

Soft Infrastructure

Even countries with well-developed hard infrastructure and digital public infrastructure may struggle to leverage technological advances and innovation to build more efficient and inclusive financial systems if they do not have a sufficient base of skills, expertise, or knowledge around digital and financial technology and innovation. Investment in soft infrastructure should therefore be another strategic national priority and a core component of long-term digital and technology agendas—including within the financial sector.

Such investments typically encompass education, innovation support, research, and community building, all of which are essential for innovation and technology to thrive (Graf et al. 2026). For the financial ecosystem, deploying and overseeing increasingly complex technologies requires investing in human capital through knowledge exchange with technology experts, experimentation with new technologies, and comprehensive in-house training programs.

This can be done through structured efforts such as (i) creating national digital strategies targeted at the specific industries, technologies, or sectors that are considered strategically important for growth, competitiveness, or national security—including the financial sector; (ii) developing advanced training programs, in collaboration with universities and research centers, on specific technologies; and (iii) convening informal communities of practice, which are particularly relevant in LMICs, where formal training channels on frontier topics tend to be limited and often unavailable in local languages (Graf et al. 2026).¹²

For the FSAs themselves, it includes expanding their in-house capacities to proactively monitor, test, and safely govern innovation. As the pace and scope of structural change accelerate, technology awareness is no longer enough. FSAs will also need to invest in their own internal soft infrastructure to improve technology fluency. Upskilling staff or recruiting the right expertise should be treated as a strategic investment. Building internal capacity to understand the potential and risks of existing and future technological advancements not only creates a culture of continuous learning but also provides assurance that regulatory guidance is grounded in reality and evolving with new innovations (see Box 10).

Like DPI, investing in soft infrastructure is typically a shared effort between the private sector, the public sector, and donors.

Strengthen Critical Guardrails

Innovation promises to narrow existing financial inclusion gaps and improve consumer outcomes, but it can also introduce new vulnerabilities and amplify existing risks—from data misuse to fraud, consumer harm, lost confidence, cyber threats, operational disruptions, and systemic risk. If left unaddressed, these risks can deepen exclusion, erode trust, and even undermine financial stability, jeopardizing progress on financial inclusion itself.

For FSAs, strengthening guardrails around innovations and technology is therefore vital. The objectives of these guardrails are to establish (or update) clear expectations for market participants, prevent market distortions, monitor and mitigate material risks, clarify accountability, and coordinate with other competent authorities domestically and across borders.

To safeguard individuals, the vital guardrails are data protection frameworks, consumer protection frameworks, and digital financial literacy initiatives. These can help build trust, reduce vulnerability, and encourage individuals to participate safely and confidently in the financial ecosystem. At the system-level, the vital guardrails are risk-based supervision, proportionate prudential standards, and competition. These guardrails allow authorities to oversee evolving technologies and business models while balancing innovation, competition, and financial stability objectives.

Data Protection

The intensive use of personal data, alongside the increased sophistication enabled by new technologies, including the expansion of data-sharing frameworks, has heightened the risk of data breaches, data misuse, and data misappropriation. Therefore, in the case of data-sharing frameworks, FSAs can strengthen data protection and data privacy by setting and enforcing clear expectations for data security, purpose limitation, explicit consent, data portability, and accountability.

Additional clarity is needed when balancing privacy rights, such as data minimization, purpose limitation, and storage limitation, with data collection requirements (KYC/CDD).¹³ FSAs should coordinate closely with the data protection authority that oversees the broader privacy regime. As data flows more freely across sectors, regulatory clarity on data protection responsibilities is critical to prevent gaps in oversight. Working with telecom authorities is vital as stricter data protection rules may limit financial institutions' ability to leverage alternative datasets generated by telecom networks. In addition, strong data protection regimes should establish ethical data frameworks to prevent the use of information sources that are positively correlated with protected personal traits (e.g., zip codes can be used as a proxy for race, employment history gaps due to child and family care can proxy for gender) and perpetuate unfair biases, particularly against marginalized groups.

Consumer Protection

Digitalization has transformed access and usage of financial services, but it has also blurred accountability, especially in ecosystems involving third-party providers and automated decision-making from AI agents. Risks go beyond data misuse: they include fraud and scams, predatory practices, opaque pricing, and unclear liability across multi-providers and automated ecosystems. These issues can quickly erode consumers' trust and deter usage. Indeed, fraud¹⁴ is one of the fastest-growing risks for users of digital financial services (Duflos 2025), with nearly 1 in 5 adults who have a phone worldwide experiencing scams (Klapper et al. 2025). Additionally, another concern is that new players, technology, and partnerships are rapidly expanding digital access to credit that may exploit behavioral biases and lead to over-indebtedness, which in turn can deteriorate financial health (Izaguirre et al. 2025) (see Box 2).

