Prudential Supervision for Deposits and Payments: Supervision of EMIs

E-money services have become a significant catalyst for financial inclusion, particularly in emerging and developing economies. These services provide an effective gateway to the formal financial system for unbanked and underserved populations, enabling them to conduct transactions and build a financial history.

According to the World Bank’s Global Findex 2025 database, the share of adults in developing economies making digital payments grew from 34% in 2014 to 62% in 2024. 
This surge is largely attributable to the accessibility of e-money, with mobile money accounts being a key driver of account ownership in regions like Africa and Asia. The ability to send and receive payments, pay bills, and access other financial products through a mobile phone has empowered millions, fostering greater economic participation.

The continued growth and sustainability of e-money services rely heavily on a robust regulatory framework and the diligent oversight of a financial prudential supervisor. The supervisor’s role is to ensure the safety and soundness of e-money issuers (EMIs), thereby fostering public trust and confidence in these services.

Public trust and confidence are achieved by implementing a range of prudential measures: 

• Minimum capital requirements
• Risk management and internal controls protocols
• Safeguarding rules that mandate EMIs to protect customer funds. (This is the most critical)

By ensuring that EMIs are well-governed and operate within a secure and transparent environment, the supervisor indirectly mitigates the risk of customer losses. 
This prudential oversight is crucial for protecting consumers, maintaining the integrity of the financial system, and ultimately encouraging the widespread adoption of e-money as a safe and reliable tool for financial inclusion.

The following interaction explores the prudential supervision of EMIs in more detail. It also looks at the growing need and push to protect those who deposit their money into EMIs. 

Additional Reading 

The following additional reading is advised in the interaction. Here is the list again for convenience. 

• Dias, D. and Staschen, S., 2018, A Guide to Supervising E-Money Issuers, CGAP. 
  https://www.cgap.org/research/publication/guide-to-supervising-e-money-issuers
• Dias, D. and Kerse, M. 2021, Regulatory Approaches to the Interest Earned on e-Money Float Accounts, CGAP Technical Report, 
  https://www.cgap.org/sites/default/files/publications/2021_05_Technical_Note_Interest_Float_Accounts.pdf
• Dobler, M., Garrido, J., Grolleman, D.J., Khiaonarong, T. and Nolte, J., 2021, e-Money: Prudential Supervision, Oversight and User Protection, IMF. 
  https://www.imf.org/-/media/Files/Publications/DP/2021/English/EMPSOUPEA.ashx
• Trusts Law Protection for E-Money Customers, 2013, Lessons and a Model Trust Deed Arising from Mobile Money Deployments in the Pacific Islands, AFI,
  https://www.afi-global.org/sites/default/files/publications/piwg_knowledge_product_e-money_trust_and_model_trust_deed.pdf