Interoperability was introduced to promote seamless financial transactions between different payment platforms and institutions. Its primary purpose is to remove barriers between mobile wallets and bank accounts, thereby enhancing convenience, encouraging digital transactions, and advancing financial inclusion. Charging customers an additional fee merely to move their own funds from one account they own (MoMo wallet) to another account they own (bank account) undermines this very objective.

From a policy and consumer protection perspective, the fee appears irrational for several reasons:

1. Customers Are Transferring Their Own Funds

A MoMo-to-bank transfer is not a commercial exchange between two independent parties. It is fundamentally a movement of a customer’s own money from one personal financial channel to another. Imposing a fee on account interoperability effectively penalizes customers for accessing or managing their own funds across integrated financial systems.

• Interoperability Was Meant to Reduce Friction, Not Create New Costs

Digital interoperability frameworks are designed to encourage convenience, efficiency, and integration within the financial sector. Introducing transaction charges at the point of interoperability creates unnecessary friction and contradicts the original policy rationale behind integrated digital finance systems.

• Double Monetisation of Existing Customers

Telecommunications companies and financial institutions already benefit commercially from customers through transaction charges, float balances, service subscriptions, data usage, and account maintenance structures. Adding another layer of charges on internal fund movement risks being perceived as excessive monetization of customers who are already paying for financial services.

• Potential Setback to Financial Inclusion Goals

In economies where mobile money serves as the primary banking gateway for many citizens, especially small traders, rural populations, and informal sector participants, additional transfer costs may discourage formal financial participation. Customers may revert to cash handling, thereby weakening national digitalization and cashless economy objectives.

• Interoperability Infrastructure Is a Shared National Financial Utility

The interoperability ecosystem is often supported by national payment infrastructure, regulatory coordination, and public policy initiatives aimed at improving economic efficiency. Customers should therefore experience interoperability as a public convenience, not as a premium service attracting punitive costs.

• Disincentive to Savings and Banking Integration

Encouraging movement of funds from wallets into bank accounts should ordinarily support savings mobilization, investment, and financial deepening. Penalizing such transfers may discourage users from integrating with the formal banking sector, contrary to broader economic development objectives.

• Risk of Eroding Consumer Trust

Digital finance thrives on simplicity, affordability, and trust. When customers perceive charges as unreasonable or exploitative, confidence in digital financial systems may decline, affecting adoption and long-term ecosystem growth.

• Investment gains not equitably shared between operators and customers.

Considering the substantial financial benefits derived by operators from customer deposits held within the Mobile Money ecosystem, it is important to critically examine the equity and transparency surrounding the distribution of such earnings to customers.

Mobile Money operators generate significant value from the aggregate balances maintained by customers through the placement of these funds with banking institutions and through various treasury and investment arrangements. These pooled customer deposits constitute a major source of liquidity and financial leverage for operators and their partner institutions, enabling considerable returns from interest-bearing instruments and treasury operations.

However, a fundamental concern arises regarding the proportion of these financial gains that is ultimately shared with the customers whose deposits form the basis of such earnings. In practice, customers often receive only marginal interest accruals credited periodically to their Mobile Money wallets—amounts that appear disproportionately insignificant when compared to the substantial treasury and investment income generated from the utilization of customer-held funds.

This disparity raises legitimate questions about fairness, transparency, and equitable participation in the value created through the deployment of customer deposits. Where operators continue to realize considerable returns from the financial intermediation of customer balances, the imposition of additional interoperability charges on customers for transferring their own funds further compounds concerns regarding excessive monetization within the digital financial ecosystem.

In essence, customers not only provide the liquidity base upon which operators earn substantial treasury-related income, but are also subsequently subjected to transaction fees for accessing or moving their own funds across interoperable financial platforms. Such a framework risks undermining consumer confidence and may be perceived as inconsistent with the broader objectives of financial inclusion, affordability, and customer-centered digital finance.

In conclusion, charging customers for transferring money between their own interoperable accounts defeats the spirit of financial integration and creates an unnecessary financial burden on users. Rather than imposing additional costs, stakeholders within the digital finance ecosystem should focus on expanding accessibility, reducing transaction barriers, and strengthening customer confidence in interoperable financial services.