Branchless banking spreads quickly in developing countries. Information and communication technologies (ICT) and non-bank retail channels such as post offices provide access to finance to many people. This paper presents a short list of key topics and recommendations for a proportionate regulatory policy in this sector.

Necessary but not sufficient preconditions for steady and safe growth are:

• authorisation of retail agents equipped with ICT as principal customer interface
• development of risk-based anti-money laundering rules and rules for combating the financing of terrorism adapted to branchless banking

Branchless banking’s sustainability as a means of providing financial services to poor people will furthermore depend on regulatory measures such as:

• the permission for non-bank retail outlets to serve as agents
• carefully defined restrictions
• the creation of a regulatory category for electronically stored value
• a clarification of the legal boundaries between retail payments, e-money and other stored-value instruments and bank deposits
• effective consumer protection
• inclusive regulation and effective oversight of payment systems
• good governance of competition among providers

Policy should urgently consider gaps in regulation and use proportionality as a guiding principle. Co-ordination between authorities and other interested players has to be facilitated.