From data to SupTech: A phased approach for smarter regulatory transformation

The volume of data worldwide is exploding. The IDC projects that by 2025, all the world’s data will reach a volume of 175 zettabytes or 175 billion terabytes, which would make manual supervisory processes untenable. This data comprises information stored in data centers, mobile towers, branch offices, PCs, smartphones, and IoT devices, and is collectively referred to as the datasphere.  

Today, regulators struggle to keep pace with the speed of financial data. The growing volume and complexity of data require more than manual processes. They demand robust and adaptable systems that enable smarter supervision. MSC’s Data Maturity Framework seen below provides a structured roadmap to help regulators progress from basic data collection to integrated, data-driven supervisory systems, enhancing risk detection, operational efficiency, and preparedness for future regulatory challenges. As discussed in our previous blog, SupTech begins with the creation of strong and flexible data foundations, which is a crucial first step in the effective implementation of supervisory technology. 

Foundations of a good data system  

Robust data systems are essential for effective SupTech, as they enable timely collection, secure storage, and seamless integration of high-quality data needed for proactive, risk-based supervision. Structured data supports advanced analytics, while sound governance and cybersecurity ensure compliance and protection against threats. We can evaluate the effectiveness of a good data system across multiple stages, as seen below, each of which is vital to enable scalable and intelligent SupTech deployment. 

Before we discuss the three main dimensions of data collection, standardization, and storage, we must understand that some basic pillars span every phase of the data life cycle. Data granularity, data governance, and data security and privacy are not discrete phases, but ongoing facilitators that form the foundation of how well data is gathered, processed, managed, and consumed. Granularity ensures data is detailed enough for risk-based supervision without being overwhelming. Governance frameworks provide transparent guidelines for acquisition, validation, and responsible sharing, which promotes consistency and accountability. 

Also crucial is for stakeholders to ensure data privacy and security at all maturity levels. Since supervisory data typically contains sensitive financial and consumer-level information, cybersecurity, encryption, and privacy-by-design must be present from start to finish. Regulators at all stages must ensure that these standards are met to avoid breaches, maintain confidentiality, and uphold trust. These cross-cutting foundations work in parallel with technical pillars to define the long-term effect of each SupTech endeavor. 

If institutions intend to implement SupTech effectively, they must first assess their data maturity on these pillars, identify gaps where they exist, and align their solution with both their current and future needs. 

Data collection 

As financial sector supervisors evolve from basic to intermediate and advanced data collection systems, their capabilities must keep pace. At the basic level, data is submitted by regulated entities to regulators manually via tools, such as Google Forms or MS Excel over email, which requires minimal IT skills and basic protection, such as antivirus software and password controls. 

At the intermediate level, supervisors have been adopting structured digital reporting through bulk-upload web portals and traditional APIs. The Bank of Ghana implemented its ORASS platform to enable API-based reporting, as reported publicly by the central bank, while NAMFISA, Namibia’s nonbank regulator, uses its statutory ERS web portal for regulated entities. Separately, the Bank of Namibia operates its own reporting arrangements and announced an automated regulatory reporting system in 2023. These require skilled IT staff and safeguards, such as the implementation of HTTPS (to ensure secure, encrypted communications), API gateways, and audit logs. 

At the advanced level, supervisors use real-time APIs, streaming tools, such as Apache Kafka, AI and NLP platforms, such as spaCy or Amazon Comprehend, and middleware, such as MuleSoft and Apache NiFi for integration across systems. For example, the Bangko Sentral ng Pilipinas implemented a real-time API solution to improve data submission. These setups demand strong cybersecurity and legal frameworks for consent, provenance, and live supervisory oversight. 

Data standardization

Through MSC’s extensive work with several central banks, including projects in Africa and Asia, we have observed that the adoption of data standardization tools and automated validation aligns with international best practices and accelerates SupTech maturity. At the basic level, reporting relies on MS Excel templates, manual validation via macros, and email submissions, primarily supported by spreadsheet analysts and IT staff. 