Therefore, financial consumer protection authorities¹⁵ must deepen their understanding of customers' realities and the evolving threats that they face; invest in internal capabilities to address rapidly-changing risks; and collaborate with other actors in the ecosystem, including data protection authorities, to prevent fraud and scams (Chang et al. 2026).

As financial value chains become more modular, with different providers controlling interfaces, data storage, and balance-sheet activities, consumers should not bear the cost of system complexity. Financial consumer protection authorities, along with FSAs, can reduce harm by clarifying liability, setting enforceable conduct standards, and requiring effective recourse mechanisms. Digital and financial literacy play complementary roles but cannot replace consumer protection.

This is why protecting consumers requires an ecosystem approach in which a wide range of stakeholders coordinate action, including public authorities that lead data protection, competition, and telecom regulation, FSPs, consumer representatives, and market facilitators. Protecting consumers should encourage collaboration and secure a shared commitment to actively identify, prevent, and mitigate consumer risks and (re)build consumer trust through customer-centricity approaches and building the financial and digital capabilities of FSAs, consumers, and other stakeholders across the ecosystem (Duflos et al. 2024). For example, FSAs can strengthen their capabilities by incorporating market monitoring tools (e.g., consumer surveys, mystery shopping, social media monitoring, analysis of complaints) into their supervisory work (Izaguirre et al. 2022).

Additionally, FSAs can benefit from strategically adopting AI-powered Suptech to strengthen their regulatory and supervisory capabilities, reducing duplicative steps in regulatory functions and streamlining compliance. Furthermore, the use of Suptech can improve oversight, surveillance, and analytical capabilities to support forward-looking, judgement-based supervision and regulation through real-time indicators, data quality validation, and automated processes (Dias and Izaguirre forthcoming).

Digital and Financial Literacy

Technology-enabled inclusion is meaningful only if financial consumers can engage with financial services safely and confidently. Consumers should be equipped to understand product characteristics, associated risks (e.g., fraud and scams), alternative offers, and their rights and responsibilities. Evidence suggests that while classroom interventions can effectively improve financial knowledge, standalone training rarely translates into sustained behavioral change. Therefore, it must be complemented by interventions at "teachable moments" that reach customers at points in their lives when they make important financial decisions or when they use a financial product. Further, interventions should use tailored content and delivery channels for specific segments, including underserved groups, low-literacy groups, and first-time digital users (Gradstein et al. 2021).

Effective design and implementation of financial education and literacy interventions should be informed by country context and rigorous monitoring and evaluation to identify what has worked and what has not (see Box 3). This means prioritizing demand-side diagnostics and collaborating closely with providers and other stakeholders to meaningfully integrate just-in-time guidance, clear disclosures, and behavioral insights (e.g., evidence-based nudges such as savings prompts, smart message framing, and reminders). Further, investment in foundational infrastructure can enable interventions to reach low-literacy segments in a genuinely accessible and cost-effective way through solutions such as text messages and voice response systems in local languages.

Importantly, financial education and digital literacy interventions are most effective when paired with robust consumer and data protection safeguards, such as effective redress, informed consent, and active fraud and scam prevention. To achieve this aim, FSAs should coordinate across public and private stakeholders to continuously adapt interventions as products, risks, and technology evolve.

Risk-Based Supervision (RBS)¹⁶

RBS replaces checkbox compliance with oversight that focuses on core policy objectives, like stability and integrity, and responds to potential risks, based on how significant and severe they are likely to be. For financial inclusion, RBS operates through two interconnected channels.

First, from a system-wide perspective, RBS allows supervisory authorities to allocate oversight resources proportionately across institutions, activities, and business models, reducing unnecessary compliance burdens that may affect smaller providers and other non-banking financial institutions (NBFIs) serving underserved segments. Additionally, RBS is increasingly important in highly interconnected financial systems, where risks emerge not only at the institution-level but also across networks that span financial institutions, payment providers, cloud service providers, and third-party data intermediaries.

These interdependencies are particularly relevant in data-sharing frameworks, where operational, cyber, conduct, and concentration risks may propagate across sectors and regulatory perimeters. FSAs should therefore complement institution-based oversight with ecosystem-oriented approaches, supported by stronger coordination among financial supervisors, data protection authorities, competition agencies, and consumer protection bodies.

Second, from the consumers' perspective, risk-based approaches can support more proportionate customer due diligence and AML/CFT frameworks, helping reduce excessive de-risking practices¹⁷ that might unintentionally exclude low-income individuals, migrants, small businesses, or other vulnerable groups from access to formal financial services. Yet many LMICs still underuse RBS due to limited data, institutional capacity constraints, insufficient technology capabilities, and concerns that simplified customer due diligence may negatively affect FATF mutual evaluations outcomes or increase grey listing risks.

Early supervisory alignment can help ensure that innovation expands inclusion and interoperability without introducing new forms of exclusion, concentration, or systemic vulnerability. Experiences from jurisdictions such as Brazil, the United Kingdom, Australia, and the Republic of Korea demonstrate the growing importance of multi-agency coordination in supervising data-sharing frameworks and aligning authorities' responses across mandates (CGAP et al. 2024a; Dias et al. 2026; Financial Conduct Authority 2026).

