How to Implement
Guidance
Protect end user needs.
The design of an Inclusive IPS should encourage adoption of digital payment by providing affordability, usefulness and convenience. To this end, the Scheme rules should ensure that end users’ data is secure, that they have the ability to easily lodge a complaint or dispute to their DFSP about a transaction, including the ability to report a fraudulent transaction — all within the user interface provided. The Scheme should also require that DFSPs undertake fraud mitigation as specified in the rules.
Provide clarity on responsibilities.
The Scheme should define and articulate all aspects of Scheme roles and responsibilities so that DFSPs fully understand the expectations placed upon them. DFSPs should have a full view of how they will be treated within the Scheme. Rules that are formulated with DFSP needs and their inputs taken into consideration are more likely to be fulfilled and not require modification.
Adopt favorable FX rates.
Foreign exchange rates are advantageous for the end user. Scheme rules should require that DFSPs that provide foreign exchange should select and apply the rate that is most beneficial to the value of the transaction.
Encourage participatory rulemaking.
Scheme rules for cross-border payments are developed in a consultative, inclusive manner. All participants should be afforded opportunities to comment on all aspects of Scheme design and governance.
Identify broad set of stakeholders.
Formal Scheme governance includes representation from key roles in the Inclusive IPS, including the Scheme, Platform, DFSPs, and other supporting roles, while Scheme rules impact and are influenced by a broader set of stakeholders. Notably, end users are the ultimate beneficiary of the Inclusive IPS and regulators and policymakers influence the Scheme through laws, regulations, and supervision. The Scheme should identify the full set of stakeholders that are part of the IPS ecosystem, understand their role, and put in place appropriate mechanisms (formal or informal) to engage with each stakeholder or representative associations.
Why It Matters
Thoughtful, unambiguous wording of the Scheme rules ensures clarity on requirements and also minimizes potential misunderstandings between the Scheme itself and participants, which can be detrimental to Scheme performance and reputation.
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Women’s Inclusion
Formalization of the Scheme rules in a Scheme Rulebook document is a critical step in ensuring participants’ and all roles in the Scheme are committed to inclusivity. Rules that are intended to broaden Women’s Inclusion require this level of formalization.
Cross-Border
Scheme rules formalize inclusive design aspects in all cases, domestic and cross-border, and thus are a primary mechanism for supporting design that leads to convenience, usefulness and affordability for end users. When done in a consultative manner with key stakeholders cross jurisdictions, they are more likely to achieve buy in and support. Further, without Scheme rules driving DFSPs to adopt favorable FX rates, end users are likely to suffer from lack of affordability.
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