In the intermediate stage, regulators shift to structured formats, such as XML or XBRL, and use schema validators and submission portals to streamline reporting. For example, the Central Bank of Ireland’s ONR platform enables firms to upload XBRL files directly, which improves accuracy and efficiency by involving schema experts and governance teams. 

At the advanced level, institutions deploy automated validation engines, NLP pipelines for unstructured document analysis (e.g. parsing audit reports), and global standards, such as ISO 20022, which have found increasing use in cross-border payment reporting frameworks. German Bundesbank’s NLP-based prospectus parser automates the interpretation of PDF documents with more than 90% accuracy.  

Institutions have also adopted the legal entity identifier (LEI) system maintained by GLEIF, alongside ISO 20022, to ensure clear entity identification in global reporting. The Bank of England mandates the inclusion of the LEI in FI-to-FI payments through its CHAPS high-value payments system, effective 1st May 2025, as publicly announced by the Bank of England. 

These advanced processes demand a skilled blend of NLP engineers, regulatory data analysts, and compliance technologists to take full advantage of automation, standards, and data intelligence in regulatory oversight. 

Data storage  

At the basic level, data is stored locally, on USB drives, shared network drives, or on-site servers, which are managed by basic IT staff and protected by simple file encryption, restricted physical access, and regular backups. These setups are low-cost but have limited resilience. 

At the intermediate level, supervisors use secure transfer protocols, such as HTTPS, SFTP, and FTPS, alongside cloud storage platforms, such as AWS S3 or Azure Blob Storage, typically managed by specialized IT teams. Institutions have been increasingly adopting cloud storage for better resilience. For example, the Bank of England has been expanding cloud usage, while the Reserve Bank of India plans to launch IFS Cloud for regulated entities.  

However, as adoption grows, central banks are concerned about the risks of storing sensitive supervisory or financial data outside national borders, particularly regarding data sovereignty, privacy, regulatory compliance, and resilience. Such concerns are significant, especially against the emergence of new technologies, such as Central Bank Digital Currencies. Many are now exploring sovereign or locally managed cloud options to address these issues. 

While many organizations are transitioning, there is no publicly available evidence confirming that any institution has completed full-scale supervisory data migration. This mirrors earlier blog: Global cloud usage remains relatively low overall. Yet, many regulators are entering the intermediate maturity phase where secure, partial cloud adoption is becoming common. This phase involves moderate costs and requires compliance with advanced security measures, such as encryption-at-rest, identifying Access Monitoring (IAM) policies, audit trails, firewalls, and Multifactor Authentication (MFA). 

At the advanced level, organizations deploy data lakes and warehouses, supported by cataloguing tools, such as AWS Glue or Azure Purview for real-time data sync. This infrastructure, maintained by cloud architects and metadata specialists, supports enterprise-scale analytics and governance. For instance, Banco de España manages more than 850 TB of regulatory data and performs thousands of analytical queries each week for robust, AI-ready supervision. 

The growing adoption of SupTech highlights that despite significant upfront costs, the long-term benefits in resilience, scalability, and regulatory capability far outweigh initial investments. Institutions preparing for SupTech upgrades must prioritize needs assessments, gap analysis, stakeholder consultations, cost-benefit analysis, and strategic planning to ensure successful transformation. 

How digital tax reforms can transform Nigeria’s revenue challenges into fiscal successes

Nigeria has vast developmental needs which are held back by its equally vast but untapped human, natural, and fiscal potentials. The federal government spends an average of $220 per citizen per year, one of the lowest levels of government expenditure among developing countries. In 2024, Nigeria’s total expenditure was 18.1% of GDP, well below the sub-Saharan Africa average of 22.86%. This underinvestment has direct consequences for its population: a child born in Nigeria today is expected to achieve only 36% of his or her potential productivity due to poor access to quality education and healthcare services.

Low public spending in the country is linked to its constrained revenue base and fragmented system of revenue collection. Adequate revenues allow countries to fund healthcare, education, infrastructure, and social safety nets while maintaining resilience against deficits and global shocks. A narrow fiscal space undermines these goals.