Prudential Standards

Roadmaps for inclusive financial ecosystems can be strengthened by recognizing the central role of sound prudential standards. FSAs should treat prudential standards as a critical guardrail for inclusive financial ecosystems while also advancing broader development objectives. As digital financial services expand rapidly, prudential standards should be at the center of efforts to preserve the continuity, reliability, inclusiveness, and resilience of core financial services.

To achieve this, FSAs should embed proportionality principles so that prudential standards reflect the scale, complexity, and systemic relevance of technology-enabled financial services. While FSAs should not reinvent the wheel, the current era of technological change raises fundamental questions about whether existing prudential requirements adequately address the inherent risks posed by frontier technologies and business models.

Currently, there are at least five key prudential issues to consider at the intersection of innovation, inclusion, and stability:

1. Fragmented rules for cloud providers¹⁸ require greater coordination among FSAs, as overly restrictive rules on cloud use and data localization can drive up costs and unintentionally favor incumbents, whereas permissive standards can be a source of systemic risk;
2. Varying levels of capital and liquidity requirements for fintech firms and NBFIs across jurisdictions require efforts to reduce market fragmentation and strike an appropriate balance between encouraging robust risk management practices and fostering market entry, competition, and innovation;
3. Fragmented rules on digital money and assets require greater regulatory coordination, as they could amplify macro-financial stability risks and exclusion;
4. Unclear or inadequate rules regarding an e-money firm's failure require clarification and strengthening, otherwise they could undermine trust and progress made on inclusion;¹⁹ and finally;
5. Cybersecurity standards and current encryption systems require reassessment in the face of rapidly evolving, sophisticated threats and increased computing capacity.

While FSAs don't need to create new prudential standards, by addressing these emerging issues, they can reap the benefits of new technologies and assets, ensuring that the accelerated pace of technological change strengthens, rather than undermines, the long-term resilience of financial ecosystems, which is the foundation of trust and inclusion.

Competition Law

Competition law differs from competition policy. The former prevents dominant firms from hindering others' entry or growth in the market, thus acting as a guardrail, while the latter seeks to boost competition as a market enabling innovation (World Bank 2023). This is why competition law operates as a guardrail and is typically enforced by general competition authorities across all sectors, while sectoral regulators lead on industry-level competition policies. As such, elements related to competition law's role as a guardrail are discussed here, while Policy Priority 1 (below) explores competition policy further.

Rethinking competition law, particularly antitrust rules, is crucial in increasingly data-driven, digital markets. This becomes even more important in the context of Big Tech. Unlike traditional financial institutions, or standalone fintech firms, Big Techs often enter financial markets with a pre-existing competitive advantage derived from a dominant position in digital commerce, social media, telecommunications, or digital platforms. For example, it is harder to identify consumer harm or collusive practices and market power of Big Techs where digital platforms provide their services nominally for "free". Market power is even more difficult to assess when data, products, and financial services are embedded on the same platform, control structures are dispersed, and typical thresholds for mergers and acquisitions under antitrust regimes are not met (Nyman and Barajas Aparicio 2021).

The challenges posed by increased digitalization and Big Techs for competition law are not trivial, and there is little to no evidence on the efficacy of the remedies adopted in developed jurisdictions (e.g., thresholds based on transaction values rather than assets or revenues) (Nyman and Barajas Aparicio 2021). For public authorities, going beyond prices to measure consumer welfare in contexts where services are virtually "free" but the hidden price is data, highlights the role of intersecting competition law, consumer protection, and data protection. Furthermore, competition authorities face the challenge of measuring welfare through the lens of increased consumer choice and utility. This highlights the importance for competition authorities to coordinate with FSAs, telecommunications regulators, and data protection agencies, where Big Tech ecosystems can span multiple sectors and regulatory perimeters simultaneously. In this context, FSAs can guide competition policy to encourage market entry, reduce implementation costs, and promote a level playing field (see Policy Priority 1). 

Advance Transformative Policy Priorities

Embracing technology and innovation is core to creating inclusive financial systems. An FSA's task is not to slow innovation but to shape it by providing a strong foundation on which innovation can thrive. As most FSAs are contending with finite resources, rapid technological change, and competing goals, they need to prioritize action in the areas with the greatest potential to produce transformative outcomes, as not all reforms will have the same impact on financial inclusion.

To assist FSAs in this task, this roadmap highlights six transformative policy priorities at the intersection of innovation, data, and finance. They are grouped into three interrelated areas and their selection is highly intentional: three of the policy priorities reshape market structure, two govern emerging technologies, and one modernizes institutions.

Reshape Market Structure

This domain focuses on enabling diverse, contestable financial ecosystems and leveraging foundational investments in infrastructure. This section presents three policy priorities to promote open, inclusive, and interoperable market structures by reducing barriers to entry, expanding consumer choice, improving interoperability, and increasing the utility of financial services.

