The Nexus between Mobile Money Regulation, Innovative Technology and the Promotion of Financial Inclusion in Zimbabwe

The advent of mobile money innovations has given people in rural areas, informal settlements and other poor communities an opportunity to participate in Zimbabwe's mainstream financial economy. However, the technology-driven money services have presented some challenges to the traditional banking sector in general and the regulation of financial services in particular. Firstly, most mobile money services are products of telecommunication corporations, which are not banks. Telecommunication companies use their network reach to provide mobile money services via mobile devices at a cheaper cost than banks across the country in Zimbabwe. As such, banks face unprecedented competition from telecommunications companies that are venturing into financial services. It also appears that prudential regulation of banks cannot keep up with the fast pace at which technological innovations are developing and this has created a disjuncture between the regulation and the use of technological innovations to promote financial inclusion in Zimbabwe. The Banking Act [Chapter 24:20] 9 of 1999, the Reserve Bank of Zimbabwe Act [Chapter 22:15] 5 of 1999 and the National Payment Systems Act [Chapter 24:23] 21 of 2001 have a limited scope in terms of the regulation of mobile money services in Zimbabwe. The Ministry of Finance and Economic Development launched the National Financial Inclusion Strategy (NFIS) 2016-2020 to provide impetus to the financial inclusion of the poor, unbanked and low-income earners in Zimbabwe. However, the NFIS appears to push more for bank-led financial inclusion than it does for innovation-driven initiatives such as mobile money services. This article highlights the positive influence of mobile money services in improving financial inclusion for the poor, unbanked and low-income earners in Zimbabwe. The article also seeks to point out gaps and flaws in the financial services regulatory framework that may limit the potential of mobile money services to reach more people so that they actively participate in the Zimbabwean economy. It is submitted that the Zimbabwean mobile money services regulations and the financial regulatory framework should be carefully amended in line with the recent innovations in mobile money to adequately regulate the use of mobile money services and innovative technology to address the financial exclusion of the poor, unbanked and low-income earners in Zimbabwe.