Similarly, although e-governance, including digital public infrastructure (DPI), is becoming a cornerstone of modern public administration, the government faces challenges in digitising public financial management (PFM), particularly at the sub-national level.

Progress in these areas can strengthen revenue mobilisation if leveraged effectively.

The digital opportunity in public financial management

Nigeria has made significant progress in digital public infrastructure, starting with a robust national ID system. As of June 2025, 121 million people out of a total population of 238 million were enrolled in its National Identification Number (NIN) database. This scale of digital ID registration can help expand digital service delivery, where it lags behind peers such as South Africa, Ghana, and Senegal, in the UN e-Government Development Index, including in areas like online service delivery, connectivity, and human capacity, which are conditions that foster revenue mobilisation.

The country’s tax-to-GDP ratio has remained mulishly below 10%, far short of the African average of 16%. By comparison, South Africa’s ratio stands at 26%, Ghana’s at 13%, and Kenya’s at 15%. According to the World Bank, a threshold of 15% or higher is critical for sustaining growth and reducing poverty. This underperformance leaves the government fraught with recurring oversized fiscal deficits. The government’s 2020 National Integrated Infrastructure Master Plan flagged persistent funding gaps in the energy and transport sectors. Low revenues also create macro-fiscal vulnerabilities, such as dependence on foreign exchange and rising public debts. To understand why revenue collection remains so low, it is necessary to examine the country’s direct and indirect taxation systems.

Challenges in direct and indirect taxation

Nigeria’s low tax revenue is beset by underlying impediments in direct taxation, such as low tax morale1, widespread exemptions, and a fragmented tax system. Low trust in government, perceived corruption, multiple overlapping taxes, and poorly coordinated collection agencies all dampen tax compliance. At the same time, generous incentives such as tax holidays, allowances, and exemptions continue to erode the tax base, estimated at USD 4.6 billion (≈4% of GDP) in 2021. Personal income and corporate tax collections are among the lowest in Sub-Saharan Africa at just 6–7% of GDP.

The government has made incremental gains in indirect taxation, particularly through value-added tax (VAT). Centrally collected VAT revenue has grown from 10% to 30% of total revenue despite a relatively low VAT rate of 7.5%, about half the Sub-Saharan African average of 15%. With streamlined rates, VAT could become a dependable revenue source. Yet, without addressing economic, institutional and administrative barriers, such large-scale gains will be far-fetched.

Beyond rates and exemptions, the structure of tax administration itself poses challenges. The fragmented responsibilities of federal and sub-national bodies weaken enforcement. Limited institutional capacity, fragile taxpayer databases, and governance challenges impede progress. The situation is compounded by a large informal economy, which accounts for over 90% of employment, much of which operates outside the tax net. Invariably, a promising revenue mobilisation strategy should be part of a broader development strategy for the country.

Nigeria’s tax system is structured under a federal framework. Revenue collection responsibilities are divided among the federal, state, and local governments. The Federal Inland Revenue Service (FIRS) administers major national taxes, such as the company income tax and petroleum profit tax, while the Nigeria Customs Service collects customs and excise duties. The State Internal Revenue Services (SIRS) collect taxes such as personal income tax at the state level. These are calculated using the pay-as-you earn (PAYE) method and direct assessment. SIRS also collect capital gains tax for individuals and business premises levies. Local governments collect market fees, tenement rates, and licensing fees for small business operators.

Centrally, the Joint Tax Board (JTB), a cross-government tax body, has collaborated with the FIRS to develop the national taxpayer identification number (TIN) system. However, many tax administration processes, especially at the sub-national level, are still partially digitised. These processes rely heavily on manual and siloed data handling, which undermine accuracy, efficiency, and transparency.

The following are the main challenges in Nigeria’s taxation process:

Fragmented digital systems: Revenue authorities lack a unified, interconnected digital infrastructure. This leads to data silos and fragmented services. Fragmentation prevents seamless information sharing and coordination as authorities expend extra resources to identify taxpayers and enforce compliance.

