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a2a interoperaBility makinG moBile money scHemes interoperate
ASSESSmENT cRiTERiA KEy quESTioNS To bE coNSidEREd foR EvERy cRiTERiA,
foR EAcH implEmENTATioN opTioN EvAluATEd
A. RiSK impAcT • are risks known and understood for both inter-scheme a2a and scheme to
bank a2a transaction clearing and settlement?
a key consideration for all new payment systems is whether the introduction
of the service brings new systemic and fraud risk. this element in the • are new settlement rules required?
assessment is used to assess the impact of an implementation option in terms • are real-time settlements available? if not, what is the settlement cycle?
of the new risks introduced through a2a interoperability.
• Do settlements rely on third parties? is their risk known?
• Does the central bank have visibility of inter-scheme and scheme-bank
settlement?
• are significant new controls and reporting required?
b. implEmENTATioN complExiTy • are common interface standards (e.g. apis) required to be defined for inter-
scheme or scheme-bank interfaces?
the cost of implementing a2a interoperability can be a significant barrier
to its deployment in a market. it is generally impractical to calculate exact • is there a suitable existing payment system (e.g. acHs & rtGs) that can be
implementation costs in the initial stages, and so at the screening stage for used to provide a2a connectivity?
the options a relative assessment of the complexity of implementing a2a • Does the existing processor operate in real-time for transaction
interoperability is an appropriate proxy for cost – allowing a direct comparison authorisation and real-time or periodic for settlement?
of a number of options. an assessment of the implement complexity of an
option will relate directly to its barriers to deployment in a market. • are changes required to the specifications and interfaces of an existing
payment system?
• can the existing payments systems process potentially very large
numbers of low value transactions without affecting its current processing
requirements?
• is there the potential to use an existing third party processor? Do they
provide open apis for integration?
c. TRANSAcTioN coST impAcT • are the additional transaction processing costs likely to be significant when
compared to existing mobile money transfer transaction costs? Will this
as well as implementation costs, another potential barrier to the make the a2a products uneconomic?
implementation of a2a interoperability using a specific option may be any
additional transaction processing costs that option requires. • are the additional processing costs under the control of a banking sector
party? are these processing costs subject to regulation?
• are the additional processing costs under the control of a commercial
third party?
• are future transaction processing costs for a2a interoperability quantifiable
or unknowable at this stage?
d. REGulAToRy ANd policy fRAmEWoRK • What are the objectives of the regulator for the development of the
ecosystem? is there specific regulation defining the requirements and
it is important to understand the requirements and constraints of any existing constraints of a2a interoperability between schemes? are these regulations
regulation for a2a interoperability between schemes. this knowledge should mature, specific and consistent?
highlight the potential barriers to entry there may be that are caused by
regulation in a specific market. equally, a lack of clarity as to the requirements • are mobile money schemes required to support other specific functionality
of the regulator may restrict the opportunity to provide a2a interoperability. (such as pos interoperability) that would necessitate working with a
therefore due diligence of the existing regulatory framework is necessary. this specific third party, therefore limiting choice of implementation option?
assessment element also allows consideration of the potential competition • Do regulations define the cost model for a2a interoperability? Will this
from other networks. model significantly affect the choice of implementation option?
• is the license given directly to the scheme operator (to the mno) for the
mobile money scheme? if not, a partner bank with a license has significant
input in the path going forward.
• in addition to regulation for mobile money payments, what other
regulations - such as consumer protection or anti-money laundering and
combating the Financing of terrorism (aml/cFt) - are likely to influence
the selection of a specific deployment option? are these regulations well-
established, clear and consistent across the related areas?
24
ASSESSmENT cRiTERiA KEy quESTioNS To bE coNSidEREd foR EvERy cRiTERiA,
foR EAcH implEmENTATioN opTioN EvAluATEd
A. RiSK impAcT • are risks known and understood for both inter-scheme a2a and scheme to
bank a2a transaction clearing and settlement?
a key consideration for all new payment systems is whether the introduction
of the service brings new systemic and fraud risk. this element in the • are new settlement rules required?
assessment is used to assess the impact of an implementation option in terms • are real-time settlements available? if not, what is the settlement cycle?
of the new risks introduced through a2a interoperability.
• Do settlements rely on third parties? is their risk known?
• Does the central bank have visibility of inter-scheme and scheme-bank
settlement?
• are significant new controls and reporting required?
b. implEmENTATioN complExiTy • are common interface standards (e.g. apis) required to be defined for inter-
scheme or scheme-bank interfaces?
the cost of implementing a2a interoperability can be a significant barrier
to its deployment in a market. it is generally impractical to calculate exact • is there a suitable existing payment system (e.g. acHs & rtGs) that can be
implementation costs in the initial stages, and so at the screening stage for used to provide a2a connectivity?
the options a relative assessment of the complexity of implementing a2a • Does the existing processor operate in real-time for transaction
interoperability is an appropriate proxy for cost – allowing a direct comparison authorisation and real-time or periodic for settlement?
of a number of options. an assessment of the implement complexity of an
option will relate directly to its barriers to deployment in a market. • are changes required to the specifications and interfaces of an existing
payment system?
• can the existing payments systems process potentially very large
numbers of low value transactions without affecting its current processing
requirements?
• is there the potential to use an existing third party processor? Do they
provide open apis for integration?
c. TRANSAcTioN coST impAcT • are the additional transaction processing costs likely to be significant when
compared to existing mobile money transfer transaction costs? Will this
as well as implementation costs, another potential barrier to the make the a2a products uneconomic?
implementation of a2a interoperability using a specific option may be any
additional transaction processing costs that option requires. • are the additional processing costs under the control of a banking sector
party? are these processing costs subject to regulation?
• are the additional processing costs under the control of a commercial
third party?
• are future transaction processing costs for a2a interoperability quantifiable
or unknowable at this stage?
d. REGulAToRy ANd policy fRAmEWoRK • What are the objectives of the regulator for the development of the
ecosystem? is there specific regulation defining the requirements and
it is important to understand the requirements and constraints of any existing constraints of a2a interoperability between schemes? are these regulations
regulation for a2a interoperability between schemes. this knowledge should mature, specific and consistent?
highlight the potential barriers to entry there may be that are caused by
regulation in a specific market. equally, a lack of clarity as to the requirements • are mobile money schemes required to support other specific functionality
of the regulator may restrict the opportunity to provide a2a interoperability. (such as pos interoperability) that would necessitate working with a
therefore due diligence of the existing regulatory framework is necessary. this specific third party, therefore limiting choice of implementation option?
assessment element also allows consideration of the potential competition • Do regulations define the cost model for a2a interoperability? Will this
from other networks. model significantly affect the choice of implementation option?
• is the license given directly to the scheme operator (to the mno) for the
mobile money scheme? if not, a partner bank with a license has significant
input in the path going forward.
• in addition to regulation for mobile money payments, what other
regulations - such as consumer protection or anti-money laundering and
combating the Financing of terrorism (aml/cFt) - are likely to influence
the selection of a specific deployment option? are these regulations well-
established, clear and consistent across the related areas?
24
