Page 29 - ITU-T Focus Group Digital Financial Services – Recommendations

ITU-T Focus Group Digital Financial Services
Recommendations

Title of recommendation Telecommunication infrastructure access & governance
Working Group Interoperability

Audience for recommendation Authorities, Telecommunication infrastructure providers

Telecommunication infrastructure providers should not restrict access to their telecommunication services,
impact service quality and/or discriminate among DFS providers. Telecommunication infrastructure providers
should commit to creating an open and level playing field for the provision of DFS.

In some markets it has been observed that certain mobile network operators that are also DFS providers
have restricted access to the mobile telecommunications network that they themselves operate and
which is used by other DFS providers. Although different from restricting access to payment infrastructures,
restricting access to the mobile telecommunications network is likely to have similar overall effects in terms
of limiting interoperability and competition in the market place.

Telecommunication providers that compete with other DFS providers, but also own key communications
infrastructure required to provide these DFS, might not only deny other providers access, they can also
provide access at a high price and/or with poor quality affecting the customer experience, trust, and effective
price. Telecommunication providers offering DFS should be able to prove that there is no discrimination among
own DFS those offered by other DFS providers upon request by the telecommunication and/or financial
regulator.
Telecommunication infrastructure providers, especially those who are also providing DFS, should
commit to create an open and level playing field for the provision of DFS services. In this context, where
telecommunication infrastructure providers or their subsidiaries are permitted to provide DFS, access to the
telecommunications channel should be provided on a competitive, commercially viable basis.

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