Manual approval and verification of tax calculation: Manual processes to approve and verify digital IDs and payment receipts, among others, result in delays, errors, and administrative burdens for revenue authorities.

Lack of standardisation and data observability: Tax collection is opaque, and receipts are not standardised. The process involves discretionary assessments or waivers, while online portals or public notice boards are underutilised. This erodes public trust and discourages voluntary compliance.

Varied levels of automation: Revenue authorities have different automation levels, whichcontribute to inconsistent and inaccurate tax collection. These differences lead to poor data management, sharing, and reporting across states.

Non-standardised taxpayer identification number (TIN) generation: Authorities generate and manage TINs inconsistently. This creates duplicate TIN records and limits the accuracy of taxpayer profiles.

Variations in level and type of digital financial inclusion: Low digital financial inclusion limits Nigeria’s revenue potential. Many adults still lack formal financial access, which leads to cash based, informal transactions. This creates haphazard audit trails and complicates effective taxation.

Emerging reform effort to strengthen revenue mobilisation

The Nigerian government has started implementing reforms to strengthen the tax system. The country seeks to boost its tax-to-GDP ratio to 18% by 2026. In July 2023, President Bola Ahmed Tinubu inaugurated a Fiscal Policy and Tax Reform Committee, which has introduced measures to increase the tax-to-GDP ratio, including a set of legislative reforms that will transform the operating environment at both the federal and sub-national levels. The committee also seeks to modernise revenue administration and combat leakages using technology and data intelligence.

On 26 June 2025, four (4) Tax Reform Bills were signed into law by the President, including the Nigeria Tax Act (NTA), the Nigeria Tax Administration Act (NTAA), the Nigeria Revenue Service Act (NRSA) and the Joint Revenue Board Act (JRBA). These changes have been regarded as one of the most comprehensive tax reforms in Nigeria’s history.

The country requires technological advancements, alongside a parallel digital drive at the state level, to achieve the ambitious tax target by 2026. In June 2024, the Nigeria Governors’ Forum (NGF) entered into a partnership with MSC (MicroSave Consulting) under NGF’s Digital Domestic Resource Mobilisation (DDRM) initiative to help states adopt digital public infrastructure (DPI) or DPI-based digital tools as a pathway to digital tax reforms.

The initiative assessed the 36 Nigerian states on their digital maturity, digital PFM ecosystem, and the readiness of their revenue administration systems to adopt digital tax reforms. The assessment was informed by four principles of Digital Public Financial Management: a single source of truth, just-in-time strategy, observability, and de-monopolising access to public resources.

States used an Intelligent Revenue Authority (IRA) index to understand the extent of their revenue systems’ digital readiness. The index is informed by MSC’s in-house smart payments tool, which is designed to reduce friction in payment processing and administrative burden for governments. A complementary Digital Public Infrastructure (DPI) Index was also designed to assess their enabling environment (policy, skills and infrastructure availability), foundational building blocks (digital IDs, payment and data sharing systems), and delivery of public services (service platforms and sector initiatives).

The results provide the first comprehensive analysis of the digital capacity and readiness of the 36 states and the Federal Capital Territory (FCT), their maturity levels (low, medium, or high), and actions to advance and meet their revenue goals.

Customised roadmaps were also developed and distributed to the states through multi-stakeholder dialogues with their IT ministries, revenue authorities and governors. States have been advised to adopt context-specific digital tools that are secure, scalable and interoperable.

This blog was first published on “Nigeria Governor’ Forum” on 4th November 2025.

SupTech starts with data: Building strong and flexible data foundations

“Regulator blames lack of timely data reporting for recent multi-million-dollar losses in the banking sector.”  

This stark headline on HSBC’s GBP-57.4 million fine reveals an unpalatable reality: Even the world’s major banks, equipped with advanced systems, can suffer costly outcomes due to gaps in data accuracy and reporting. Failure to properly identify eligible customer deposits has exposed significant weaknesses in data handling, which has led to heavy regulatory penalties and hurt customer trust. 