Policy Priority 1: Leveling the Playing Field and Encouraging Diverse Players in the Market

FSAs have the power to shape who can enter, participate, and scale in a market. Actively encouraging a more diverse ecosystem of banks, NBFIs, and innovators is critical for expanding consumers' choices, lowering costs, and extending services to underserved segments. In addition, challengers—including NBFIs, startups, fintechs, and niche financial service providers—are often better positioned to reach underserved segments by leveraging structural, technological, and data-driven innovations that incumbent banks cannot easily replicate due to the higher costs associated with underserved populations. It is therefore essential for FSAs to ensure a level playing field (see Box 4).

There is a range of existing regulatory levers that FSAs can use to level the playing field and reduce barriers to entry for new players. For example, they can implement proportional licensing requirements, impose interoperability requirements especially for payment systems, and establish data-sharing frameworks that enable more diverse and inclusive financial ecosystems (Kumaraswamy and Kremnitzer 2025). In particular, calibrating entry requirements to be proportional to the institution's size, risk profile, and capacity prevents smaller institutions from being crowded out. Proportionality can enable responsible innovation by new entrants while maintaining stability and consumer protection.

This decision is not trivial. For FSAs, leveling the playing field to welcome new participants requires proportionate rules that reflect the increasingly modular nature of financial services, including the growing role of new technology players that use digital distribution channels, data-driven innovation, and modern user interfaces to reach and benefit a wider range of consumers (Zetterli 2019; Zetterli 2021; Zhang 2025). However, in parallel to promoting innovation, FSAs may also need to update their prudential requirements to mitigate increased systemic risks, or potential contagion from increased interconnectedness.

Policy Priority 2: Making Payment Systems Fit for Purpose—Instant, Interoperable, and Inclusive

Once the foundational elements of Digital Public Infrastructure—including fast payment systems (FPS)—are in place, FSAs have a valuable opportunity to leverage these systems to expand financial inclusion.

Around the world, FPS have been launched in an effort to achieve diverse policy objectives, including enhancing financial inclusion, fostering competition among payment service providers, driving digitalization, reducing cash use, and enabling innovation (World Bank n.d.-a). Among these many objectives, their role in driving greater financial inclusion can be incredibly powerful, especially because they can increase access to digital payment services for low-income populations and provide an on-ramp for them to access other financial services.

To positively impact financial inclusion, fast payment systems should include five core features:

1. They must provide instant, real-time settlement to ensure that the payee can use the funds immediately. This is critical for low-income populations with limited cash balances.
2. They must enable interoperability, so that NBFIs, including fintechs, who are often better placed to serve low-income and informal customers, can participate on equal terms with other traditional financial institutions. As part of their interoperability, the payment systems should enable third-party payment initiation, which allows NBFIs to offer seamless customer experiences without relying on banks for execution.
3. To be successful and inclusive, the design of fast payment systems must support a wide range of different use cases valuable to end users, allowing them to pay and be paid instantly, in all contexts (e.g., between people (P2P), people and merchants/businesses (P2M, P2B, and B2P), people and governments (G2P, P2G), and cash-in-cash out (CICO)) (see Box 5). In this regard, account-to-account payment models—including quick-response QR-based transfers—can reduce reliance on card networks and lower costs for merchants and consumers.
4. Careful decisions also need to be made around pricing. These decisions sit at the intersection of public policy, long term commercial sustainability, and incentives for innovation, and have significant consequences. While excessive charges at the network or API level risk entrenching incumbents, pricing models that are unsustainably low may weaken incentives for investment and innovation over time. Authorities should therefore adopt pricing frameworks that preserve affordability, universal access, and incentives for adoption, particularly for low-value and P2P transactions, while ensuring transparent, proportionate, and competitively neutral cost-recovery mechanisms that protect the long-term sustainability and inclusiveness of fast payments ecosystems. This can be done by ensuring that P2P transactions are free of charge while encouraging MSMEs to participate in the digital economy and limiting regulatory arbitrage between P2P and P2M/B (see Box 6).²⁰
5. The scheme should ensure that users can conduct their transactions safely by providing clear rules to prevent, detect, and manage fraud, as well as specific procedures for redress.

Further guidance and toolkits for FSAs looking to adopt a fit-for-purpose FPS are available from the World Bank Project FASTT (World Bank n.d.-a) and The Level One Project (Gates Foundation n.d.).

Policy Priority 3: Broadening the Scope of Open Finance Frameworks to Encompass Open Data

As with fast payment systems, once investments have been made in foundational Digital Public Infrastructure—including data-sharing frameworks as one of its three critical layers—there is an opportunity to further develop these frameworks along a spectrum from open banking to open finance and ultimately to open data systems.²¹ Through these data-sharing frameworks, FSAs can change the trajectory of inclusion, competition, and innovation (Fernandez Vidal and Sirtaine 2024; CGAP et al. 2024a). By allowing financial service providers to access transaction histories, payment flows, account balances, and other customer-authorized data, these frameworks enable providers to better tailor products to customers' cash flows, improve credit worthiness assessments, reduce onboarding and credit application costs, and expand the utility of financial services.