accounts without visiting a bank branch. 6 However, for the purposes of this article, we refer to mobile money services that are offered by telecommunication companies in Zimbabwe. 7 Accordingly, bank-led mobile money services fall outside the scope of this article. Mobile money users are able to store funds either originally purchased as airtime or as money that has been deposited directly into the relevant user's mobile wallet for future use either as electronic money or withdrawn as cash. 8 (For the purposes of this article, the terms users and customers will be used interchangeably.) Zimbabwe has mobile money platforms such as Ecocash, Onemoney and Telecash that are run by three mobile network operators (MNOs), namely Econet, NetOne and Telecel respectively, and not by conventional banks. 9 Ecocash, Onemoney and Telecash are accessible through the use of mobile phones and they have changed the way that the poor, unbanked and low-income earners access financial services and financial products in Zimbabwe and other developing countries. 10 Mobile money platforms provide some avenues for financial inclusion for the poor and previously unbanked persons who become able to participate in the formal financial sector in Zimbabwe. 11 Financial inclusion entails the provision of access for all persons to affordable and useful financial products and financial services such as payments, savings, credit and insurance in a responsible and sustainable manner by various providers in a properly regulated environment. 12 On the contrary, financial exclusion means the failure or inability of poor and unbanked persons to access and use reasonably cheap and suitable financial services and financial products that are 6 Wayne et al 2020 Research Agenda Working Papers 43; Bećirović, Bajramović and Ahmatović "Role of Mobile Banking" 89, 91-92;Chitokwindo, Mago and Hofisi 2014 MJSS 420.  offered in the formal financial sector of any country, including Zimbabwe. 13 Persons who do not have access to formal financial services and financial products such as payments, savings, credit and insurance are regarded as financially excluded. There are various factors that contribute to financial exclusion of the poor, unbanked and low-income earners in Zimbabwe. These include the absence of a financial inclusion policy, geographical distance, proof of identity documentary requirements, the costs of financial services and products, cultural and psychological hindrances. 14 For the purposes of this article, the poor, unbanked and low-income earners refer to both unemployed and employed persons who do not have enough money or income to support themselves or to maintain a bank account. 15 Put differently, poor, unbanked and low-income earners have limited or no access to formal financial services and they often resort to cash when they do transactions. 16 Although the growing use of mobile money and related digital financial services is a positive development for financial inclusion, it requires the relevant authorities to effectively regulate and supervise mobile money services in Zimbabwe. 17 The effective regulation of mobile money is crucial owing to the fact that mobile money combines a telecommunication service on the one hand and a financial service on the other. These two sectors have separate regulatory frameworks in Zimbabwe. 18  anonymity, elusiveness, rapidity and poor oversight of the system, due to the limited or poor regulation and supervision by regulators. 20 In addition, the instant nature of mobile money transactions appears to be too fast for effective regulation and supervision of the financial sector in Zimbabwe. 21 As a result, these innovative technologies have both positive and negative implications for consumers, financial service providers, financial sector regulation and the economy at large. 22 It is submitted that Zimbabwe does not have legislation that expressly regulates mobile money services. In this regard, a wide range of incoherent laws are used to regulate and supervise innovative financial services and products in Zimbabwe. The authors argue that a new statute must be enacted to accommodate innovative technology that effectively regulates the financial sector to promote financial inclusion for the poor, unbanked and low-income earners in Zimbabwe. Against this background, this article discusses the relationship between mobile money regulation, innovative technology and the promotion of financial inclusion for the poor, unbanked and low-income earners in Zimbabwe. in the formal financial sector in Zimbabwe. 35 The high rate of mobile money adoption in Zimbabwe mirrors what has transpired in other similar developing countries in Africa such as Kenya. 36 Kendall and Voorhies express the opinion that the majority of the poor and unbanked persons in developing countries have embraced mobile phone technology and are using their mobile devices to send, receive and save money cheaply and securely without the need for banks or bank accounts. 37

How mobile money operates in Zimbabwe
Mobile money service providers may not pay interest on deposits or provide loans like conventional banks. Accordingly, it is hoped that technological innovation will result in greater financial inclusion for the poor and low-income earners in Zimbabwe. 38 Each mobile money platform provides financial services to customers who use SIM cards registered with its parent MNO. For instance, Ecocash accepts cash deposits from Econet subscribers and Onemoney deals with those using NetOne, while Telecash serves Telecel subscribers. There are less stringent requirements when an individual registers a mobile money account than when the same individual opens a bank account. 39 For instance, mobile money users are not compelled to produce proof of residence or income. Instead, they can be registered once they produce any form of identity, such as an identity card or passport. 40 For a person to open a bank account, he or she is supposed to satisfy the Know Your Customer (KYC), anti-money laundering (AML) and counter-terrorist financing (CTF) requirements. 41 It is submitted that the relaxed requirements to open a mobile money account enable the poor and unbanked persons who usually lack sufficient documentation, such as migrant workers, to get registered and participate in the mainstream financial system in Zimbabwe. In exchange for cash deposits, mobile money service providers credit the mobile money user's mobile account with an e-float or 35 Mbengo  e-money. 42 The e-float is the equivalent of credit in a bank account and it is held in a mobile account or mobile wallet under the user's name, ready for withdrawal or any other transaction the user may want to perform. 43 A mobile money service provider like Econet manages the mobile money account or wallet, recording the amount of money held by a customer at any given time. 44 As indicated above, mobile money users in Zimbabwe are not charged for depositing funds, but users pay tariffs levied according to the amount of money they withdraw. 45 For example, in Zimbabwe a user may pay $3 when she or he withdraws $100. Mobile money users can transfer the money from their account to another account using the Short Message Service (SMS). 46 Mobile money may be used for various purposes such as micro-payments to merchants, paying utility bills, business-to-business transfers (B2B), person-to-person transfers (P2P), business-to-person transfers (B2P) and long-distance remittances. 47 The recipient of the transferred value or money can redeem it as cash at agents who work for MNOs across Zimbabwe or use it electronically to pay for goods and services such as bills, debts, fuel and bus fare. 48 Agents are individuals, shops or garages that MNOs like Econet contract to provide mobile money services in all areas across Zimbabwe. 49 However, it appears that the success of mobile money depends on several factors such as the regulatory environment in which it operates to promote the financial inclusion of the poor, unbanked and low-income earners. Kendall  success of mobile money. 50 Furthermore, Munyoro et al point out that contractual obligations between a service provider like Econet and its agents is critical in ensuring that agents work in the best interests of their principal. 51 Therefore, it is beneficial for mobile money service providers to give competitive commissions and to invest in training and branding their agents to ensure continued service of their customers across Zimbabwe. 52 The agents ensure that people who want to register for mobile money services, those who want to transact and those receiving money, are served even though they are not registered. 53 It is submitted that without agents, it would be difficult for telecommunication service providers to spread their innovations and provide financial services to the poor, unbanked and low-income earners in Zimbabwe. Therefore, apart from the need for networks to have extensive reach, mobile money providers in Zimbabwe must have well trained, branded and equipped agents in communities, who are able to use technology to meet the financial needs of the poor, unbanked and low-income earners.