Such challenges multiply in developing or underdeveloped countries that have weaker data infrastructure and less mature supervisory technologies. Here, the risks compound and make financial stability even harder to safeguard.  

This is precisely where supervisory technology, or SupTech, can emerge as a panacea. It uses analytics to transform messy, incomplete data into clear, actionable insights that help regulators and firms spot threats and manipulations faster than traditional, manual methods. 

A leading example is Singapore’s Monetary Authority, which developed “Apollo,” an AI-powered system that analyzes vast volumes of trading data to detect subtle patterns of market manipulation that humans often miss. Apollo learns from expert investigators, which allows regulators to focus on the riskiest cases and illustrates how AI-driven SupTech reshapes market supervision. However, even the most advanced solutions depend fundamentally on high-quality data. Without timely, consistent, and complete data, these tools cannot yield reliable insights. 

For regulators, especially in emerging markets, strong and adaptable data systems are imperative and serve as the very foundation of effective, future-ready financial supervision that can prevent crises and protect markets. 

Global adoption: Steady progress but uneven readiness 

While SupTech adoption is increasing worldwide, progress remains uneven. MSC’s work with regulators across Asia-Pacific and Africa shows that while many authorities are interested, their level of readiness varies. A Cambridge SupTech Lab’s 2024 survey shows that 75% of advanced economy regulators and 58% of emerging market authorities now use one or more SupTech or RegTech tools, a gap that has narrowed from 25% in 2023 to 17% in 2024. But behind these encouraging numbers lies a deeper challenge, the unequal readiness of data systems that underpin SupTech initiatives. 

MSC’s country-based studies reveal that many lower-income nations are still in a transitional stage of digital supervision, where some automation exists but manual processes continue to dominate. In the Pacific region, for example, several central banks have launched pilot dashboards for data analysis, but much of the input still comes from manual submissions and non-standard templates. This limits both scalability and consistency. 

Our diagnostics also show that weak digital infrastructure, inconsistent data definitions, and unclear data governance frameworks are often bigger obstacles than funding. In short, the adoption of SupTech tools does not always mean being ready for them. In this context, “ready” refers to the availability of robust data foundations, including clarity, consistency, quality, and  governance of data. Many regulators may have access to these systems but lack the data foundations needed to use them effectively or expand them sustainably. 

Robust and integrated data systems are the foundation upon which effective SupTech supervision is built, powering automation, real-time oversight, and risk-based actions as shown below.

Why strong data systems matter 

SupTech begins with technology, but its true power depends on data, and that is where the foundation for effective supervision is built. Strong data systems sit at the heart of every effective supervisory function. They process high-frequency granular information automatically, detect risks the moment they surface, and give supervisors the confidence to act based on hard evidence. They ensure that every regulated entity reports consistently and comparably, and that sensitive information is stored securely while remaining accessible to those who need it. 

Table 1: Varying data requirements of supervisory functions 

Core challenge: Weak data foundations 

Across less digitally mature markets, MSC’s data maturity assessments have identified three interlinked gaps that frequently delay SupTech transformation. Figures based on MSC’s data are derived from direct surveys of Pacific Island regulators conducted in 2023 as part of our data maturity assessment work. Cambridge figures are cited for global context. While these overlap with global patterns described in the Cambridge SupTech Lab’s work, our regional evidence provides sharper insights into their practical consequences.  

Data quality gaps 

Manual and spreadsheet-based reporting still dominate. MSC’s Pacific SupTech readiness survey (2025) found that one-third of regulators rely on manual submissions. This finding echoes Cambridge’s 2023 global trend, which shows more than half of authorities still handle manual data and nearly three-quarters validate it manually. These overlapping findings underscore how poor-quality and manual data weakens supervisory confidence and delays risk detection. 

