(UN)STACKING

FINANCIAL MARKET
INFR ASTRUCTURE

August 2020 William Cook, Dylan Lennox, and Anand Raman

Consultative Group to Assist the Poor
1818 H Street, NW, MSN F3K-306
Washington, DC 20433 USA
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Cover photo by Nicolas Réméné via Communication for Development Ltd.

© CGAP/World Bank, 2020.

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Attribution—Cite the work as follows: Cook, William, Dylan Lennox, and Anand Raman. 2020.
“(Un)stacking Financial Market Infrastructure.” Working Paper. Washington, D.C.: CGAP.

All queries on rights and licenses should be addressed to CGAP Publications, 1818 H Street, NW,
MSN F3K-306, Washington, DC 20433 USA; e-mail: [email protected].
CONTENTS

Introduction 1
Enable financial inclusion through the Stack 2
Focus on schemes over technology 6
Bring infrastructure systems together 7
Looking ahead 10
References 11
1
Introduction
In March 2019, a group of senior government officials, regulators, banking executives,
and fintech CEOs from the Philippines gathered in Manila to discuss the future of financial
technology in their country (Schellhase 2019). During the workshop, participants debated the
potential of the market, highlighted opportunities to improve financial inclusion, and created
a list of the barriers to success. Topping this list was the absence of a “Philippine Stack”—a
financial infrastructure capable of providing safe, efficient, and ubiquitous digital rails.

The comments from the Manila workshop are far from unique. Similar conversations are
happening in markets across the world, driven in part by the global popularity of “India Stack.”
In India, several independent infrastructure systems work in tandem to improve digital financial
services for poor people.1 However, India Stack is more of a conceptual framework than an
operational one.

It has provided a common narrative to describe how separate infrastructure systems can help
to meet the various needs of poor people. India’s biometric identification system (Aadhaar)
allows for remote account opening. Its payment rails (e.g., the unified payment interface [UPI])
allow customers to use those accounts to make interoperable payments. Its data-sharing
ecosystem, which is supported by account aggregators, allows these payments to form
a shareable transaction history capable of proving credit worthiness. The systems are not
necessarily linked or even driven by the same institutional sponsors, but they leverage each
other to improve the overall value proposition for customers.

Different elements of this arrangement can be found in many countries. The core of India’s
real-time payments, a bank-led and participant-governed retail payment system, also is found
in Kenya with PesaLink, the United Kingdom with Faster Payments, and many other markets.2
There are ubiquitous biometric identity systems in Pakistan, Rwanda, Colombia, and other
countries.3 Collaborative facilities for sharing credit data are used in a wide variety of markets.

No two markets look exactly alike, and how well these systems work for poor people varies
widely. While India has shown that a single narrative can help coordinate efforts around a clear
set of goals, each market’s path will be different depending on the infrastructure already in
place in the market. As a result, local champions are essential, and they often come from the
topmost levels of government.

Understanding how to adapt infrastructure to meet the needs of poor people also requires
thinking about how each component will help to advance one or more inclusion goals. This is
what the Stack narrative has helped to achieve in India. It answers the question: What is the role
of each system in advancing our financial inclusion goals? The abilities of these components to
advance inclusion goals can be put in four main categorizes, as shown in Figure 1.

1 The Stack is used to describe complex systems as a neat pile of functions, arranged as conceptual layers.
2 PesaLink, https://www.sc.com/ke/pesalink/; Faster Payments, https://moneyfacts.co.uk/banking/guides/faster-
payments-how-do-they-work/.
3 See the World Bank’s ID4D website, https://id4d.worldbank.org/global-dataset references.

Introduction
2
FIGURE 1. How the Stack concept helps drive financial inclusion

Digital financial services

Managing Conducting Sharing

risk transactions personal data

Proving identity

1. Proving identity. Digital identity improves the ability of financial services providers to offer
identity verification and authentication remotely, including for account opening.

2. Managing risk. Collaborative due diligence allows financial institutions to better manage
consumer and compliance risk, sharing the compliance burden to reduce provider costs
while maintaining high levels of risk assurance.

3. Conducting transactions. Interoperable payment systems allow consumers fast,

efficient, and secure payment transactions between institutions. They also help to build the
transaction histories customers need to better access other value-added financial services,
such as credit.