The use of mobile money to promote financial inclusion in Zimbabwe
Before the advent of mobile money, the poor, unbanked and low-income earners in Zimbabwe would pay their bills in cash and send cash to families in distant places via bus drivers or friends. 54 This mode of remitting funds was risky, unreliable and very slow. 55 Mobile money has opened doors for the poor, unbanked and low-income earners to remit money, even small amounts, in a cheaper, safer and faster way than before. Furthermore, the poor and unbanked persons are now able to participate in Zimbabwe's mainstream financial sector as they can keep their electronic money in their mobile wallets and do transactions in real 50 Gibson  (24)  10 time, sending and receiving money instantly at very low cost. 56 Mobile money service providers have managed to develop branchless, convenient and fast financial services platforms that are available to almost everyone with a mobile phone handset. 57 Chinakidza, Mbengo and Nyatsambo argue that mobile money services are reaching the poor and unbanked persons who were financially excluded due to the unavailability of banks and other basic financial services in areas outside towns and cities in Zimbabwe. 58 As outlined above, millions of poor and low-income earners in Zimbabwe have now adopted mobile money and are now able to access their savings, insurance, credit and other financial tools to meet their daily needs. 59 It is submitted that mobile money has dismantled a number of barriers that kept the poor, unbanked and low-income earners outside the mainstream financial sector in Zimbabwe. Munongo and Bizah argue that some of the factors that contributed to their financial exclusion are a trust deficit in banking institutions, their distance from financial institutions and their failure to satisfy documentary requirements such as a proof of identity and a proof of residence. 60 For instance, banks require customers to produce a proof of identity when opening accounts in line with prudential requirements. 61 However, the requirement for proof of identity is not rigorously enforced when a person opens a mobile money account. It suffices for a potential mobile money user to produce an ID or passport to register a mobile money account in Zimbabwe and other developing countries. 62 The relaxation of identity requirements for mobile money services could be intended to allow the poor, who may not have identity documents, also to participate in the formal financial sector. Besides identity requirements, the costs of opening and maintaining a bank 56 Kendall account are too high for poor and low income earners in Zimbabwe. 63 Nonetheless, a registered SIM card inserted even in a basic mobile phone can store monetary value, enabling a user to process payments, save, send and receive money. 64 Moreover, mobile money service providers have agents who serve the poor and unbanked persons in communities where they live in Zimbabwe. 65 As a result, mobile money services have managed to thrust the poor and unbanked persons back into the formal financial markets and the mainstream economy in Zimbabwe. 66