Lack of standardization 

MSC’s diagnostics across small islands and low-income economies show that few regulators have consistent taxonomies or standardized data dictionaries across departments. While only 14% of regulators globally report full data standardization, the figure drops even lower, below 10%, in smaller jurisdictions that depend on legacy reporting formats. The absence of common definitions forces supervisors to clean and reconcile data after submission, which slows decision-making, undermines cross-entity comparisons and systemic risk analysis, and makes it inefficient or impossible. As a result, any SupTech solution built on this data risks being weakened. 

Infrastructure constraints 

Even as some authorities explore cloud-based SupTech pilots, in-house or private server storage still accounts for more than half of supervisory data systems in the Pacific, as per MSC’s research. This reliance on in-house systems protects confidentiality but creates silos that block data sharing and integration with modern analytics tools.  

While Cambridge reports low global adoption of cloud storage (31.5%), MSC’s Pacific survey reveals a significant and continued dependence on in-house and private servers across the region, which sometimes exceeds 50% in individual countries. These regional figures may appear to contradict global studies, but they are consistent when viewed in terms of maturity. Many jurisdictions remain at the transitional stage, where cloud experimentation has begun, but full adoption is still limited. 

Why a direct jump to SupTech is risky 

The temptation to invest in the latest tools is understandable. MSC’s research, supported by findings from CCAF and OECD, shows that technological investments often underperform when built without solid data foundations. Ineffective systems yield unreliable results, exhaust critical institutional resources, and heighten exposure to operational and reputational vulnerabilities. In the absence of dependable data, even the most advanced SupTech initiatives can turn into costly trials. 

Therefore, the data shows that before regulators allocate funds to advanced SupTech platforms or infrastructure, they should follow a gradual, capability-based strategy aligned with the maturity of their data ecosystems. The gradual implementation of SupTech solutions promotes smoother implementation, enhances value realization, and prevents costly setbacks. Without this foundation, institutions risk pouring resources into advanced technologies without addressing core weaknesses in data systems, which would ultimately drain institutional capacity and weaken the stability of the financial system. 

In our next blog, we will explore the building blocks of effective data systems and MSC’s framework, which defines what constitutes basic, intermediate, and advanced maturity levels, and showcase how central banks use these stages to implement scalable and future-ready SupTech solutions.

Advancing financial supervision: Best practices in SupTech and RegTech

The report explores how SupTech and RegTech are modernizing financial supervision through automation, analytics, and AI to improve compliance, risk management, and consumer protection. The report draws on global case studies, from the Bank of England to Rwanda and the Philippines, to illustrate practical innovations that strengthen regulatory efficiency and inclusion.

It also presents a five-step adoption framework and strategies to address challenges, such as data privacy, legacy systems, and resource constraints, to promote resilient, technology-enabled regulatory ecosystems.

Unlocking smart supervision in the Pacific

The report “Unlocking Smart Supervision in the Pacific” provides a detailed analysis of current regulatory technology readiness among Pacific Island central banks, which identifies institutional, legal, and technical gaps. The report proposes a phased rollout of a collaborative, modular SupTech solution governed by regulators.  The solution is designed to automate data collection, enhance risk-based supervision, and support financial inclusion. This approach emphasizes regional cooperation, cost efficiency, and sustainable innovation. The report seeks to build resilient regulatory frameworks with a measurable impact within two years. 

 

How locally-led adaptation can make the inherent resilience of MSMEs in Uganda’s cattle corridor bankable

Godfrey is not alone. Uganda’s MSMEs and farmers form the but struggle with the growing impacts of climate change. Droughts are now more frequent and prolonged, which disrupts rain-fed farming and pastoral systems. The 2010–2011 drought alone led to losses worth USD 1.2 billion, which is approximately 7.5% of Uganda’s GDP. In the cattle corridor districts of Nakasongola and Masindi, drought consistently ranks as the most severe hazard, as it dries up water points and destroys pastures. Recurrent drought also causes slow-onset impacts, such as land degradation and desertification, which strip pastures, exhaust soils, and depress future productivity.