Available evidence for early open banking and open finance initiatives in Brazil and India have demonstrated practical benefits ranging from reduced credit application costs and improved loan approval rates for consumers (Fernandez Vidal and Sirtaine 2024) to new forms of acceptable collateral, including receivables or inventory for small firms (Yu 2024; Xiong 2024; Eroglu et al. 2026). Importantly, open finance itself already broadens the scope of usable information beyond traditional credit bureau data and static financial records, to include transactional data. This can be particularly transformative for consumer segments that are often invisible to traditional credit assessment frameworks.

As noted in the section on DPI, open banking and open finance initiatives now operate in more than 60 countries (CCAF n.d.) (see Box 7). However, buoyed by the early experiences of open finance, some countries are now exploring whether data-sharing frameworks can be expanded to include more diverse and richer datasets. This could involve enabling permissioned access not only to financial data, but also to selected datasets from sectors such as telecommunications, utilities, commerce, health, tax records, land registries, and beyond. Broadening the pool of accessible datasets may further improve financial service providers' ability to assess risks, tailor products, and even serve low-income or informally employed populations whose economic activity is rarely fully reflected in financial transaction records alone (Fernandez Vidal and Sirtaine 2024; CGAP et al. 2024a). Evidence suggests that some forms of alternative data can complement or even match the predictive power of historical data from credit records (Björkegren and Grissen 2020).

Expanding the scope of data-sharing schemes beyond open finance and towards open data goes beyond the remit of FSAs alone. However, they can play a catalytic role by identifying which datasets have the greatest potential for improving financial inclusion while setting the right foundations for interoperable, secure, and trusted open finance frameworks (FCA 2026). This is not just a case of applying the design features from open finance to open data; expanding the sectoral scope introduces significant institutional and governance complexity that must be considered. Different sectors are governed by specialized data protection regimes, and operate under separate licensing frameworks and supervisory authorities, creating significant interoperability and accountability challenges.

Careful sequencing and cross-sectoral coordination are therefore critical. Certain datasets are also highly sensitive, commercially strategic, or subject to stricter legal protections. Telecommunications data, for example, may reveal location patterns and behavioral information that raise significant privacy concerns.

International experience suggests that gradual and coordinated expansion can help create inclusive digital data economies over time. Australia's Consumer Data Right illustrates how phased implementation can support expansion from finance into the energy sector while maintaining clear consumer protection safeguards (Australian Government n.d.). Similarly, Korea's MyData Initiative demonstrates how financial authorities can catalyze broader data portability while progressively coordinating across sectors and regulators (Personal Information Protection Commission 2025) (see Box 8).

As the pool of usable data expands, FSAs may also need to consider potential prudential implications. Although the existing Basel III framework is formally data-agnostic,²² integrating alternative data into underwriting and risk assessment models raises supervisory challenges, particularly regarding data reliability, interpretability, and auditability. FSAs should therefore encourage the use of alternative data sources with clear supervisory guidance, controlled testing environments, and peer-learning mechanisms to ensure that alternative data strengthens FSP's risk management assessment without weakening prudential safeguards or obscuring underlying credit risk.

Ultimately, expanding from open finance toward broader open data ecosystems is not a one-time reform but an ongoing process requiring continuous institutional coordination, governance adaptation, and trust-building. FSAs can play a critical leadership role in promoting interoperability, trusted governance frameworks, and responsible data use frameworks that support innovation and inclusion while preserving privacy, consumer trust, and financial stability.

Govern New Technologies

This domain focuses on establishing governance frameworks for two of the most disruptive technologies, which have the greatest potential to deliver near-term transformative outcomes: artificial intelligence and tokenization. Over time, other technologies such as quantum computing may also need to be added. FSAs have an important role to play in creating environments where individuals and businesses reap the benefits of such new technologies for financial inclusion, whilst at the same time ensuring that they are adopted in a way that mitigates risks for financial systems and preserves stability and consumer protection (Bank of England 2025; Graf et al. 2026).

Policy Priority 4: Establishing a Policy Approach for Inclusive AI

AI offers innovative capabilities in data analysis, predictive modelling, and tailored insights. It is being used across the financial sector for customer onboarding, credit scoring, insurance underwriting, claim processing, chat bots, robo-advice, trading, risk management, fraud detection, cybersecurity, and AML/CFT compliance. For financial inclusion, AI promises to address both demand- and supply-side barriers.

