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




mobile money, mobile money services, financial inclusion, unbanked persons, regulation


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.


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Author Biography

Howard Chitimira, Faculty of Law at the North-West University

Senior Lecturer

North-West University           




Ahmad HA, Green C and Jiang F "Mobile Money, Financial Inclusion and Development: A Review with Reference to African Experience" 2020 Journal of Economic Surveys 753-792

Alexandre C and Eisenhart L "Mobile Money as an Engine of Financial Inclusion and Lynchpin of Financial Integrity" 2013 Wash J L Tech & Arts 285-302

Ali A "Beyond Traditional Microfinance: Financial Inclusion for Unbanked Kenyans" 2016 Int J Soc Sci Stud 74-85

Andrianaivo M and Kpodar K ICT, Financial Inclusion and Growth Evidence from African Countries (International Monetary Fund Washington DC 2011)

Arner DW, Berberis J and Buckley RP "Fintech, Regtech and the Reconceptualisation of Financial Regulation" 2016 Nw J Int'l L & Bus 1-51

Bara A "Mobile Money for Financial Inclusion: Policy and Regulatory Perspective in Zimbabwe" 2013 AJSTID 345-354

Barruetabeña E "Impact of New Technologies on Financial Inclusion" 2020 Economic Bulletin, Banco de España 1-14

Bećirović S, Bajramović D and Ahmatović A "The Role of Mobile Banking in Enhancing Economic Development" in International Conference: Communication and Business Sector (June 2011 Berane) 89-98

Buckley RP et al "Sustainability, FinTech and Financial Inclusion" 2019 EBOR 7-35

Buckley R, Greenacre J and Malady L "The Regulation of Mobile Money in Malawi" 2015 Wash U Global Stud L Rev 435-498

Buku MW and Meredith MW "Safaricom and M-PESA in Kenya: Financial Inclusion and Financial Integrity" 2013 Wash J L Tech & Arts 375-400

Chatain PL et al Protecting Mobile Money against Financial Crimes: Global Policy Challenges and Solutions (World Bank Washington DC 2011)

Chibango C "Mobile Money Revolution: An Opportunity for Financial Inclusion in Africa" 2014 IJHSS 59-67

Chinakidzwa, Mbengo and Nyatsambo 2015 IJSER

Chinakidzwa M, Mbengo P and Nyatsambo M "Mobile Money Usage in Rural Areas of Zimbabwe: Case of Mudzi District" 2015 IJSER 128-141

Chitimira H "The Reliance on Artificial Intelligence Measures to Curb Money Laundering Practices in South Africa Banking Institutions and Real Estate Sector" 2020 Acta Universitatis Danubius Juridica 28-43

Chitimira H and Ncube M "The Role of Regulatory Bodies and Other Role-Players in the Promotion of Financial Inclusion in South Africa" 2020 Acta Universitatis Danubius Juridica 24-37

Chitokwindo S, Mago S and Hofisi C "Financial Inclusion in Zimbabwe: A Contextual Overview" 2014 MJSS 415-423

Chopra S and Sherry AM "Architecture of a Low Cost Technology Solution Integrating Mobile Financial Services with AADHAAR Authentication to Accelerate Financial Inclusion in India" 2014 OIDA International Journal of Sustainable Development 27-34

De Koker L "The 2012 Revisited FATF Recommendations: Assessing and Mitigating Mobile Money Integrity Risks within the New Standards Framework" 2013 Wash J L Tech & Arts 165-196

De Koker L, Morris N and Jaffer S "Regulating Financial Services in an Era of Technological Disruption" 2019 Law in Context 1-22

Dube T et al "Adoption and Use of SMS/Mobile Banking Services in Zimbabwe: An Exploratory Study" 2011 JIBC 1-15

Fonte E "US Regulatory Overview of Mobile Wallets and Mobile Payments" 2017 Wake Forest J Bus & Intell Prop L 549-608

Gibson E, Lupo-Pasini F and Buckley RP "Regulating Digital Financial Services Agents in Developing Countries to Promote Financial Inclusion" 2015 Sing JLS 26-45

Goldby M "Reporting of Suspicious Activity by Mobile Money Service Providers in Accordance with International Standards: How Does It Impact on Financial Inclusion?" 2013 Wash J L Tech & Arts 401-418

Greenacre J Regulating Mobile Money: A Functional Approach (Pathways for Prosperity Commission Oxford 2018)