Mobile money regulation and financial inclusion in Zimbabwe
Mobile money is an innovative financial product that has managed to put millions of poor, unbanked and low-income earners into financial inclusion in a considerably shorter period of time than banks in Zimbabwe. 67 Before the advent of mobile money, the majority of financially excluded persons relied on informal cash transactions that often posed systemic risk to the financial markets in Zimbabwe. 68 In addition, liquidity challenges and distrust in the banking sector resulted in the poor and low-income earners being financially excluded in Zimbabwe. 69  telecommunications aspects are non-prudentially regulated in Zimbabwe. According to Lumsden, the financial aspects of mobile money require prudential regulation that seeks to avert systemic risks which may lead to the collapse of the financial sector and the economy in any country. 72 On the other hand, the ICTs or telecommunications aspects of mobile money require non-prudential regulation that deals more with the promotion of transparency, establishing accounting standards and dispute resolution methods that protect the poor, unbanked and low-income earners. 73 It is submitted that the robust regulation of mobile money helps stabilise financial markets, protects consumers and generates market and business confidence while keeping the poor and unbanked financially included. 74 Policy makers should enact robust mobile money legislation that embraces the use of innovative technology to curb the financial exclusion of the poor, unbanked and low-income earners in Zimbabwe. 75 The Zimbabwe NFIS, 2016-2020 proposes changes to the legal and supervisory framework to promote financial inclusion through financial innovations. 76 However, no legislation has been enacted in line with the Zimbabwean financial inclusion strategy to date. Due to the absence of a specific statute that regulates mobile money in Zimbabwe, laws that regulate electronic money have been used to regulate telecommunications-driven financial services. 77 earners in Zimbabwe. 78 The NFIS provides that mobile money is a financial tool that is crucial for the payment system and financial inclusion of the poor and unbanked persons in Zimbabwe. 79 According to Lawack, a payment system forms the basis of any sound financial system in any economy and it is important to the financial inclusion of the poor. 80 In this regard, the NFIS notes that mobile money has introduced payments, credit and other formal financial services to the adult population in rural areas in Zimbabwe. 81 However, the NFIS also notes that there is no coordinated national policy on financial inclusion in Zimbabwe. 82 Furthermore, poor consumer protection and resource constraints are some of the factors hindering the financial inclusion of the poor, unbanked and low-income earners in Zimbabwe. 83 The relevant legislation on the regulation of mobile money in Zimbabwe is discussed below.

The RBZ Act and mobile money regulation
The RBZ Act regulates the functions of Zimbabwe's central bank, the RBZ. 84 The RBZ is a legal persona capable of suing and being sued in its name. 85 Furthermore, it is a creature of statute and its actions are guided by the enabling law. The RBZ is obliged inter alia to regulate and supervise banking institutions such as commercial banks, accepting houses, discount houses or finance houses. 86 The RBZ Act also regulates and supervises building societies and the Post Office Savings Bank (POSB). 87 In this regard, MNOs providing mobile money services are excluded from the list of institutions regulated and supervised by the RBZ. Therefore, it is clear that the RBZ Act does not apply to Econet, NetOne and Telecel, since they are not regarded as banking institutions.
In addition, the RBZ regulates Zimbabwe's monetary system and it is obliged to maintain the stability of the ensure a properly functioning financial services sector. 88 To achieve this, the RBZ is required to effectively oversee activities of banking institutions in Zimbabwe. 89 Furthermore, the RBZ has powers to print money, accept money from customers, grant loans, buy and sell securities, buy and sell precious metals and buy foreign currency. 90 It is submitted that the statutory functions and powers of the RBZ exclude MNOs and their mobile money activities. Thus, the RBZ Act does not provide for the regulation of mobile money services and it does not promote financial inclusion of the poor, unbanked and low-income earners.

