The United Nations Capital Develop Fund (UNCDF) is keen to provide comments on the draft report. UNCDF strategy has recently evolved from Inclusive digital finance to inclusive digital economies and the link between digital finance and digital economy is at the center of our work.  UNCDF comments are focused on the digital finance section of the document, taking into consideration the key role of digital finance in the development of digital economies in Africa.

• Regarding page 50 and the proposed actions around digital finance, UNCDF would welcome two recommendations to the DETF:
  • The development of national and regional forums to foster public and private dialogue around DF policy and regulation.  The continuous evolution and innovation in the sector require continuous dialogue between the government and the private sector to develop the right enabling environment for the private sector to develop the right services that will be used by the unbanked population. 
    Constructive stakeholder dialogue is enabled by regular engagement of public and private stakeholders to discuss specific market constraints and public policy objectives. This effort includes dialogue among regulators, to clarify jurisdictions, share data and rally behind a common economic vision. This activity is key to the acceleration of policy and regulatory change. It relies heavily on consulting with local stakeholders and clearly defining the market barriers that legal reforms can address. Engagement with the private sector is a central component of the UNCDF methodology, specifically seeking to identify issues that are common to a critical mass of private sector actors so that policy change can have the widest possible impact. Such engagement most often results in the presentation of various options available to policymakers and regulators, which ensures that governments can identify the choice that works best for their respective objectives.
  • The use of data for beter decision-making around policy and regulation. Data driven decision-making implies systematic collection and assessment of market data (both supply and demand) to inform regulation and guide policy priorities. In addition to the system itself, policymakers and regulators require clear measurement frameworks and the technical capacity to monitor data.
• An Open Digital finance ecosystem in Africa will be the main foundation of inclusive digital economies at national, regional and African levels.  In the digital era, the future of financial inclusion is all about innovation. Innovation to develop the tailored compelling value proposition for each individual. While access and outreach for financial services have been driven by traditional and less-traditional financial service providers (banks, microfinance, mobile network operators, etc.) usage will be driven by the most innovative players in the market. It can be traditional players (that achieve a digital transformation) or new players like fintech, agtech, edutech, platform, etc.. Innovation will also be about continuously leveraging data from each individual to always improve value proposition and to remain relevant on the market.  Furthermore, in the digital era, the future of financial inclusion is not only about developing the right payment, the right loan or insurance alone. It is about developing tailored services leveraging technology that offer compelling value propositions for youth, women, refugees, farmers and other. The financial services are part of these services and are perfectly embedded into them. To achieve this goal, it is all about partnership! Because not a bank, not a microfinance, not a mobile network operator will be able to develop this alone. Digital offers also tremendous opportunity for faster partnerships (ex: open API).”
  On page 45 & 46, UNCDF would welcome to include other new players beyond fintech only (platforms, start-ups in various sectors like energy, agriculture, education, health, etc.) as key driver of usage of financial services.  There is a key role to foster partnership with financial services providers and these new players to drive usage.