One Financial Decision. Four Regulated Products. Does Regulating the Parts Tell Us Enough About the Whole?
When One Financial Decision Becomes Four Regulated Products
A woman walks into a shop in Accra to buy a new smartphone. She does not have enough cash to pay for it outright, so the salesperson shows her an instalment option on the phone. She enters a few details, agrees to make monthly payments and pays the first amount from her mobile-money wallet. Device insurance may be bundled into the offer, and future payments can be collected digitally.
As far as she is concerned, she has done one thing: bought a phone and agreed to pay for it over time.
The regulatory system may see something quite different. There is a retail purchase. There may be a regulated credit product. There may be an insurance policy. There is a payment arrangement. Data from one part of that relationship may be used to determine what she can access in another.
That distinction is becoming increasingly important in African financial services.
This is no longer a marginal digital-finance question. Sub-Saharan African account ownership reached 58% of adults in 2024, up from 49% in 2021, with mobile-money use in the region the highest in the world. (World Bank) Globally, mobile money processed more than $2 trillion in 2025, and most of the growth in new registered and active accounts came from Sub-Saharan Africa. More importantly for this discussion, mobile money is increasingly a gateway to other financial services: credit remains the most widely offered adjacent service, savings is close behind, and the number of mobile-money providers offering insurance increased by a third in 2025. (GSMA)
Africa has spent the last decade making finance easier to access. We should celebrate that.
But there is a regulatory question sitting inside that success.
What happens when financial services become easier to combine than they are to regulate as a combination?
The Consumer Makes One Decision. Regulation May See Four.
Consider a market trader who receives most of her business payments through mobile money.
Her transaction history provides evidence of how her business performs. That can make it possible for a lender to offer her short-term working capital without requiring the kind of fixed collateral she may not have. Repayment can be deducted from incoming payments. Insurance could potentially be attached to the financed stock or loan.
She does not think: Today I am entering a payments relationship, creating alternative data for a credit assessment, establishing an automated repayment mechanism and purchasing an insurance product.
She thinks: I need money to buy stock.
That difference matters because convenience is increasingly being created by collapsing several financial decisions into one commercial decision.
Ghana gives us a sense of the scale at which this can matter. In December 2025 alone, mobile-money transactions reached approximately GHS518.4 billion across 982 million transactions, according to the Bank of Ghana. (Bank of Ghana) This is no longer simply another payment channel sitting at the edge of the financial system. Digital transaction environments increasingly provide the infrastructure through which other financial services can be offered.
Now imagine a ride-hailing driver.
The platform knows approximately how much he earns through it. A financial institution can use that income history to offer vehicle finance. Motor insurance can sit alongside the financing. Repayments can be connected to the income generated from driving.
Again, the driver is not shopping for three regulated financial products.
He is trying to answer a much simpler question:
Can I get a car and earn enough from it to make the monthly payment?
Or imagine a family seeing an online offer that says:
“Drive this car for GHS X per month.”
Behind that one number could sit vehicle finance, motor insurance, a payment mandate and perhaps tracking or other services required as conditions of the finance.
Every institution involved could potentially comply perfectly with the rules governing its individual product.
The lender can disclose the interest and repayment terms.
The insurer can provide the appropriate insurance documentation.
The payment provider can obtain a valid mandate.
The platform can comply with its obligations.
Four green ticks.
And yet there is still a question worth asking:
Does four compliant financial products necessarily produce one well-governed financial proposition?
I am not convinced that the answer is automatically yes.
Product Compliance Is Not Necessarily Proposition Governance
This is the distinction I think African regulators increasingly need to examine.
Product compliance asks whether the loan, insurance policy, payment service or investment product satisfies the rules governing that financial activity.
Proposition governance asks what those products become when they are deliberately connected and presented to the market as one convenient financial decision.
Take the car example.
The lender may correctly disclose the cost of credit and the insurer may correctly disclose the insurance premium. But does the consumer clearly understand the total economic commitment represented by “GHS X per month”?
Which components are compulsory?
Which can be cancelled?
What happens to the finance if the insurance ends?
What happens if the payment mandate is cancelled?
If the consumer has a complaint about the amount being deducted each month, should she know whether to call the marketplace, lender, insurer or payment provider?
These are not theoretical questions about regulatory turf. They are questions created by the design of the proposition itself.
There is another dimension.
Suppose our market trader’s payment history is what makes her eligible for affordable working capital. That can be a very positive development. Across Africa, one of the great promises of digital finance is precisely that businesses previously difficult for formal financial institutions to understand can begin to establish a usable economic history through their transactions.
But what happens when she wants to move her payments elsewhere?
Can she take that financial history with her?
Does leaving the payment environment also weaken her access to credit?
