Ama is a market trader in Africa. From her stall, she sells groceries, cooking oil, sugar, tinned tomatoes, spices, and soap. A natural entrepreneur, Ama dreams of expanding her business by moving into a shop. But that takes capital, and she has no idea how to get a bank loan. And which bank would consider lending to her, given her lack of formal credit history or collateral?

Now bear in mind that most of Ama’s customers pay via mobile money, and she pays her suppliers digitally. Over time, these daily transactions build a clear record of her income and business activity, effectively forming a credit history.

What if, with Ama’s consent, her transaction details could be securely shared with different providers? Banks or fintechs could use this data to understand her business, and offer tailored services such as small loans, savings, or insurance that match her cash flow. Ama could view these offers through a mobile app, and compare key details like loan amount, interest rate, repayment period, and total cost, helping her to identify the most suitable and affordable option.

Ama’s everyday business activity would generate a usable financial profile and history, and bring competing offers to her in a clear, comparable way.

This is the premise of Open Finance, a regulatory and market framework that enables secure, consent-based sharing of a customer’s financial data across different financial service providers through interoperable systems, typically Application Programming Interfaces (APIs).

How does Open Finance affect inclusion?

Open Finance advocates say that that it promotes innovation and fosters healthy competition, while empowering customers to make informed choices. And that by facilitating a level playing field among providers, and improving the choice, quality, and convenience of financial services, it serves to accelerate financial inclusion.

As a counterpoint, however, observers including the OECD have flagged that unless strong safeguards are in place to protect consumers, Open Finance frameworks can generate considerable risk around inappropriate data usage and handling, privacy leakage and unauthorized surveillance.

At the recent 3i Africa Summit in Accra, I joined a panel discussing ‘Open Finance and Data Sharing: Governance, Standards and Innovation’, sharing perspectives from the global AFI network. In 2025, AFI published a Policy Development and Implementation Guide for Inclusive Open Finance, which sets out a comprehensive framework for policymakers and regulators to design and implement inclusive data-sharing ecosystems.

Drawing on the experiences of AFI’s 80+ member institutions across emerging and developing economies, including 44 from sub-Saharan Africa, I stressed a number of core requirements for effective governance of Open Finance from AFI’s Policy Guide on OPen Finance:

• Meaningful consent. Consumers should remain in control of their data through consent that is informed, specific, time-bound, and easy to withdraw. Countries such as the Philippines are already demonstrating approaches where users can clearly see and manage who is accessing their data, what data is being shared, and for what purpose, helping strengthen transparency and trust in the system.
• Clear accountability across the ecosystem. Open finance involves multiple actors; banks, fintechs, mobile money providers, and third-party providers, so responsibilities must be clearly defined. This includes licensing and supervisory arrangements, cybersecurity and API standards, auditability, and clear liability when things go wrong.
• Strong consumer protection, built into the system from the start. This includes privacy safeguards, transparent data use, effective redress mechanisms, and protections against fraud or discriminatory outcomes. This is especially important in Sub-Saharan Africa, where mobile money ecosystems often serve as the primary entry point into formal finance.
• Approaches should be country-led and contextualized, grounded in national needs and objectives, and existing levels of financial sector development. There is no single model for Open Finance: some jurisdictions may develop centralized API layers, while others may build on or extend existing infrastructure such as payment systems and mobile money rails.

The importance of trust

Ultimately, strong data governance builds trust, which is the currency of open finance, as well as foundational to participation and inclusion. In markets where trust is still developing, liability frameworks need to be in place. These should be simple, enforceable, and supported by strong supervision and consumer redress. In practice, this means having clear legal rules that define who is accountable at each step of the data-sharing chain, mandatory incident reporting when breaches occur, audit trails so regulators can trace failures, and fast dispute resolution systems so consumers are not left dealing with multiple institutions. It also requires effective redress mechanisms to ensure consumers are protected and able to resolve issues in a timely way.

Another key principle is that open finance infrastructure must enable interoperability across providers and systems. This helps avoid fragmented or closed ecosystems, and ensures that banks, fintechs, and mobile money operators can participate on fair and standardized terms.

Applied together, these principles can create solid foundations for effective governance.

While Open Finance is still a relatively recent phenomenon, use cases from the AFI network and beyond indicate that it has the potential to contribute to an inclusive, sustainable and resilient financial landscape.

If we can get the governance right, Open Finance will benefit not just consumers like Ama, but our broader efforts to create an inclusive, robust and sustainable financial ecosystem.