4. Sharing personal data. Data-sharing arrangements provide customers the ability to

control and benefit from their own data. They can use the data to apply for loans, get
insurance more easily, or simply to change their provider relationship more easily.

The biggest challenges in scaling effective financial infrastructures that work for poor people
often are not about technology. Instead, they often revolve around questions of ownership,
governance, economics, regulation, and political economy. These challenges are not small, but
when addressed effectively, a system can emerge that improves the value of financial services
for poor people.

This paper is intended for policy makers and others who are interested in improving the
digital financial infrastructure in their countries with the goal of advancing financial inclusion. It
advocates for a scheme approach to infrastructure and describes some of the ways countries
have tried to accelerate progress toward better systems through a holistic narrative for better
“digital rails” in the country.

Enable financial inclusion through the Stack

iSPIRT describes the “Stack” as comprising “presenceless, paperless, cashless, and consent
layers” that are intended to drive more than just financial services. These terms vary between
markets as does the scope of what is included as part of the narrative. However, the layers

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roughly correspond to four major activities related to enabling financial inclusion: proving
identity, managing risk, conducting transactions, and sharing personal data.

PROVING IDENTIT Y
Identity provides a point of entry into the financial system and helps improve service delivery
in several ways. The World Bank’s Identification for Development (ID4D) program identifies
key roles for identity in advancing development goals, and several of these relate to financial
inclusion (World Bank 2019).

Some of these include establishing proof of ownership, satisfying customer due diligence (CDD)
requirements, proving uniqueness, authenticating transactions, and establishing proof of life.

Identity offers proof of ownership over property (e.g., to establish collateral for lending) and the
ability to satisfy CDD requirements (e.g., to obtain an account). Digital identity allows these
activities to happen remotely, which lowers the burden on customers. Countries like India and
Pakistan have developed centralized digital ID systems that allow customers to biometrically verify
their identity. Other countries offer digital ID systems where verification can be done remotely,
though not through biometrics—the Integrated Population Registration Services system in Kenya
is an example of this.4 Most countries have some sort of digitized version of records; the question
is more often about how easily that information can be used by the market.5

Second, identity systems that offer deduplication within a given population can help to establish
the uniqueness of consumers. For example, they help to ensure the same consumer does
not have several credit profiles. At a market level, uniqueness may be limited where ID systems
are used in federated or open-market models—where several entities can provide government-
recognized identification (World Bank 2019). In countries with multiple systems, such as the
United Kingdom, the United States, and Brazil, establishing unique identities for the purposes
of assessing credit or performing consent-based data sharing fall to the systems offering those
services or to financial services providers themselves.

However, even in markets with centralized systems, such as India with Aadhaar, the use of the
ID system to establish uniqueness can be contentious. When India’s tax authority announced
the use of Aadhaar to establish uniqueness, multiple stakeholders challenged the legality
of this action.6 India’s public credit registry, which is in development, intends to link credit
reporting records to tax identification to establish uniqueness in the system. However, it relies
on Aadhaar’s centralized database only indirectly. India’s consent-based personal data-sharing
scheme has opted to avoid some of these challenges by not relying on a single unique identifier,
even though this is theoretically available through Aadhaar.

Secure payment authentication (e.g., proving payers are who they say they are) and proof
of life (e.g., ensuring a social protection recipient is still present or alive to receive benefits) are

4 See IPRS Kenya, https://immigration.go.ke/integrated-population-registration-systemiprs/.

5 There are very few examples of fully nondigital identification (i.e., where no portion of the information is
digitized). One example of this is the Kebele card in Ethiopia where paper-based cards are issued through
decentralized issuance centers and no digital record is maintained.
6 Addendum to India’s Income Tax Act, 2017, https://www.incometaxindia.gov.in/Acts/Finance%20
Acts/2017/102120000000064612.htm. See also LiveMint (2020).