The Banking Act, mobile money and financial inclusion in Zimbabwe
Although the Banking Act regulates mobile banking services offered by banks, or any other wireless service provider, it does not expressly regulate mobile money services that are offered by telecommunication companies in Zimbabwe. 91 Listed banking activities that are provided in the Banking Act that can be attributed to mobile money include receiving deposits, providing money transmission services and administering means of payment services. 92 The Banking Act applies to any other registered institutions that provide money transmission services in Zimbabwe. 93 While MNOs may be among the institutions offering money transmission services, they do not have registration certificates for the purposes of the Banking Act. 94 The registration certificate is usually issued to a banking institution upon registration. 95 Banking institutions that should be registered include commercial banks, accepting houses, discount houses, finance houses and micro-finance providers. 96 In this regard, MNOs in Zimbabwe are not registered as banks and there is no special provision for their regulation in the Banking Act. 97 Put differently, the Banking Act provides for the regulation of mobile banking services in line with conventional banking activities but it does not expressly apply to mobile money services that are offered by telecommunications companies in 88 Section 6 of the RBZ Act. 89 Section 6(1)(b) of the RBZ Act. Zimbabwe. 98 Thus, the poor, unbanked and low-income earners are not covered under the Banking Act in Zimbabwe.
In addition, the poor, unbanked and low-income earners are not protected in terms of the Deposit Protection Corporation Act (DPCA). 99 Consequently, mobile money deposits made by both the unbanked and banked individuals may not be protected under the DPCA, since MNOs are not legally recognised as financial institutions for the purposes of the Act. 100 Therefore, the Banking Act does not expressly provide for the promotion of financial inclusion for the poor and low-income earners in Zimbabwe. In addition, the Banking Act does not provide for the regulation and innovative technology to curb financial exclusion in Zimbabwe. Nonetheless, the Banking Act gives the Minister of Finance and the RBZ powers to develop regulations or guidelines that respond to new developments in the financial markets. 101

New banking regulations, mobile money and financial inclusion in Zimbabwe
In 2020, the RBZ published new banking guidelines that seek to coordinate mobile money services from different providers in a way that benefits the end user in Zimbabwe. 102 For instance, the new regulations require the cooperation of rival mobile money providers in the transfer of funds across mobile money platforms and their agents and between mobile money platforms and banks. 103 The regulations aim to create a smooth exchange of money between two or more mobile money accounts operated by different service providers and in the transfer of money between mobile money platforms and bank accounts. 104 In this regard the regulations represent a departure from the initial set-up, where mobile money service providers served their subscribed or registered customers only. Under the new regulations, mobile money services can cut across networks, allowing customers to send or receive money from any mobile money platform. In addition, mobile money platforms such as Ecocash, Onemoney and Telecash should be connected to the national payment switch and each should have a trust bank account dedicated to mobile 98 Section 7 of the Banking Act. banking. 105 This could protect mobile money users' funds against possible abuse by service providers. Nonetheless, mobile money users can access their service providers' platforms only if they are registered. 106 Furthermore, all mobile money users who have been suspended or barred from using mobile money services cannot transact. 107 Moreover, all mobile money transactions should be done within clearly specified limits. 108 The three measures given here are heavy-handed and they potentially hinder the growth of financial innovations and the promotion of financial inclusion for the poor and unbanked persons in Zimbabwe.

The National Payment Systems Act, mobile money and financial inclusion
The NPS Act regulates and supervises systems that clear payment instructions between financial institutions in Zimbabwe. 109 The NPS Act defines financial institutions as banking institutions that are registered and conduct banking activities in terms of the Banking Act. 110 In line with the discussions under the RBZ Act and the Banking Act above, MNOs that provide mobile money services are not registered financial institutions. Nonetheless, under the Banking Act, other institutions that provide money transmission services should also be regulated. 111 In this regard, the NPS Act accords the RBZ powers to extent its regulation and supervision to institutions other than financial institutions as long as such institutions provide financial services such as deposits, money transmission and payment services. 112 As discussed above, the RBZ could develop regulations on electronic payments that touch on mobile money services in Zimbabwe. Failure to adequately regulate payment systems could lead to disruptions that affect financial markets and the economy at large, compromising the availability of financial services to the unbanked. 113 Since the launch of mobile money services in 2011 in Zimbabwe, the RBZ has been responsible for all licensing and supervision of mobile money as a financial product. 114   Furthermore, the NPS Act does not give the RBZ express powers to supervise and regulate consumer protection matters pertaining to mobile money services. Therefore, the NPS Act is not robust enough because it does not regulate mobile money services so as to promote the use of innovative technology to enhance financial inclusion for the poor, lowincome earners and unbanked persons in Zimbabwe.

