Page 176 - ITU-T Focus Group Digital Financial Services – Technology, innovation and competition

ITU-T Focus Group Digital Financial Services
Technology, Innovation and Competition

In terms of market behaviours, regulators, competition authorities and some market participants may find the
following behavior problematic from a competition perspective:

• Outright or unreasonable restrictions on or inordinate delays in access to scarce infrastructure, channels
and services such as unstructured supplementary service data (USSD), shortcodes, and payment
switches.
16
• Bundling of services, or ability to provide scarce incentives, that create unfair competition.
• Collusive or unfair pricing of services for USSD, STK, and switching and interchange fees in payments
switches.
• Lack of, or restricted, ability to participate in industry-led governance structures relating to infrastructure
or services.
• Deliberate or unreasonable lack of QOS guarantees.

• Inability to, or unreasonable restrictions on, access to big data suites.
Market participants may believe that the following regulatory and policy approaches could affect their ability
to compete on a level playing field, as summarized in Exhibit 1. 17
• restrictions on licensing/market access and unequal unequal licensing provisions;

• asymmetric compliance requirements such as for agent know your customer (KYC), and cash handling
and physical security;

• unequal tax treatment;
• unequal treatment of capital requirements required for licensing;
• forced or mandated pricing caps for channel access;

• bans on agent exclusivity.

16 In scenarios where an entity controls the entire vertical chain of (scarce) access, this may result in ‘refusal to supply’ behavior.
17 Depending on the behaviour, market participants outline in Exhibit 1 may be the cause or recipient of the behavior.

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