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two more ways that identity, and biometrics in particular, can support financial services. In cash
transfer schemes, biometrics can help ensure the intended beneficiary received the payments.
Examples of this include the United Nations High Commissioner for Refugees’ iris-scan
payments in Jordan using a United Nations beneficiary registry and Aadhaar-based transfers
for social protection payments in India. In Kenya, social protection payments are secured by
biometrics, but the biometrics are held with the financial institution and collected at the time
of enrollment. The commonality in all these cases is that some biometric token helps to prove
information. A foundational national identity is only one among a variety of options for meeting
these objectives.

Finally, digital signature solutions in coordination with digital identity also offer consumers the
ability to digitally sign documents such as loan agreements and other contracts (FATF 2020).
These have a long history with services like Verisign, which serves wealthy customers in
developed markets, but are becoming increasingly relevant in developing markets.7

MANAGING RISK
Some components of financial infrastructure help manage the risk and cost absorbed by
providers when they comply with anti-money laundering and combatting the financing of
terrorism (AML/CFT) requirements. Solutions such as collaborative know-your-customer (KYC)
assessments make it possible for a customer to avoid repeated KYC checks by sharing the
assessment already performed by a provider.

India established a centralized KYC solution in 2015. The system is operated by the Central
Registry of Securitization Asset Reconstruction and Security Interest of India. However, it is not
widely used. There are few other examples of markets that have tried the model, and questions
remain around whether the right economic incentives exist to drive adoption.

The Association of Banks in Singapore pursued a utility that would support both customer
identity verification and beneficial ownership checks of corporate customers, but a lack of a
viable business case led the service to be shut down (Lyman, de Koker, Martin Meier, and
Kerse 2019). Collaborative models for managing risk may struggle, in part, because liability
often remains with the provider. Shared services will not offer efficiency gains unless providers
are also comfortable reducing their own internal compliance activities and costs.

Other facilities for shared transaction monitoring and reporting, assessment of beneficial
ownership, and risk assessment and profiling have the potential to collaborate and standardize
activities that drive up costs for providers, but there are similarly few global examples. As open
banking regimes gain traction, new decentralized mechanisms for improving risk management
also may become available, but this remains to be proven.

CONDUCTING TRANSACTIONS
Digital payments offer a well-documented value to financial inclusion through sending
remittances, receiving social protection payments, and driving other solutions. They are
becoming more relevant in helping to build the data footprints necessary for poor people to

7 Verisign is a global provider of domain name registry services and internet infrastructure.

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obtain other financial products, such as credit, for the first time. Interoperable services improve
the value proposition for payments by allowing customers to conduct transactions across
providers rather than in silos.

Interoperable payment systems have a long history in card-based models and interbank transfers,
but they are becoming increasingly positioned to support the small-dollar, real-time transactions
relevant for poor people. Instant payment systems are becoming popular in both developed and
developing markets—from Faster Payments in the United Kingdom and NPP in Australia, to FAST
in Cambodia, InstaPay in Philippines, and PesaLink in Kenya, among many others.

Increasingly, these systems are expanding to accommodate new types of actors that are more
likely to serve poor people with accounts that are the on-ramp to formal financial services.
Examples include JomoPay in Jordan, which includes bank and e-money participants, and
NPCI in India, which extended participation to prepaid issuers. Services like UPI in India also
push the boundaries of payment interoperability by allowing for transactions to be initiated by
services providers other than those who hold (issue) the account (Cook and Raman 2019).

S H A R I N G P E R S O N A L D ATA
Accounts and digital transactions offer an on-ramp to financial services for poor people, but a
broader array of services is needed to improve livelihoods (FinAccess 2019). Consent-based
data-sharing models, such as open banking and India’s data-sharing architecture, allow
consumers to use their data to obtain services such as credit and insurance and get better
financial advice. They also help providers build better user experiences.

Other collaborative models, such as MyData, have voluntary data-sharing frameworks with
public and private collaboration, but few have achieved scale.8 One reason behind the limited
adoption of these models may be that while financial services providers may have a clear
incentive to participate in an arrangement for payment interoperability, which would allow
their customers to make and receive more transactions, those same providers may have less
incentive to participate in a data-sharing arrangement that they believe will benefit only other
actors. India’s account aggregator model attempts to address this by requiring participants who
are able to receive data to also share data (Datwani and Raman 2020).