ICTs, financial crimes, mobile money and financial inclusion in Zimbabwe
The advancement in ICT innovation has opened room for non-banking institutions like telecommunication corporates to provide financial services in the form of mobile money in Zimbabwe. 117 The fact that telecommunication companies have ventured to provide financial services raises questions on whether the customer due diligence (CDD), the KYC and other requirements for the opening of an account should be strictly applied in the same way as they are applied by banks. 118 The CDD and KYC requirements are essential in combating financial crimes like money laundering that harm the integrity of financial markets and threaten financial inclusion for the poor. Money laundering includes actions of criminally minded persons that are undertaken to disguise the original ownership and control of the proceeds of their criminal conduct by presenting them as if they have been lawfully gained. 119 The Financial Action Task Force (FATF) has come up with anti-money laundering standards and there are international standards to combat the financing of terrorism (AML/CFT) and other financial crimes. 120 However, enforcing 115 Section 6(1)(e) of the RBZ Act; also see s 3 of the NPS Act; Bara 2013 AJSTID 348.
formal financial sector at great risk to the integrity of the financial system. 127

The Money Laundering and Proceeds of Crime Act, mobile money and financial inclusion in Zimbabwe
The MLPC Act 128 provides inter alia for the regulation of mobile money services and associated risks in Zimbabwe. The MLPC Act requires financial service providers to carry out money laundering and terrorist financing risk assessments in financial services and financial products that are accessed using technological devices such as mobile phones. 129 It is submitted that the MNOs that provide mobile money services are financial institutions for the purposes of the MLPC Act. 130 Furthermore, all financial service providers are supposed to implement and periodically review their AML and CTF measures. 131 In line with the risk assessment procedures, prospective financial service providers should submit detailed money laundering and terrorist financing risk assessment and mitigation strategies when they apply for registration. 132 These measures seek to ensure that mobile money and other financial tools operate within the rules in order to promote financial inclusion for the poor without compromising the integrity of the financial markets in Zimbabwe.

Selected flaws in the regulation of mobile money services in Zimbabwe
The possible confusion around mobile money regulation in Zimbabwe is more about non-bank institutions that provide financial services rather than the services themselves. 133 When mobile money was initiated in Zimbabwe it was not a deposit-taking service, but ongoing innovations have made the taking of deposits one of the functions that mobile money is discharging. 134 The expansion of mobile money services allows the poor and unbanked persons in Zimbabwe to save money in their mobile accounts. However, this creates competition for banks that may not be ready to yield deposit-taking functions to non-banking institutions. non-bank mobile money service providers to keep their clients' deposits in a trust account opened at a commercial bank that is subject to prudential regulation. 135 This could be a way to stifle the growth of financial innovations and the use of innovative technology in order to maintain the hegemony of banks. This approach is impeding financial inclusion. One major weakness of the new mobile banking regulations in Zimbabwe is their apparent one-sided focus on the financial aspects of mobile money, that leaves out the telecommunications regulatory aspects of mobile money. 136 It is submitted that innovations in ICTs are likely to continue to occur and may modifying financial products in a bid to increase the financial inclusion of the poor, the unbanked and low-income earners.