Harris A, Goodman S and Traynor P "Privacy and Security Concerns Associated with Mobile Money Applications in Africa" 2013 Wash J L Tech & Arts 245-264

Hughes N and Lonie S "M-PESA: Mobile Money for the 'Unbanked' Turning Cellphones into 24-Hour Tellers in Kenya" 2007 Innovations 63-81

Jones E, Woods N and Ndung'u N Consolidating Africa's Mobile Banking Revolution (Global Economic Governance Programme Oxford 2016)

Kendall J and Voorhies R "The Mobile-Finance Revolution: How Cell Phones Can Spur Development" 2014 Foreign Affairs 9-13

Kernan AB "Sustaining the Growth of Mobile Money Services in Developing Nations: Lessons from Overregulation in the United States" 2018 Vanderbilt J Transnat'l L 1109-1151

Kersop M and Du Toit S "Anti-Money Laundering Regulations and the Effective Use of Mobile Money in South Africa - Part 1" 2015 PELJ 1602-1635

Kong Y, Tampuri Jnr MY and Opoku BP "Digital Financial Inclusion: The Star Strategy Approach to Policy Formulation" 2018 IJMSBR 120-129

Kufandirimbwa O et al "Mobile Money in Zimbabwe: Integrating Mobile Infrastructure and Processes to Organisational Infrastructure and Processes" 2013 Online Journal of Social Sciences Research 92-110

Lashitew AA, Van Tulder R and Liasse Y "Mobile Phones for Financial Inclusion: What Explains the Diffusion of Mobile Money Innovations?" 2019 Research Policy 1201-1215

Lawack VA "Mobile Money, Financial Inclusion and Financial Integrity: The South African Case" 2013 Wash J L Tech & Arts 317-346

Louis L and Chartier F "Financial Inclusion in South Africa" 2017 Journal of Comparative Urban Law and Policy 170-186

Lowry C "What's in your Mobile Wallet: An Analysis of Trends in Mobile Money Payments and Regulation" 2016 Fed Comm LJ 353-384

Lumsden E "The Future is Mobile: Financial Inclusion and Technological Innovation in the Emerging World" 2018 Stan J L Bus & Fin 1-44

Mago S and Chitokwindo S "The Impact of Mobile Banking on Financial Inclusion in Zimbabwe: A Case for Masvingo Province" 2014 MJSS 221-230

Mann RJ "Driver for Contactless Payments" in Pistor K (ed) Law in the Time of COVID-19 (Columbia Law School New York 2020) 175-182

Masiyandima N, Mlambo K and Nyarota S "Financial Inclusion and Quality of Livelihood in Zimbabwe" in Africagrowth Institute 14th African Finance Journal Conference (17-18 May 2017 Victoria Falls) 1-38

Masocha R and Dzomonda O "Adoption of Mobile Money Services and the Performance of Small and Medium Enterprises in Zimbabwe" 2018 AAFSJ 1-11

Mavhiki S, Nyamwanza T and Shumba T "Impact of Mobile Banking on Traditional Banking Practices in Zimbabwe" 2015 IJECM 1-13

Mazambani l, Rushwaya TJ and Mutambara E "Financial Inclusion: Disrupted Liquidity and Redundancy of Mobile Money Agents in Zimbabwe" 2018 Investment Management and Financial Innovations 131-142

Mbengo P and Phiri MA "Mobile Banking Adoption: A Rural Zimbabwean Marketing Perspective" 2015 Corporate Ownership and Control 195-204

Mugarura N "The Use of Mobile Phones in Changing the Banking Regulatory Landscape in Africa" 2019 AJICL 308-331

Munongo S and Bizah DS "Mobile Money Users' Challenges: Evidence from Developing Countries" 2017 IJER 77-88

Munyoro G et al "The Significance of Mobile Money Transfer Facility to Zimbabwean Economy: A Case Study of EcoCash" 2017 IMPACT: IJRBM 1-20

Ngwenya B, Pelser T and Chivaura T "Perceptions of Post-Multicurrency Regime Financial Inclusion Confidence Challenges in Zimbabwe" 2018 SAJEMS 1-15

Ozili PK "Optimal Financial Inclusion" 2020 IFR 1-18

Phiri and Muponda 2016 University of Zimbabwe Business Review Phiri C and Muponda G "Public Confidence and Its Impact on the Performance and Stability of Banks in Zimbabwe" 2016 University of Zimbabwe Business Review 1-14