On the supply-side, AI can significantly reduce the operational costs and information asymmetries associated with serving underserved segments. Promising solutions leverage traditional AI (Machine Learning) to assess alternative data and better understand financial behavior and risk profiles of customers with irregular income patterns or cash flows. In addition, AI-powered facial recognition and document scanning can accelerate Know Your Customer (KYC) compliance and reduce the logistical costs of onboarding customers in remote areas.

On the demand side, AI has the potential to address low financial literacy, lack of trust in financial services, and language barriers. Generative and agentic AI may help bridge critical gaps by overcoming local dialect differences or enabling individuals with limited literacy to understand complex financial concepts. While still developing, agentic AI promises to help consumers manage everyday finances, track expenses, optimize bill payments, compare financial products, and make more informed financial decisions based on their cash flow needs (Aldasoro et al. 2024; VISA 2025; Davidovic and Tourpe 2026).

While the possibilities are exciting, AI itself will not foster financial inclusion. Making AI inclusive requires decisive policy action. FSAs should recognize that exclusion is rooted in weak, fragmented, unrepresentative, and biased data systems rather than in a lack of suitable algorithms alone. AI also poses a risk: When data systems systematically underrepresent women, rural populations, informal workers, MSMEs, or low-income customers, AI models may replicate or amplify existing exclusion patterns. Investments in foundational infrastructure are therefore needed to improve the availability, quality, interoperability, portability, and representativeness of data (Salman et al. forthcoming).

FSAs can encourage the responsible use of richer datasets while requiring financial institutions to regularly test AI systems for discriminatory outcomes and unintended exclusion. Controlled experimentation environments, such as regulatory sandboxes, and supervisory dialogue can further help authorities and industry participants understand how AI models affect different customer segments and whether existing governance frameworks remain fit for purpose (Graf et al. 2026; Salman et al. forthcoming).

Furthermore, the growing autonomy of agentic systems blurs the lines of accountability and liability. Agents can hallucinate, misdirect consumers' funds, provide harmful advice, automate discrimination at scale, or create opaque denial loops that lock vulnerable communities out of "human-in-loop" dispute resolution processes (Aldasoro et al. 2024; Visa 2025; Davidovic and Tourpe 2026). The immediate priority for FSAs is therefore to establish clear rules governing AI-enabled advice and decision-making, while ensuring enforceable requirements on customer consent, accountability, transparency, and data protection are in place. Doing so would support the ethical deployment of AI, maintain consumer trust, and safeguard privacy (Graf et al. 2026; Salman et al. forthcoming).

While many AI-related risks can be addressed within existing regulatory frameworks, FSAs should urgently assess whether certain areas require further clarification. Seeking feedback from market participants can be particularly valuable for this. Authorities in Japan, New Zealand, Sweden, the United Kingdom, and the US have already collected input highlighting the need for clearer guidance on issues such as discrimination in automated decision-making, the role of human oversight, explainability of AI-driven outcomes, and model risk (Quevedo-Vega et al. 2025a).

Policy Priority 5: Establishing a Regulatory Framework for the Responsible Use of Tokenization of Money and Assets

Tokenization of money and assets can deepen existing financial markets, unlock new ones, and change how assets, capital, and balance sheets can be mobilized within the financial system to make transactions faster, cheaper, and more efficient (Bank of England 2025). From a financial inclusion perspective, tokenization has the potential to expand access to payments, savings, credit, and investment opportunities for underserved individuals and businesses. However, it is not a magic solution that will address the root causes of exclusion and, if left unguided, it could even introduce vulnerabilities to the financial system.

In terms of its promise, the tokenization of money, primarily through stablecoins,²³ may help address longstanding frictions in cross-border payments and remittances by enabling near-instant and lower-cost transfers compared to traditional correspondent banking. This could particularly benefit low-income households in LMICs that rely heavily on remittance inflows and continue to face high transaction fees. Reduced costs for cross-border transactions may also support MSMEs engaged in international trade by reducing settlement costs and delays.

Stablecoins have also emerged as an alternative source for storing value in countries facing high inflation or currency volatility. In such environments, households and small businesses increasingly use dollar-denominated stablecoins to preserve purchasing power and protect savings from rapid depreciation. Since early 2022, adoption of stablecoins in some LMICs has accelerated in response to macroeconomic instability, de-risking of correspondent banking relationships, and restrictions on access to foreign currency (Aldasoro at al. 2026).

The tokenization of assets²⁴ may also support financial inclusion by expanding the range of assets that can be used as collateral and by improving access to finance for underserved firms. For example, tokenization can enable individuals and MSMEs to digitally represent and fractionalize real-world assets, such as receivables, agricultural output, equipment, or livestock, into blockchain-based tokens, potentially making these assets easier to value, transfer, pledge, and monitor.²⁵ This approach can also increase transparency, reduce information asymmetries, and support innovative lending models.