If repayment is automatically deducted from incoming payments, what happens when those payments stop flowing through that platform?
The issue is not whether using transaction data for lending is inherently problematic. Quite the opposite: it could significantly widen access to finance.
The regulatory question is whether we sufficiently understand the dependencies being created between individually regulated products.
That is harder to answer from inside a single regulatory silo.
Every Regulator Can Be Doing Its Job
This is perhaps the part of the problem that should concern African financial regulators most.
There does not need to be a regulatory failure for a gap to emerge.
The central bank can supervise the lender and payment provider correctly. The insurance regulator can supervise the insurer correctly. The securities regulator can supervise an investment product correctly. The data-protection regulator can enforce the rules governing personal information.
Everybody can be doing their job.
The problem is that the economic proposition does not necessarily respect the boundaries between their mandates.
Suppose a mobile-money environment allows someone to receive income, make payments, save, borrow and buy insurance. Different regulated institutions may sit behind those services. The GSMA’s latest data show exactly this broadening of mobile money beyond payments, with credit, savings and insurance increasingly sitting alongside the wallet. (GSMA)
The consumer experiences one financial environment.
Regulation sees several financial activities.
That leads to a question more difficult than the familiar call for regulators to “collaborate”.
What exactly should they collaborate to see?
If the answer is simply exchanging information about their respective regulated institutions, we may still be looking at the same proposition vertically.
Perhaps the more important questions sit between the products.
When does information generated in one financial relationship legitimately determine access to another?
When does making several products dependent upon one another create a risk that no individual product regulator naturally sees?
When a consumer buys what appears to be one proposition, who is accountable for ensuring that its total cost and consequences are understandable?
When one component fails, who has examined what happens to the others?
And perhaps most importantly: at what point does a combination become significant enough that somebody should examine the combination itself?
These are harder questions than determining which licence applies.
Central Banks Have a Particularly Difficult Position
Central banks sit in an interesting place in this transition.
Across Africa, they have spent years enabling digital payments, interoperability, fintech participation and financial inclusion. That work has produced extraordinary results. More than one billion registered mobile-money accounts were already in Sub-Saharan Africa by 2024, twice the number in 2020. (GSMA)
The next stage of digital finance is increasingly about what can be built on top of that access.
Payments become a gateway to credit.
Transaction history becomes useful for financial decision-making.
Wallets connect to savings and insurance.
APIs make it easier for institutions to assemble products provided by other institutions.
Merchant platforms become financial distribution channels.
That is exactly the kind of innovation African financial systems should want. The continent still has enormous gaps in access to credit, insurance, savings and investment. Making financial products easier and cheaper to distribute is part of closing them.
The objective cannot therefore be to put all the institutional seams back into the consumer experience.
A Ghanaian trader should not have to understand the architecture connecting a bank, fintech, insurer and mobile-money provider simply to obtain working capital.
But the easier we make it for her not to see those seams, the more important it becomes for regulators to see them clearly.
That may require central banks and their fellow regulators to work through some uncomfortable choices.
Should there be a point at which a multi-product financial proposition is looked at as a whole rather than only through its components?
If so, what triggers that scrutiny: customer numbers, value, the number of products involved, the degree of data integration, or the extent to which one product affects another?
Should one institution have explicit responsibility for the overall proposition even where several regulated providers sit behind it?
What should the consumer be told: the terms of four separate products, or also the total financial commitment and the consequences of how those products interact?
And when a proposition crosses the mandates of a central bank, insurance regulator, securities regulator and data regulator, what information does each need in order to understand the whole without unnecessarily duplicating the work of the others?
I do not think those questions lead automatically to a new regulator, a new licence or even a new set of regulations.
Different African markets will probably arrive at different answers. Their existing institutional structures, legislation and financial markets are too different for a single model to be assumed.
But there is a question that should probably come before choosing the regulatory solution.
What is the thing we are now trying to regulate?
If the answer remains simply “the loan”, “the insurance policy” or “the payment”, we may miss an important part of what technology is changing.
The innovation is increasingly not only inside those products.
It is in the way they are being put together.
Africa’s digital-finance story has been extraordinarily successful at making the boundaries between financial services matter less to the people using them. The latest GSMA figures show an industry that has moved far beyond simple person-to-person transfers: merchant payments alone grew by almost half to $155 billion globally in 2025, while adjacent credit, savings and insurance services continued to expand. (GSMA)
That evolution should continue.
But it leaves African central banks and financial regulators with a question worth resolving before the combinations become considerably more complex:
If a consumer increasingly makes one financial decision while our regulatory system sees three or four separately regulated products, who is responsible for understanding the decision as a whole?
Because every individual product can comply with the rules.
Every regulator can do its job.
And we can still discover, too late, that nobody was looking at what we created when we put all the pieces together.