목차
Title page 1
Contents 5
Acknowledgements 4
Executive Summary 6
1. Mobile payment services landscape 8
1.1. Types of mobile payments and the technology that enables them 8
1.2. Payments sector infrastructure 10
1.3. Mobile payment providers and service models 12
1.4. Opportunities for competition and innovation 16
2. Competition risks 18
2.1. Structural Risks - Barriers to entry and expansion 18
2.1.1. Characteristics of mobile payments and the role of data asymmetries 18
2.1.2. Regulation as a potential direct barrier to entry and expansion 20
2.1.3. Lack of access to or interoperability of key technological infrastructures as a potential indirect barrier to entry and expansion 22
2.2. Behavioural Risks - Exclusionary practices 25
2.2.1. Foreclosure or raising rivals' costs 25
2.2.2. Tying, bundling, leveraging, self-preferencing 27
2.2.3. Most favoured nation clauses and anti-steering provisions 28
2.3. Interdependencies between new entrants and incumbents 29
2.4. Considerations for merger enforcement 31
3. Potential pro-competitive initiatives 33
3.1. Open banking, data portability, and interoperability 33
3.1.1. Design of technical standards and harmonisation of APIs 34
3.1.2. Reciprocal data access considerations for open banking 39
3.2. Asymmetric digital market regulations 40
3.3. Open and interoperable retail-level alternative payment rails 42
3.3.1. National payment switches 42
3.3.2. Fast payment systems (FPS) 42
4. Conclusion 45
Endnotes 47
References 56
Tables 5
Table 1. BigTech and large FinTech licenses across jurisdictions 29
Figures 5
Figure 1. Examples of types of mobile payments, channels, and underlying technology 10
Figure 2. Representation of a bank-centric model and retail-level payment rail 11
Figure 3. Representation of an independent non-bank-centric retail-level payment rail 12
Boxes 5
Box 1. Examples of mobile payment service models and adoption 14
Box 2. Regulatory lessons from Nigeria and Ghana 21
Box 3. Examples of enforcement and policy interventions promoting horizontal interoperability 23
Box 4. Examples of enforcement and regulation over access to Apple's NFC and API functionality 26
Box 5. Experiences in merger enforcement across jurisdictions underscore its importance 31
Box 6. The EU's Payment Services Directive and its evolution: PSD1-PSD3 35
Box 7. Examples of open banking, data portability, and interoperability experiences across jurisdictions 37
Box 8. The EU's Digital Markets Act 41
Box 9. Examples of alternative mobile retail-level payment rails 43