The Postal and Telecommunications Act, mobile money and financial inclusion in Zimbabwe
The telecommunications sector is regulated under the Postal and Telecommunications Act. 137 The Postal and Telecommunications Regulatory Authority of Zimbabwe (Potraz) supervises the telecommunications sector. While Potraz has a broad mandate, the financial business ventures of MNOs fall outside its scope. 138 However, the Postal and Telecommunications Act provides for, monitors and supervises the rollout of cellular communication services in Zimbabwe. 139 It further promotes and encourages the growth of technology, which is the key to innovation in the ICT sector. 140 In this regard, MNOs have invested in innovative technology 141 resulting in mobile money services that are provided to millions of the poor, unbanked and low-income earners in Zimbabwe to promote their financial inclusion. Greenacre argues that mobile money is growing in terms of its reach and importance to the poor and that there is a need to streamline the telecommunications and financial regulation of mobile money in developing countries such as 135 Zimbabwe. 142 It is submitted that both telecommunications and financial services regulation are equally important in the effective regulation of mobile money services in Zimbabwe. Therefore, innovative technology must be carefully utilised to promote financial inclusion for the poor and low-income earners. 143

The reliance on mobile money services during the corona virus (COVID-19) pandemic in Zimbabwe
Mobile money services have become a convenient payment channel for many persons, especially frontline workers dealing with the COVID-19 pandemic in remote areas, who cannot easily access banking services in many affected countries, including Zimbabwe. 144 Crises such as the COVID-19 pandemic tend to leave the poor and unbanked persons in a more precarious position in terms of their financial wellbeing compared to their banked counterparts. 145 The COVID-19 crisis came at a time when developing nations such as Zimbabwe were experiencing an unprecedented use of innovative financial products in their financial markets. 146 The exponential adoption of mobile phone technology has amply provided the poor and unbanked persons with cheap, affordable and safe mobile money services in Zimbabwe. 147 The COVID-19 pandemic has shown that innovative technology can serve communities better in times of crisis. For instance, cashless modes of transaction like mobile money are safer and more convenient, particularly for the poor and unbanked, owing to the fear that the COVID-19 virus could survive on paper and get transmitted when people exchange money. 148 In response to the COVID-19 virus, there has been a marked increase in many countries, including Zimbabwe, in the number of retail outlets that decline 142 cash payments in preference for contactless electronic money to combat the spread of the COVID-19 virus. 149 Consequently, mobile money has become a convenient tool to provide safe transactions while allowing the banked and unbanked to participate in the financial services sector in Zimbabwe. The relative safety of mobile money in the COVID-19 pandemic period adds to the growing importance of innovative technology to promote the financial inclusion of the poor, unbanked and low-income earners in Zimbabwe.

Concluding remarks
Innovative technologies and advancements in ICTs have transformed mobile phones from mere communication devices into powerful financial tools that are contributing to the financial inclusion of the poor, unbanked and low income earners in Zimbabwe. Mobile phones are hosting financial platforms such as Ecocash, Onemoney and Telecel either as software on the SIM card or as applications that can be downloaded and installed on the mobile phones in order to access financial services in Zimbabwe. Ecocash, Onemoney and Telecash are providing cheap, convenient, safe and fast financial services to the poor, unbanked and low-income earners who cannot afford the cost of opening and maintaining bank accounts in Zimbabwe. Mobile money services have also become a safe and convenient mode of payment during the COVID-19 pandemic for both the banked and the unbanked in many countries, including Zimbabwe. The payment of frontline workers dealing with the COVID-19 pandemic via mobile money in areas far from banking facilities allows such workers to receive their salaries in a convenient and safe manner that minimises the transmission of the COVID-19 in Zimbabwe. Furthermore, the poor, unbanked and low-income earners who usually rely on cash can also access their funds and COVID-19-related relief payments through mobile money.
However, the financial regulatory framework in Zimbabwe does not adequately regulate mobile money services to promote the financial inclusion of the poor, unbanked and low-income earners. The Banking Act, the NPS Act, the RBZ Act, the MLPC Act and the Postal and Telecommunications Act are insufficient and do not robustly regulate mobile money services. The NFIS and the mobile banking regulations published in 2020 have some positive aspects on the adoption of 149 Mann "Driver for Contactless Payments" 177-178; Ozili 2020 http://dx.doi.org/10.2139/ssrn.3585662 1-9.