For lenders, these shocks drive arrears, delay repayments, and distort credit demand. The default strategy in such conditions is to withdraw from the market. However, they reveal a pathway for innovation, which includes adaptation efforts to generate finance opportunities if lenders can design products aligned with seasonal shocks and recovery periods.

This is where locally-led adaptation measures become crucial. Part one of this series showed how community-level LLA tools help households map hazards and cocreate adaptation options. This second part shifts the focus to the middle tier of MSMEs and their lenders. MSMEs are often banked and have cash flows with repayment capacity, which allow lenders to underwrite adaptation investments. They anchor value chains and provide crucial market services, yet remain climate-exposed.

MSC’s LLA toolkit for IFSPs (LLA-IFSP toolkit) is built for this tier. It enables lenders to trace climate impact pathways across household journeys, from hazards and vulnerabilities to impacts on livelihoods and supply chains that include inputs and outputs. Lenders can adjust product structures and translate MSME insights into phased, financeable plans.

Against this backdrop, MSC partnered with FINCA Uganda to pilot its LLA-IFSP Toolkit. The exercise exposed material climate risks in FINCA’s portfolio, which clarified client adaptation needs, and generated product concepts that aligned with seasonal cash flows. It highlighted climate change as a risk to manage and an opportunity to expand the customer base. This approach could improve portfolio quality, de-risk existing lending, and place climate risk at the core of the ESG strategy.

Preparation is the key

Before the application of the toolkit, secondary research is vital to understand the nature of climate risks and past activities in the locality. This requires a deeper examination of the current climate hazards and impacts, which are expected under different representative concentration pathways (RCPs) and shared socioeconomic pathways (SSPs). This knowledge will be essential for the discussion of future climate scenarios with participants in the field-based exercises.

Insights from the toolkit

Tool 1: Supply-side risk analysis

The tool highlighted how drought stresses FINCA’s loan book. The findings were stark, as approximately 25% of FINCA’s clients are in climate-sensitive sectors. During droughts, these borrowers consistently missed one to two installments per cycle. This pattern increased PAR≥30 by 0.5–1%, with projections that suggest it could double to 1–2% within three years.

The data revealed that recovery is possible. Post-event loan cohorts appeared significantly cleaner, which shows that the problem is not weak underwriting or poor repayment culture, but the strain the households faced during droughts. Grace periods and moratoriums can give clients the time they need to recover.

Subsequent tools (2-7) that were implemented in the field comprised:

Tool 2: Mapping climate hazards

Participants use this tool to identify climate-hazard-prone zones and track changes in hazard patterns. Here, farmers rated drought severity as “five out of five.” They reported longer dry seasons. The farmers explained how enclosures and new veterinary rules hindered coping strategies, such as relocation of cattle to lakes.

Tool 3: Vulnerability assessment

This tool used the DFID’s sustainable livelihoods framework to map resilience across five capitals, which reveals the fragility of rural households when droughts strike.

  • Natural capital erodes as water sources dry up, pasturelands degrade, and elevated temperatures reduce crop and livestock productivity.
  • Physical capital has also degraded. Kraals, the wooden enclosures that protect cattle, collapse under drought stress and termite damage, which causes livestock to escape. This results in fines for encroachment on private land.
  • Financial capital is razor-thin. Most farmers work with little savings and limited access to credit, which hinders recovery after a single failed season. VSLAs and informal lenders are unable to support large-scale investments in adaptation.
  • Social capital remains essential, but it has limits. Neighbors share small amounts of fodder or drugs with each other. Yet, such help is limited in scale and cannot sustain households through prolonged and widespread shocks.
  • Human capital is under immense stress. Drought dries up fields, water sources, and pastures. Hired laborers and men often migrate in search of work, which leaves women and children to shoulder additional burdens.

Tool 4: Climate-related impacts

Participants analyze how climate hazards interact with vulnerabilities to create direct and indirect impacts. They trace impacts through value chains, which reveals the ripple effect. Direct impacts include crop failures, storage losses, livestock stunting, and livestock mortality. Meanwhile, indirect impacts include lost contracts, inflated input prices, reduced access to formal and informal credit, and reputational damage.