The most ubiquitous examples of data-sharing infrastructure are credit bureaus and public
credit registries. These services often are different from consent-based data sharing in that
they focus on consumer liabilities rather than assets (Nilekani 2019; Aiyar 2017). Consent-based
models often are not well-positioned to report on liabilities because consumers could opt not to
consent to sharing information that puts them in an unfavorable light.

Infrastructure solutions that support better digital identity, risk management, financial transactions,
and data sharing can vary widely between markets. These systems have the potential to carry
unique consumer benefits, project needs, and participant incentives, depending on market
context. However, designing a scheme is complicated and requires looking beyond technology to
the governance and economic considerations that drive effective use.

8 See MyData, https://mydata.org/.

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Focus on schemes over technology
Policy makers and other champions of inclusive financial services infrastructure tend to
approach these issues as technology problems. However, infrastructure is about more than
technology. The ability of financial services infrastructure to effectively serve poor people
depends heavily on building sustainable and inclusive schemes.

A scheme generally is defined as a large-scale plan or arrangement. In the payment systems

space, schemes define the rules for how participants will work together, how incentives will
be balanced, and how systems will provide the necessary level of support, and the same
conceptual framework can be useful in promoting effective models for other types of financial
infrastructure. These three elements (shown in Figure 2) form the basis of an inclusive, effective
infrastructure that is capable of advancing the needs of poor people.

• Scheme governance defines the power

FIGURE 2. Three elements
structure of the scheme and the way
of an effective scheme
decisions will be made. Fair and inclusive
governance helps ensure participation
from a variety of actors, including those
best positioned to serve poor people,
such as e-money issuers. The role of
the infrastructure owner or operator in
making these decisions—and its ability to
Scheme Economic
self-supervise—will depend on local laws governance incentives
and regulations.

• Balanced economic incentives between

infrastructure operators and participants
help ensure use of the system at scale Operational models
and a sustainable commercial model to
support ongoing operation. Infrastructure
owners and operators must cover costs to
ensure sustainability, either through fees to
participants (users) or through some form of subsidy. Understanding and applying the right
incentives help to ensure costs are not passed on to poor people, except where necessary.

• Effective operational models help ensure the system is reliable and that appropriate
contingencies have been considered in case of failure. They also help owners and operators
manage emerging risks, clearly communicate expected service levels, and define mitigating
actions when things go wrong. For poor people, this means being able to count on the
services they use. Financial products offered to consumers will be only as reliable as the
infrastructure that products ride on.

Taking a scheme view of infrastructure components and thinking about the impact of governance
and economic incentives, operational models help to ensure individual infrastructure components
are best placed to serve poor people. For example, questions such as the following go beyond

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technology investment but have significant impact on how financial infrastructure will or will not
support financial inclusion:

• What are the rights of an e-money issuer in accessing a digital ID system for CDD verification
as compared to that of a bank?

• How does a payment system use interparty fees to balance participant incentives?

• What measures in a data-sharing arrangement help to maintain data-blind intermediaries?

While the champions, owners, and operators of these arrangements can be drawn from the
public or private sectors, the public sector is likely to play a role in any scheme discussion. This
role may be limited to oversight, such as ensuring fair use and compliance with relevant policy
and regulation, but it also could take on the role of a catalyst that prompts the private sector to
take certain action or a directly operational role that is responsible for owning and operating the
infrastructure system (Cook and Raman 2019).

The nature of the public sector’s role will vary depending on the type of infrastructure and the
market context. While identity systems frequently are operated by the public sector and retail
payment systems frequently are governed by industry, there are exceptions to both. For policy
makers, improved service delivery, stability, integrity, and consumer protection drive these
decisions. For financial services providers, incentives more frequently include cost reductions
and the ability to provide new services that are native to digital.

Building effective infrastructure systems that meet the needs of all participants and encourage
sustainable growth is not easy. Yet some markets have taken the discussion around
infrastructure to another level of abstraction, drawing conceptual lines around a series of
infrastructure systems in the market to highlight how these systems might work in tandem as a
Stack to address the needs of poor people.

Bring infrastructure systems together

Anyone who has ever met Sharad Sharma, co-founder of iSPIRT, India’s civic technology think
tank, probably has heard the story about Rajni. Rajni is a poor fruit seller in Mysore. She needs
credit to run her business but that requires a variety of services: a credit history, a way to safely
receive the funds, and a way to get an account in the first place. However, Rajni historically has
not had access to these services.