For example, tokenized receivables or warehouse receipts could help small firms and agricultural producers access credit from financial institutions that would otherwise face high verification and monitoring costs. This can be used to boost agricultural value chains by enabling alternative forms of "assets"—such as tokenized warehouse receipts, crop receivables, or supply-chain claims—to become collateral. Separately, lenders could tokenize their MSME loan portfolio to securitize and distribute their exposures and diversify their funding sources and, ultimately, enhance the availability of financing for MSMEs.

Additionally, the use of tokenized digital identities and blockchain technology for verified credentials can improve security, portability, interoperability, and user control by enabling selective sharing and verification of identity credentials without exposing personal data. By substituting a sensitive identifier with a token, authorities can also ensure selective data disclosure while reusing identity attributes, thereby reducing fraud and costs of AML/CFT compliance (World Bank 2019; World Bank n.d.-b).

Further to these more advanced applications of tokenization to improve financial inclusion, there are other potential use cases that currently remain more experimental. Examples include:

• Domestic payment transfers programmed with embedded smart contracts that ensure funds reach intended beneficiaries for their designated purposes.
• Tokenized parametric insurance using real-world data to trigger automatic payouts when predefined conditions are met (e.g., rainfall falls below a threshold indicating drought), which could potentially reduce claims processing times and administrative costs for smallholder farmers.
• Tokenized carbon credits for sustainable agricultural practices that smallholder farmers could leverage to generate additional income.
• The tokenization of real estate to improve affordability and encourage asset diversification for households in contexts where formal property markets remain underdeveloped.

For both tokenized money and assets, the nascent nature of this innovation means that these benefits cannot yet be reliably quantified. While there are select use cases that illustrate potential benefits, the real value of others is still to be determined. Further pilots are needed to build a better evidence base to quantify the benefits for financial inclusion and identify potential risks that need to be addressed (see Box 9 for examples of pilot uses of tokenization for financial inclusion). However, because the technology could develop quickly and adoption could be exponential, FSAs will need to be prepared to address regulatory gaps.

As such, FSAs should proceed with caution as tokenization also introduces important macro-financial, prudential, operational, integrity, and consumer protection risks. In the case of stablecoins, key risks include: (i) currency substitution and digital dollarization, particularly in countries with weak macroeconomic fundamentals or volatile currencies (Adrian et al. 2025, Alkhair et al. 2026, Lee and Tou 2026); (ii) increased capital flow volatility and reduced effectiveness of monetary policy transmission; (iii) liquidity and redemption risks if reserve assets are insufficient, illiquid, or poorly managed; (iv) operational and cyber risks arising from dependencies on third parties providing key infrastructure; (v) unclear redemption rights, misleading marketing, fraud, and lack of deposit insurance; and (vi) financial integrity risks.

Similarly, asset tokenization raises legal and prudential uncertainties regarding ownership rights, insolvency treatment, collateral enforceability, custody arrangements, valuation methodologies, and interoperability with legacy financial infrastructure. The current limited legal certainty regarding tokenized claims may also discourage adoption and impede the development of secondary markets and market-making activity.

The opportunities and risks associated with tokenization for financial inclusion underscore the need for clear, proportionate, and coordinated regulatory approaches that enable innovations in the tokenization of money and assets, while preserving financial integrity, consumer trust, and financial stability. International standard setting bodies (SSBs) are increasingly providing high-level guidance on stablecoins and tokenized finance (FATF 2021; CPMI and IOSCO 2022; FSB 2023).

At the national level, FSAs should seek to reduce regulatory fragmentation and establish clear legal and prudential frameworks for tokenized money and assets. Initial steps should include clarifying their regulatory classification and determining when existing frameworks for e-money, payments, securities, or collective investment schemes apply to ensure that similar activities and risks receive consistent regulatory treatment. Key safeguards that FSAs may need to establish for tokenized money and assets include:²⁶

1. Entry requirements and prudential standards to safeguard stability and integrity. These include licensing requirements, fit-and-proper rules, capital²⁷ and liquidity buffers, high-quality liquidity backing, currency matching, fund segregation, custody arrangements, insolvency procedures, incident reporting, regular reporting and audit expectations, and AML/CFT compliance.
2. Interoperability and reliable on/off-ramp mechanisms with payment and banking systems to ensure that tokenized money can support recurring transactions.²⁸
3. Clear point-of-sale disclosures on redemption rights, applicable fees, nature (e.g., not mis-selling as deposits), and the absence of deposit insurance or similar government-backed guarantee, where applicable, to protect consumers.
4. Legal certainty on ownership rights, settlement finality,²⁹ treatment of tokenized collateral, collateral valuation, and resolution mechanisms. The latter requires strengthening home-host supervisory cooperation arrangements.
5. Controlled experimentation leveraging regulatory sandboxes, pilot programs, and phased implementation to better understand operational, prudential, and consumer risks of tokenized assets before large scale adoption.

A fully liquid, institutionalized, and interoperable market for tokenized money and assets will not happen overnight. FSAs therefore have an important role to play in providing legal certainty, supporting interoperability, clarifying prudential treatment, and ensuring that tokenization evolves in a way that supports inclusion and innovation without undermining trust or financial stability.

