In September 2024, the United Nation’s DPI Safeguards Initiative released its Universal DPI Safeguards Framework version 1.0. This framework was the result of a multi-stakeholder process that collected lessons learned from existing implementations and sought to “ensure DPI implementations mitigate risks at both the individual and societal level, advance the UN’s Sustainable Development Goals and foster trust and equity across all countries,” according to the Safeguards Initiative website.
The Mojaloop Foundation applauds this initiative and recommends that all DPI projects follow these guidelines. We also believe that the Mojaloop platform already aligns with the principless recommended in the framework. This alignment stems from the Mojaloop Foundation’s mission of building an equitable and inclusive financial system and the principles we use towards that objective, such as the Level One Principles and the Principles for Financial Market Infrastructure (PFMI) from the World Bank and the Bank of International Settlement. While these are excellent starting points, what excites us about the new Safeguards Framework is that it takes inclusion principles to the next level, applying them to a broader range of DPI types, not just financial ones.
What follows are the nine foundational principles and nine operational principles quoted from the Safeguards Framework whitepaper, followed by a brief explanation of how Mojaloop upholds the standards.
The full report is a worthwhile read for anyone involved in DPI or financial inclusion. It outlines the risks to safety and inclusion for individuals as well as the structural vulnerabilities that are risks to societies that the Framework is designed to address.
How Mojaloop Addresses the 9 Foundational Principles
These foundational principles are the building blocks for safe and inclusive DPI.
“F1. Do No Harm
Harms to individuals may not be immediately obvious. A human rights-based framework should be integrated throughout the DPI life cycle to anticipate, assess, and effectively mitigate any potential human rights harms and power differentials.”
How Mojaloop addresses this principle: Mojaloop was designed specifically to protect citizens’ privacy through the cryptographic lock on its transaction flow. More importantly, it was designed to ensure that small community financial institutions are included on equal terms with large urban institutions. These community institutions are more responsive to rural, lower-income communities. Digitizing payments leads to an increase in deposits and therefore an increase in investment, but if only large urban financial institutions hold these deposits, then the power differential grows. The capital flows away from rural communities.
“F2. Do Not Discriminate
All individuals, regardless of intersecting identities, should have unbiased access and equal opportunity. Risks due to the circumstances of all vulnerable communities, historically marginalized groups and those who opt-out should be mitigated.”
How Mojaloop addresses this principle: Creating an equal playing field for all financial institutions and fintechs, big and small, provides the best opportunity to ensure that if groups are discriminated against by some institutions or business models, another will be able to serve them in a cost-effective way.
“F3. Do Not Exclude
All individuals should have a choice of channels (digital/non-digital) to access and benefit from services enabled by DPI based on their individual capacity and resources. Access should not be limiting, conditional or mandatory — explicitly or in practice.”
How Mojaloop addresses this principle: The choice of channel is crucial for citizens, particularly in government benefit programs. Citizens should not be required to open a special account with a different provider simply because a particular government agency or NGO selects a specific mobile money provider. With a Mojaloop-enabled IIPS, a citizen can access services from their existing account. Additionally, Mojaloop is designed to serve feature phone (USSD) and agent-enabled transactions equally with smartphone enabled transactions.
“F4. Reinforce Transparency and Accountability
DPI should be developed with democratic participation, have public oversight, promote fair market competition and avoid vendor lock-in. All partnerships should be transparent, accountable and publicly governed.”
How Mojaloop addresses this principle: Mojaloop supports the ability of adopters to create an open and inclusive scheme development process in which the scheme and the technology are built side by side. This approach not only increases the transparency and accountability of the process but also promotes greater participation. More importantly, Mojaloop was designed so that end users have full visibility of all fees and terms prior to approving a transaction.
“F5. Uphold the Rule of Law
DPI should be introduced with a clear legal basis, with required legal and regulatory aspects embedded into its design, supported with capacity for sector specific tailoring (such as health), implementation, oversight and regulation by law.”
How Mojaloop addresses this principle: The Mojaloop Foundation works with central banks and designated licensed hub operators, and we have built our community to share not only IT experience but also regulatory experience. The platform was designed to connect all types of licensed and regulated financial institutions.
“F6. Promote Autonomy and Agency
Ensure that everyone (especially indigenous communities with sui generis rights), on their own or with assistance, can take control of their data, promote their agency, exercise choice, and contribute to their society’s well-being.”
How Mojaloop addresses this principle: Mojaloop was built so that countries can control their own national digital payment infrastructure without dependencies on foreign vendors, foreign countries, and foreign debt. We train domestic technology experts to support the payment system and build products that are responsive to local needs.
“F7. Foster Community Engagement
All stages of the DPI life cycle should centre on the needs and interests of individuals and communities at risk. They should participate at critical junctures and provide feedback actively in an environment of transparency and trust.”
How Mojaloop addresses this principle: Mojaloop encourages a participatory approach to building a payment system that brings in feedback from PSPs and community organizations. As an open-source platform, Mojaloop enables continuous, cost-effective, and citizen-centered iterations that a proprietary foreign solution cannot offer.
“F8. Ensure Effective Remedy and Redress
Complaint response and redress mechanisms, avenues for appeal without reprisal, supported by robust administrative and judicial review, should be accessible to all in a transparent and equitable manner during service delivery.”
How Mojaloop addresses this principle: The Mojaloop Foundation and its community regularly engage in discussions about best practices in redress and remedy, and the platform is designed to make implementing redress mechanisms easy, even for small financial institutions.
