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ITU-T Focus Group Digital Financial Services
Consumer Experience and Protection
2.4 Complaints handling
2.4.1 In-house dispute resolution
Recourse mechanisms can build consumer trust in the system if they operate efficiently and respond to
consumer concerns and problems (Chapman & Mazer 2013). From the contract review, provider contracts
described an in-house dispute resolution mechanism in only 39 per cent of the agreements. This means that
for the most part, customers will not know how to go about resolving disputes. As a result, customers may
unnecessarily accept loses or burden government agencies with complaints that could have been resolved
more efficiently and promptly directly with the provider.
See Box 5 for an example of contract clauses related to complaints handling which may not adhere to the legal
and regulatory requirements in Uganda and Nigeria.
Figure 8: In-house dispute resolution
Box 5: Complaints handling
Uganda Mobile Money Regulations
Under Section 12(d) Complaints handling and consumer recourse, mobile money service providers
shall ensure that appropriate and effective procedures for receiving, considering and responding to
complaints are put in place. The complaints handling procedure shall ensure that:
(iii) A dedicated toll free telephone line for complaint resolution is provided;
Nigeria, Consumer Protection Framework:
2.7.1 Complaints Channels - Financial institutions shall have multiple channels (including electronic and
non-electronic channels) for consumers to lodge complaints. Examples of complaints channels may
include provision of dedicated email addresses, telephone numbers, help desk, web chat etc. Such
channels shall be toll-free, easily accessible and available to consumers or their agents at all times.
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