Modernize Financial Sector Authorities

Policy Priority 6: Building Adaptive and Innovation-ready Ecosystems

Lastly, FSAs should establish robust innovation frameworks that go beyond isolated regulatory decisions and instead embed innovation into their core culture, governance structures, and supervisory strategy. CGAP's research emphasizes that successful innovation ecosystems are not driven solely by regulatory sandboxes or innovation hubs, but by a broader institutional approach by FSAs that combines a clear strategic vision, a clear tone in favor of innovation from senior leadership, an innovation-oriented organizational culture, industry engagement, and an adaptive supervisory capacity (Jeník et al. 2025).

At the same time, as this paper suggests, FSAs should ensure that innovation frameworks contribute directly to financial inclusion and positive development outcomes, while protecting ecosystem resilience—rather than promoting innovation in isolation. Doing so requires FSAs to systematically follow and decipher market developments through active market monitoring and ongoing dialogue with market players. It also requires them to establish methodologies, accountability, and processes to systematically assess how innovations are likely to affect underserved populations and market competition, while also leveraging supervisory technology (Suptech), data analytics, and ecosystem monitoring tools to identify emerging risks (Dias and Izaguirre forthcoming).

Building an innovation-ready institution also requires FSAs to strengthen their internal learning mechanisms and to build a workforce with up-to-date skills, aligned with the latest technological developments. To do so, cross-agency knowledge sharing, secondments, and peer knowledge exchange across jurisdictions might be useful. Experiences documented by Jeník et al. (2025) in countries such as Brazil, Ghana, and Singapore highlight how leadership commitment, innovation culture, institutional adaptability, and even strategic investments in soft infrastructure can help regulators proactively shape inclusive financial ecosystems rather than merely reacting to technological change (see Box 10).

Ultimately, to be effective, FSAs should adopt a holistic, ecosystem-based approach that balances innovation, competition, consumer protection, and stability objectives in rapidly evolving digital markets.

Conclusion

Rapid innovation and technology development are already reshaping financial systems. What remains uncertain is whether they will advance financial inclusion and financial health, ultimately supporting inclusive economic growth and shared prosperity, or whether they will instead entrench new forms of exclusion and risk that may be difficult to reverse in the future. This will not be determined by innovation and technology alone, but by the strategic policy actions that FSAs take today.

The roadmap presented in this paper is clear: FSAs do not need new mandates to act and do not need to reinvent the wheel. Rather, they need well-defined, intentional policy priorities anchored in a customer-centric, responsible, outcome-driven approach and the willingness to build strategic technology fluency now. The journey ahead is also clear: define guiding principles that inform policy choices, invest in foundational infrastructure, enforce robust guardrails, and advance the six transformative policy priorities identified in this paper. By doing so, FSAs can steer technology to deliver better outcomes for individuals and businesses, while safeguarding trust and financial stability.

For many FSAs, limited resources are a real constraint. Yet the actions in this roadmap do not all need to be done at once. The most important step is to get started rather than waiting for the 'perfect' moment: emerging technologies and the disruption they bring to financial ecosystems will not wait. The sooner FSAs embark on this journey, the greater their ability to shape how innovation and disruptive technology transform their financial systems.

FSAs are central to this effort, but they cannot do it alone. Achieving the aims of this roadmap will require a whole-of-ecosystem response, and collaboration between public and private-sector actors to ensure that FSAs are well-positioned to operationalize this action plan. Nor can FSAs afford to take a "wait-and-see" approach to this current wave of innovation and technological change. Instead, they must adopt proactive, outcome-oriented stewardship by implementing intentional policies that harness the transformative potential of new technologies for financial inclusion, while addressing emerging risks and the market failures they may exacerbate.

With the right leadership from FSAs, the private sector—including banks and NBFIs—may increasingly view financial inclusion as an opportunity to expand their client base and leverage new data and technologies to develop products that better cater to underserved populations. International organizations, the donor community, and standard-setting bodies also have a central role to play in supporting country-level action with the knowledge, evidence, and resources needed to deliver such reform.

Policy rarely moves as fast as technology advances—and the gap between the two is rapidly widening. But the pace of change is an argument for urgency, not inaction. Authorities who follow this roadmap and define guiding principles that inform policy choices, invest in foundational infrastructure, strengthen guardrails, and intentionally focus on transformative policy priorities will be best positioned to harness the extraordinary potential of this new wave of disruptive technological change to build safe, inclusive financial ecosystems.

The future of inclusive finance will be shaped not by technology and innovation alone, but by the choices that leaders make today. This includes the actions of policymakers who proactively harness innovation to advance financial inclusion as a stepping stone for achieving broader development outcomes, by FSAs who prioritize technology fluency over mere awareness, and by ecosystems that recognize that the success of inclusive financial systems is measured not only by access, but by the value it brings to everyone.

The path forward is clear. The time to act is now.