“F9. Focus on Future Sustainability
Inculcating foresight is key to anticipating and limiting long term and inter-generational harms. For example, mitigating the environmental impact with a net-zero strategy or minimizing resource needs with reuse of software.”
How Mojaloop addresses this principle: Local ownership and maintenance mean avoiding costly trips for foreign vendor employees for in-person meetings, and a lower cost and lower footprint overall, in addition to avoiding the inter-generational value extraction risks that come from large multinational monopolistic behavior. The Mojaloop platform was built to be incredibly lightweight, meaning fewer resources to run and operate.
How Mojaloop Addresses the Nine Operational Principles
The operational principles drive continuous trust and adaptation.
“1. Leverage Market Dynamics
DPI should foster an increasingly inclusive environment for public and private innovation such that market players can compete and introduce diverse equitable solutions that cater to emerging needs of all people across the society.”
How Mojaloop addresses this principle: Mojaloop supports the growth of local fintech ecosystems through its open-source codebase, which prevents vendor lock-in. Our expanding community offers diverse options for vendor procurement and provides training for additional local system implementers (who are engaged in building a national payments hub) via the Mojaloop Accelerator program, which pairs new local implementers with seasoned experts.
“2. Evolve with Evidence
Independent, transparent, and continuous assessments, due diligence, or audits should engage with people, understand concerns, review evidence and rapidly cease or initiate activities that contain heightened risks or harms.”
How Mojaloop addresses this principle: Our active Community meets several times a year to discuss new features and plan the path forward for future releases. Between meetings, our robust Community governance model helps members engage in an ongoing structure and unstructured dialogue to ensure the best product possible.
“3. Ensure Data Privacy by Design
DPI should embed legal, regulatory and technical principles that enforce core privacy principles (e.g., data minimization, provisions to delink, ability to limit observability) and legal safeguards should be enacted around them.”
How Mojaloop addresses this principle: The Mojaloop platform was built to be a “light hub”, optimizing for data minimalization while allowing individual Mojaloop implementations to be built to follow local regulations by payment solutions companies. Mojaloop can be deployed in the cloud, on-premises or hybrid to ensure that data is stored in-country.
“4. Assure Data Security by Design
DPI should incorporate and continually upgrade security measures, such as encryption or pseudonymization, to protect personal data. A legal framework should fill the gaps where technical design may be insufficient for data security.”
How Mojaloop addresses this principle: Mojaloop’s unique transaction protocol allows for a secure transaction with no PII passing through the hub. Mojaloop employs several full-time technical leaders who are responsible for ensuring that the latest security approaches are in use. National or international regulators are able to ensure that their desired requirements are met for the individual implementation.
“5. Ensure Data Protection During Use
Personal data should be processed or retained lawfully and transparently only by authorized personnel within a legal framework including transaction history, data subject rights and protections against overreaching requests.”
How Mojaloop addresses this principle: Mojaloop was designed to minimize the data collected in the process of each transaction and works with identity and data exchange DPI builders to ensure financial data is owned by the citizen.
“6. Respond to Gender, Ability or Age
Not all individuals experience DPI in the same way, and some continue to face barriers and challenges related to access or use. DPI implementation should not exacerbate existing challenges or introduce new barriers and inequalities.”
How Mojaloop addresses this principle: Most payment systems focus on urban middle class banked customers first, widening the digital divide. Mojaloop-based hubs can be used by anyone with a feature phone and are designed to enable, not just allow, all types of financial service providers to be part of a loop. This enables national payment systems that are low- or no-cost for end users and that can be connected to services like mobile wallets, and accounts for SACCOs, MFIs, or banks of any size.
“7. Practise Inclusive Governance
Long-term effectiveness of DPI is contingent upon the establishment of a robust legal, regulatory and institutional framework that should promote transparent and participatory multi-stakeholder governance focused on safety and inclusion.”
How Mojaloop addresses this principle: The Mojaloop Community governs the development of the Mojaloop platform and follows the product development roadmap that enables an expanding set of use cases. Annual elections ensure that Mojaloop’s development is governed by a representational council. Individual Mojaloop instances are overseen by hub operators and, where needed, any fintech hired to build or expand the system. The Mojaloop Foundation supports central banks and national hub operators to create inclusive, participatory design processes.
“8. Sustain Financial Viability
As DPI are a public infrastructure, diversified, phased and sustainable financing models should be established. Governments can lead during the build phase and local digital partners or the private sector can lead on operations and maintenance.”
How Mojaloop addresses this principle: Designed to enable low- or no-cost payment systems, Mojaloop is available to use free of charge. Our free training program takes developers, managers, and regulators through the particulars of how Mojaloop works, and our Accelerator Program can be used to help qualifying local IT companies lead national payment system projects.
“9. Build and Share Open Assets
DPI should share and reuse open protocols, specifications, digital public goods (DPGs), and the associated knowledge. This enhances flexibility and assures that proprietary systems do not limit the ability to improve safety and inclusion.”
How Mojaloop addresses this principle: As a digital public good verified by the Digital Public Goods Alliance, the Mojaloop open-source platform is maintained and upgraded by its active Community, and that is available under the Apache-2.0 open license.
A Great Move Forward for Payments DPI
When hub operators and central banks issue RFPs for payment systems, they should prioritize the inclusion and verification of compliance with the Safeguards Framework. Donors, such as development banks funding digital public infrastructure, should mandate these principles as a condition for funding.