India Stack (as shown in Figure 3) first helps address her need for a financial account with the
digital identity proofing provided by Aadhaar. Once she has an account, Rajni can use UPI
to make interoperable digital payments from her mobile phone and thus build a transaction
history. Through India’s data-sharing framework, her transaction history is made available to
other services providers who can check her creditworthiness and provide a loan offer. Finally,
India’s digital signature solution gives her the ability to sign the loan agreement remotely. The
funds are transferred into her account, from which she can spend and repay digitally and can
continue to build her digital footprint to obtain future services.

Bring infr astructure systems together

8
FIGURE 3. India’s approach to the Stack

Banks, PPIs, OTT

NPCI/UPI Authentication Agencies Digilocker

Centralized KYC Account Aggregators

UIDAI/Aadhaar

This type of visioning—a mix of human-centered design and strategic planning—forms the
basis of what iSPIRT has championed as India Stack. For this one loan transaction to work
effectively, several digital infrastructure components must work in tandem. These infrastructure
systems are separately developed and serve different purposes in the market, but they work
together to achieve a common goal.

This type of narrative helps to build the vision of infrastructure systems in relatable rather than
technical terms. However, consumer needs will be different in every market, and there is likely
to be more than one user profile—more than one Rajni. A narrative helps tell the story, and this
narrative continues to evolve as new innovative use cases are added.

Global experience suggests that two factors are typically necessary to drive a market-level
narrative: finding a champion and building popular legitimacy.

FINDING A CHAMPION
Nandan Nilekani—former CEO and current Chairman of the technology company Infosys—first
outlined a form of the vision for India Stack in a book that was published in 2007 (Nilekani 2009).
In 2009, he was appointed to a cabinet-level position to oversee the implementation of India’s
digital ID system, Aadhaar. In driving Aadhaar, Nilekani recruited talented people from the private
sector as volunteers. These volunteers provided early technical skills and capacity that would
have been difficult for the government to easily acquire. The team deliberately built in flexibility and
scalability. It used open technologies and standards to avoid being locked into using only one or
two vendors.

It was in this context that the volunteer organization iSPIRT was founded by Sharad Sharma
in 2013. iSPIRT draws on the belief that private innovation can build value only when local
communities create foundational public goods as an open ecosystem.

Over the same period, the Reserve Bank of India (RBI) led the creation of the National
Payments Corporation of India (NPCI), and more recently, it played a leading role in driving
consent-based data sharing (Datwani and Raman 2020). RBI provided direction, institutional
memory, convening power, and legitimacy for these projects. However, iSPIRT has continued
to act as a champion for each, and it also has continued to connect the dots between efforts to
help to provide capacity and drive the narrative for change.

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Champions work outside government or at a high level within an administration to drive a
holistic narrative for change can be seen outside India. Examples include Anir Chowdhury
working with a2i, an e-government initiative directly supervised by the Prime Minister’s Office
in Bangladesh, and Nadeim Makaram, co-founder and CEO of Go-Jek, holding in a cabinet-
level position in Indonesia (Potkin 2019). In Kenya, a comprehensive strategy toward market
infrastructure has been championed in part by FSD Kenya. The plan, called “Digital Finance
2.0,” includes aspects of digital identity and eKYC, retail payment infrastructure, and personal
data sharing.

What makes an effective champion? Ideally, a champion’s ability to motivate extends beyond
her ability to mandate. This may be one reason why India and an increasing number of other
countries are looking beyond government and toward civil society to help drive change.
Representation from civil society allows initiatives to maintain continuity through political changes.

The champion’s role of inspiring change is not necessarily the same as that of a neutral
facilitator or resource center, but the hats are often worn together. Successful examples such
as iSPIRT offer both additional (free) capacity to the market and a voice that is independent
from constituencies inside and outside government.