Robb G and Vilakazi T "Mobile Payment Markets in Kenya, Tanzania and Zimbabwe: A Comprehensive Study of Competitive Dynamics and Outcomes" 2016 AJIC 9-37

Sulieman DM and Salleh F "Anti-Money Laundering Risk Posed by Mobile Money Services in Sub-Saharan Africa" 2020 Journal of Critical Reviews 568-571

Wayne T et al "Technologies for Financial Inclusion in Nigeria" 2020 Research Agenda Working Papers 40-56

Winn JK "Mobile Payments and Financial Inclusion: Kenya, Brazil and India as Case Studies" 2016 Social Sciences Research Network Electronic Journal 1-26

Winn JK and De Koker L "Introduction to Mobile Money in Developing Countries: Financial Inclusion and Integrity Conference Special Issue" 2013 Wash J L Tech & Arts 155-164


Banking Act [Chapter 24:20] 9 of 1999

Banking (Money Transmission, Mobile Banking and Mobile Money Interoperability) Regulations, 2020 [Chapter 24:20]

Deposit Protection Corporation Act [Chapter 24:29] 9 of 2011

Money Laundering and Proceeds of Crime Act [Chapter 9:24] 4 of 2013

National Payment Systems Act [Chapter 24:23] 21 of 2001

Postal and Telecommunications Act [Chapter 12:05] 4 of 2000

Reserve Bank of Zimbabwe Act [Chapter 22:15] 5 of 1999

Internet sources

Bayona‐Rodríguez H, Rodríguez C and Melo JS 2017 Financial Inclusion of the Poor and Money Laundering Indicators: Empirical Evidence for Colombia accessed 14 June 2021

Brenton P and Chemutai V 2020 Trade Responses to the COVID-19 Crisis in Africa

handle/10986/33548/Trade-Responses-to-the-COVID-19-Crisis-in-Africa.pdf?sequence=1 accessed 14 June 2921

Burns S 2015 Mobile Money and Financial Development: The Case of M-Pesa in Kenya accessed 14 June 2021

Dittus P and Klein M 2011 On Harnessing the Potential of Financial Inclusion: The Case of "Mobile Payments" – BIS Working Papers No 347 accessed 15 June 2021

Fernandes N 2020 Economic Effects of Coronavirus Outbreak (COVID-19) on the World Economy - IESE Business School Working Paper No WP-1240-E accessed 15 June 2021

Gas SA 2017 Mobile Money, Cashless Society and Financial Inclusion: Case Study on Somalia and Kenya accessed 15 June 2021

Jenik I, Kerse M and De Koker L 2020 Rapid Account Opening in a Pandemic: How to Meet AML/CFT Rules for Social Assistance Payments accessed 15 June 2021

Klein M and Mayer C 2011 Mobile Banking and Financial Inclusion: The Regulatory Lessons - Frankfurt School of Finance and Management Working Paper Series 166

/48654/1/664524133.pdf accessed 15 June 2021

Levin P 2013 Big Ambition Meets Effective Execution: How EcoCash is Altering Zimbabwe's Financial Landscape

mobilefordevelopment/wp-content/uploads/2013/07/EcoCash-Zimbabwe.pdf accessed 15 June 2021

Lyman T et al 2019 Beyond KYC Utilities: Collaborative Customer Due Diligence for Financial Inclusion – Working Paper accessed 15 June 2021

Malady L and Buckley R 2014 The Regulation of Mobile Money in Emerging Markets: State of Play


april_2014.pdf accessed 15 June 2021

Ozili PK 2020 Financial Inclusion and Fintech during COVID-19 Crisis: Policy Solutions accessed 15 June 2021

Postal and Telecommunications Regulatory Authority of Zimbabwe 2020 Abridged Postal and Telecommunications Sector Performance Report First Quarter 2020 accessed 16 July 2020

Remolina N 2019 Open Banking: Regulatory Challenges for a New Form of Financial Intermediation in a Data-Driven World - SMU Centre for AI and Data Governance Research Paper No 2019/05 accessed 15 June 2021

RBZ 2016


RBZ 2017

Reserve Bank of Zimbabwe 2017 Guidelines for Retail Payments Systems and Instruments accessed 20 June 2021



How to Cite

Chitimira, H., & Torerai, E. (2021). The Nexus between Mobile Money Regulation, Innovative Technology and the Promotion of Financial Inclusion in Zimbabwe. Potchefstroom Electronic Law Journal, 24, 1–33.



Special Edition: Corporate and Financial Markets 2021

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