Page 24 - ITU-T Focus Group Digital Financial Services – Recommendations

ITU-T Focus Group Digital Financial Services
Recommendations

Title of recommendation Interoperability scheme access and governance
Working Group Interoperability

Audience for recommendation Authorities, DFS providers

Access criteria for interoperability schemes should be clear, objective, publicly disclosed and allow for new par-
ticipants, banks and authorized/regulated non-banks, to join. Equal representation of participants (irrespective
of market size) in the scheme governance is encouraged. The governance process should foresee effective dis-
pute resolution and the orderly exit of scheme participants without unreasonably disrupting the interoperability
scheme, and an appeal mechanism.

Governance should ensure whether a decision to establish an interoperability arrangement appropriately
reflects the objectives and interests of the relevant stakeholders and, if so, how. Market participants involved
in an arrangement should preferably implement formalized mechanisms for sharing relevant information with
the relevant stakeholders and consult them when needed.

Access criteria to interoperability arrangements should ensure a level playing field among market participants.
If market participants are foreclosed or inhibited from joining existing interoperability arrangements, the result
may be substantial inefficiencies that limit growth and/or reduces the benefits for end users. Access criteria
should be justified in terms of the safety and efficiency of the system, as well as the broader financial markets.
From a risk mitigation perspective, the access criteria should aim at minimizing legal, financial and operational
risks. Participating market participants in an interoperability arrangement have the requisite operational
capacity, financial resources, legal foundation and risk-management expertise so that risks are adequately
mitigated and managed. From an efficiency viewpoint, the access criteria may be based on the business case.
The access criteria should have the least restrictive impact on access that circumstances permit.
Access criteria should be commensurate with the risks generated by interoperability and those to which
participating market participants may be exposed. If access to interoperable systems is refused by the system
owners or operators to an applicant market participant, the reasons should be explained to the applicant in
writing on the basis of the access criteria adopted.

When access criteria constitute terms and conditions for maintaining interoperability, they have to be
continuously applied. Market participants should monitor compliance with participation requirements
on an ongoing basis through the receipt of timely and accurate information. If conditions for maintaining
interoperability are no longer met, rules and procedures should be legally set either for the termination of
the non-compliant market participant or for dismantling an interoperability agreement depending on the
extent of the problem.

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