September 23rd, 2025

For consumers and small businesses, financial data is a key enabler of access to new opportunities such as business investment or financing of key household needs like housing, education, and consumption. But too often this data remains siloed across different financial service providers (FSPs), with limited ability for consumers and businesses to share this data with other competing FSPs. Open finance is a new model for financial ecosystems which seeks to break down these data siloes across financial institutions. At the center of this is consumer control over their data—in open finance consumers can direct participating financial service providers to make their financial information available to other financial service providers, and unlike most current models this is not dependent on the data holder being willing to do so.

Kenya has some of the highest potential for open finance in Africa, with 84.8% of adults having access to formal financial accounts (FinAccess 2024), interoperable and fast digital payments, and a diverse digital finance sector of banks, mobile money operators and fintechs. Kenya’s digital financial sector consistently ranks in the top three African markets for fintech startups and has successfully developed shared solutions such as open APIs and remote identify confirmation through mobile phone subscriptions that could provide key infrastructure for open finance. Recent policy efforts such as Digital Credit Providers Regulations and the planned Fast Payments System show an interest in policy innovations to increase quality of digital finance and improve policy oversight.

Open finance could be the next stage in market development for Kenya’s financial sector, increasing competition and consumer choice in key sectors such as mobile money and digital credit, which currently have high levels of market concentration. This report summarizes initial industry consultations on the potential, challenges, and requirements to implement open finance in Kenya. The primary sources of data collection were individual interviews, a survey distributed to stakeholders in the financial sector, an industry webinar “Navigating open finance in Kenya,” and an Open Finance Industry Workshop held on March 19, 2025. A report validation session was also convened on July 10, 2025. The session brought together stakeholders to review the draft findings and provide additional input prior to finalisation.

These consultations surfaced several common insights regarding industry’s views on open finance, which are summarized as follows:

1. Kenya’s financial sector is supportive of open finance. From banks to mobile network operators (MNOs) to fintechs and beyond, Kenya’s financial service providers see opportunities that open finance will provide in their ability to serve Kenyans’ needs. Industry actors were encouraged by the potential for open finance to positively impact key sectors of the economy such as micro, small and medium enterprises (MSMEs) and agriculture value chains, which are currently underserved.
2. Current data sharing arrangements are limited. The work that industry has done to build shared infrastructure in know-your-customer (KYC) verification, payments data, and embedded finance in Kenya provides a solid foundation on which to build open finance. However, even those participating in existing interoperable data and transaction systems were clear current arrangements are limited due to being primarily bilateral, lacking standardisation, and have numerous inefficiencies that open finance could address.
3. A core set of financial sector data could catalyse open finance. Four data types were commonly viewed as most essential for open finance, and should be included in the first wave of open finance: Identity and KYC data to improve account registration; Deposit accounts at commercial banks (phasing in deposit-taking microfinance institutions (DTMIs) and SACCOS eventually); Payments and mobile money accounts to expand access to digital data on Kenyans’ cash flows; Credit data, connecting existing credit bureau data with new lender data.
4. Data protection and data security is the most important risk to manage in open finance. Industry actors were concerned about the risks of data breaches and unauthorized data usage in open finance, as well as current regulatory ambiguities related to the Data Protection Act, which have in some cases prevented firms from sharing data that could benefit financial consumers. Open finance could help to clean up current ambiguities and enhance the standards for data security through clearer and more comprehensive rules as well as centralized oversight.
5. A partially mandated approach is favoured over a voluntary approach. The majority of industry respondents felt that the government needs to lead with a strong policy mandate to compel open finance and make sure it is fair and open. At the same time, most respondents felt that implementation should be through a shared governing body of policymakers and industry, with industry leveraging much of their existing expertise in data exchanges and embedded finance solutions to build open finance solutions.

Open finance will form a key component of Kenya’s emerging data economy and should therefore be aligned with broader data governance frameworks. Industry stakeholders emphasized that open finance should not be treated in isolation but rather as a segment within the broader data economy. Open finance policies, infrastructure, and governance must therefore be aligned with national data economy strategies to ensure coherence, interoperability, and sustainability. This includes harmonizing open finance with frameworks governing data governance, digital identity, data portability, and consumer data rights. Doing so will help unlock synergies between sectors, foster innovation beyond financial services, and ensure that open finance contributes to a more inclusive and efficient digital economy.

The first and second insights speak to the current reality and anticipated potential of open finance. Participants were optimistic that standardized, comprehensive financial information for bank, payments, and fintech customers would address current constraints on financial service quality, such as: Lack of access to a diversity of products; High costs for financial services; and lack of utility for consumers’ needs.

The third insight, regarding key data types to include, is where the impact of open finance starts to take shape. It was not difficult for industry stakeholders to imagine numerous ways that standardized, real-time (or near real-time), comprehensive financial information for bank, payments, and fintech customers would lead to financial innovation. Some of the possible innovations and benefits mentioned by participants are listed in Figure 1 below. These innovations would address constraints on financial service quality, such as: Lack of access to a diversity of products; High costs for financial services; and lack of utility for consumers’ needs. The exact types of innovations that will emerge will depend on consumer needs and provider ingenuity, but the potential benefits open finance’s data exchange could bring for firms and consumers is clear.

The fourth and fifth insights, on security and policy model, indicate industry desires policymakers to play a strong leadership role in open finance development and implementation. Respondents generally preferred policymakers to set and enforce clear standards on participation, establish rules for data security, and monitor and enforce compliance and performance quality. This did not mean industry would play a passive role in open finance development. Stakeholders generally preferred establishing councils or dedicated entities that were led by policymakers but had formal participation of industry representatives in the governance, setting of standards, implementation and performance monitoring.  To achieve this governance model, industry stakeholders believed that Central Bank of Kenya (CBK) and other policymakers would have to increase their technical capacities, expand their oversight functions, and improve their approach to industry engagement.

Industry’s appetite and commitment to open finance is strong and increasing, and the benefits of open finance in Kenya are considerable. Industry associations will continue to engage their members to develop more specific perspectives on key topics like data types, participation, governance, and data security. In the meantime, policymakers can begin to explore open finance frameworks that will ensure data sharing is fair, transparent, and center’s consumers in the design of Kenya’s open finance ecosystem.

Click here for the full Unlocking open finance in Kenya: Opportunities for Kenya’s financial sector report.

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