Page 56 - ITU-T Focus Group Digital Financial Services – Consumer Experience and Protection

ITU-T Focus Group Digital Financial Services
Consumer Experience and Protection

are indeed representative of the challenges consumers are encountering in their respective markets. If they
are encountering these challenges, the recommendations detailed in the report will be a useful starting point
for revamping the DFS landscape.
In addition to the contract specific concerns highlighted above, an examination of the country legal frameworks
revealed that in some instances, laws/regulations might need greater specificity in order to ensure that
consumers are better protected. It was observed that in instances where providers may not be directly flouting
laws or regulations, the existing provisions as framed have the net effect of causing consumer harm. For
example, with regard to provisions requiring transparency of fees and charges: Often the law will state that
providers need to make consumers aware of the fees prior to signing on to contracts or purchasing services,
but the provisions do not specially require that this should be stipulated in the user agreement itself. As such,
a provider may technically be complying, as they make this information available in another location (on their
website for instance), but customers may not be able to access these sources, especially those who do not
have access to the Internet. This means that they are not informed of the associated charges at the point
where they accept contract terms and conditions.

Overall, in order to ensure improved consumer experience as they navigate the DFS landscape, we need to
have:

• User agreements that are consumer friendly in terms of language, length of contracts, and transparency
of provisions.
• Greater scrutiny by regulators of these provider agreements. They might look at how providers word
their obligations to ensure that consumers are not facing undue burdens and they might also generally
analyse agreements to ensure key areas of consumer protection are captured in the agreement.
• Legislative amendments, as required, to improve protection for DFS consumers.

• Consumer education and awareness to help them understand their legal rights and how to navigate
redress when those rights are violated.

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