Tool 5: Adaptation options currently

This tool looks at how MSMEs have already adapted to climate stress and whether those strategies are sustainable. It helps distinguish between temporary coping mechanisms that merely keep businesses afloat versus genuine adaptation that builds their long-term resilience. An assessment of coping strategies revealed that farmers sought short-term fixes. The farmers adjusted feed times and shifted meals to cooler hours of the day so animals could withstand heat stress. They purchased additional grass, often at high cost, to replace depleted pasture. They also hand-carried water to livestock, a labor-intensive task to compensate for dried-up sources. These measures kept animals alive in the immediate term but placed heavy burdens on household labor and savings.

Tool 6: Prioritization

Participants brainstorm and evaluate potential adaptation options based on availability (is it technically feasible?), accessibility (can we implement it?), and affordability (can we sustain it?). This ensures that final plans reflect realistic, context-appropriate solutions rather than wishful thinking.

In practice, the prioritization exercise revealed a sharp divide. Farmers consistently ranked long-term investments, such as boreholes, feed stores, and fencing, as suitable measures to tackle droughts. Yet, they also considered these options the least feasible, as finance was out of reach.

The MSMEs are not short on ideas, discipline, or clarity. These enterprises know what works and can develop detailed, budgeted roadmaps for adaptation. Yet, well-designed plans fail to take off without suitably designed financial products and models or incentives that can make these adaptation assets bankable.

Tool 7: Farmer’s adaptation plans

The process culminates in a detailed action plan that specifies activities, milestones, timelines, costs, funding sources, and responsible stakeholders. Farmers presented strong and implementable plans, which include boreholes to secure water, feed stores to stabilize nutrition, and fencing to protect cattle, among others. These plans also included suppliers, installation details, and seasonal repayment calendars that match cash flows. Despite strong business cases, no plans were accepted due to credit ceilings or perceived risk.

The path forward

The pilot highlights the urgent need for inclusive financial service providers to adapt their products and processes to meet the resilience needs of farmers.

  1. Redesign loan products
    • Introduce seasonal repayment schedules aligned with harvest or livestock fattening cycles
    • Develop phased lending that supports long-term investments in manageable tranches
  2. Recognize adaptation as bankable
    • Treat investments such as boreholes, feed reserves, and veterinary certification as productive assets
    • Bundle credit with adaptation services such as insurance, agronomic advice, and input supplier linkages
  3. Manage portfolio risks
    • Mainstream climate risk into credit assessments and provisioning
    • Use early warning systems and local data to predict repayment challenges
  4. Partnerships and funding
    • Mobilize concessional finance, guarantees, and parametric insurance to de-risk adaptation lending
    • Partner with development agencies, insurers, and technical experts to support farmers with credit.

A path from risk to resilience

MSMEs are at risk when labeled as “climate risky” without changes in how finance is delivered. This approach could cut MSMEs off from credit entirely when they need it most. In such cases, climate finance that focuses on risk recognition without product redesign leads to exclusion, rather than resilience.

The LLA toolkit helps avoid this trap. It shows lenders how to lend differently and not less. Lenders can align repayment terms with seasonal hazards. They treat adaptation assets, such as boreholes and feed stores, as bankable, and phase credit to manage exposure. Consistent with this toolkit, FINCA Uganda is committed to equip its customers with practical, user-friendly tools and resources to adopt a customer-centric approach in product design and delivery.

This change in approach acknowledges that farmers are not passive victims of climate change but active participants who plan, invest, and adapt. However, what these farmers lack is financial support. As a result, financial institutions can protect their portfolios. This approach enables MSMEs to adapt and demonstrate that climate resilience is not only necessary but also financially viable.

For Godfrey, this means he can have a borehole that keeps his herd alive. For FINCA, it means arrears that stabilize and a portfolio that holds. For both, it means resilience in the face of harsher seasons.