Should agent exclusivity be permitted?

Agent exclusivity focuses on the ability of a customer of one provider to use the agent of another provider for cash-in and cash-out services related to that customer’s account. In several countries, e-money providers with significant market power initially established and enforced exclusivity agreements with agents. These agreements made it difficult for later entrants to compete on a level playing field.



Arguments for Permitting Agent Exclusivity

Exclusivity may encourage investment

First-movers spend significant resources identifying, training, and monitoring agents. To incentivize agent network development, they should be permitted to recoup these expenses without allowing competitors to free-ride on their investment in agent identification and training.

Exclusivity may not impact competition

Exclusive agents may not the only potential agents, so effective competition often is still possible.

Arguments for Prohibiting Agent Exclusivity

Exclusivity may favor first-movers

In countries where first-movers have significant market power, exclusivity agreements may make it difficult for later entrants to compete on a level playing field.

Exclusivity may be particularly harmful in rural areas

In some areas (particularly rural areas), there may be few entities that are able to meet the requirements to serve effectively as an agent.



  • As market structures and incentives vary, the merits and risks of agent exclusivity policies will need to be evaluated in the particular country context.
  • While every country is different and should be evaluated independently, in most cases the risk to effective competition from permitting agent exclusivity is likely to outweigh the risk that prohibiting agent exclusivity would discourage investment in agent infrastructure.
  • In countries where agent exclusivity is prohibited, regulators may need to monitor the market for signs of possible agent coercion, such as high rates of “voluntary” agent exclusivity, particularly with respect to agents of a market leader or other large EMI.

Country Examples

Country Examples

Link to Zimbabwe case studies
Link to Kenya case studies
Link to Uganda case studies