The case for change often is rooted in a vision that can be hard to quantify—for example,
think about all the ways Rajni’s life will improve when these systems work in tandem to solve
her problems. However, the achievement of intermediate goals likely will be driven by more
immediate realities. For example, Aadhaar’s adoption largely was driven by an opportunity to
improve the process for disbursing social protection payments, which helped the government
save money. The system solved an immediate pain point for stakeholders, while at the same
time it put down the first plank toward the vision of a broader digital future for poor people.

Centralized environments—such as Thailand, China, or Vietnam—where strong public sector

institutions have played a coordinating role seem to have an obvious advantage in setting a
marketwide roadmap. However, the importance of popular acceptance is not to be undervalued.

BUILDING POPUL AR LEGITIMACY

While Nandan and the iSPIRT team helped shape a vision, they were contributing to a much larger
agenda. In July 2015, Indian Prime Minister Narendra Modi launched “Digital India,” a campaign by
the Government of India to improve digital infrastructure in the country. It covers everything from
e-governance and communications to the infrastructure supporting financial services.

The digital nation, waving a banner for technology, is a familiar concept, but the success of these
programs varies widely. Commitment from the topmost levels of government is a key success factor.

“There needs to be a vision from the political side. It needs to be there always—a policy,
not politics. But the politicians need to live it,” said Marten Kaevats, Estonia’s national digital
adviser in 2017 as he described his country’s path to progress. The Estonia government has
consistently championed its country’s digital infrastructure and as a result, invested heavily in that
infrastructure. “We had to set a goal that resonates, large enough for the society to believe in,”
said Taavi Kotka, former chief innovation officer of Estonia (Heller 2017).

Bring infr astructure systems together

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A similar ethos was embraced by India. Progress on initiatives like the payment systems reforms
driven by NPCI were tracked in weekly reporting up to the level of the Prime Minister’s Office.

Part of building legitimacy involves applying what makes a country culturally unique to create a
narrative that resonates. Aadhaar, which means “foundation”; Bharat, which means “truth seeker”;
and BHIM, which is a reference to Bhimrao Ambedkar, the architect of the Indian constitution, all
draw on a sense of patriotism in a country with high trust in government institutions. A part of what
drove membership in NPCI after some initial reticence from mid-tier banks was a demand from
consumers who wanted their BHIM app because it was named and championed by the Prime
Minister. To offer BHIM, banks had to join NPCI as participating members (Cook and Raman 2019).

In Estonia, forming this narrative meant reaching into cultural heritage for a sense of identity in a
post-Soviet society. For example, the term kratt, which refers to an assembly of objects brought to
life in Estonian folklore, was used to establish a new discourse around the roles of algorithms and
technology in public life (Heller 2017). The discourse was important in the context of emerging as a
digital nation, and the term connected with the public in a way that technical jargon could not.

Looking ahead
Even in India, the what of India Stack continues to evolve as new use cases are imagined and
new infrastructure systems are developed. Some use cases such as centralized KYC remain
underused. Others such as India’s account aggregator model for open banking will soon be
tested. And yet India’s progress remains defined in terms of the whole rather than the success
or failure of individual systems.

In India, a government benefactor found great value in driving a government-to-person use

case to promote early change. Is this repeatable? In some markets, maybe. Countries like
Bangladesh and Indonesia are picking up a portion of the India playbook to develop similar
solutions for enabling social protection payments. Other markets are looking toward different
government use cases and still others are looking to the private sector to drive the change
toward better, more connected digital rails.

More than ever before the necessary technology tools are available. Biometric identity systems
are cheaper to build. Open source platforms like the Modular Open Source Identity Platform are
being implemented in markets like Morocco and the Philippines (Ganapathi and Karwa 2018).
Best practices in the development of infrastructure components are being championed through
the projects of global partners such as the Bank of International Settlements, the World Bank,
ID4D, and others. However, these remain tools to help implement a broader vision.

The vision for change and the narrative must be local—as must the champions who drive
that narrative. Civil society has a unique role to play in bridging public and private sector
conversations, attracting the right talent, and pressing an agenda for change that outlives
changing political fortunes. However, public sector leadership is equally important in solidifying
legitimacy, building popular support, and in many cases, ensuring adequate funding.

Where all these pieces come together, infrastructure systems have the potential to go beyond
siloed technologies and instead become the building blocks for financial inclusion.

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Re f e r e n c e s
cgap.org