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Behind the design of customized evaluations for complex multistakeholder programs

How can an organization help make a major road more resilient to floods if it does not build the road? It can advise planners, train government officials, and involve local communities, while others make the final decisions.

The government makes decisions, a development bank finances the project, engineers develop the design, and local authorities and communities influence what gets built. If the road becomes more resilient to floods, how do we understand one organization’s contribution when many actors shape the result? How did the actors’ decisions interact, and did the support justify the resources used?

MSC faced these questions as we evaluated the Global Center on Adaptation’s (GCA’s) in Bangladesh, supported by Global Affairs Canada (GAC).

GCA intended to influence larger investments rather than directly finance major infrastructure. In Bangladesh, its portfolio included nine projects that span locally led adaptation, resilient infrastructure and urban systems, nature-based solutions (NbS), and climate adaptation finance. Seven of these projects were linked to larger investments supported by multilateral development banks (MDBs) and other international financial institutions (IFIs).

GCA worked with government agencies, MDBs, and IFIs during the early project preparation phase to integrate climate resilience into large-scale infrastructure projects. It conducted climate risk assessments, prepared adaptation solutions, provided technical advice and capacity-building support, and contributed to locally led community planning.

The portfolio’s size created only part of the evaluation challenge. How could MSC assess GCA’s influence in a complex multistakeholder ecosystem? GCA provided only part of the support. Other actors influenced whether that support was used, approved, financed, and implemented. GCA’s theory of change recognized this reliance on other actors in the ecosystem. As a result, MSC customized the evaluation approach and learning questions to GCA’s expected change pathway. The team combined project documents, performance data, and stakeholder perspectives to examine each part of the results pathway.

Why do conventional evaluation designs only tell part of the story?

Climate adaptation and NbS depend heavily on context and can take years to show their full effects. A flood-resilient road, an urban drainage plan, or a nature-based intervention depends on climate conditions, government decisions, financing, maintenance, institutional capacity, and community participation. These factors also interact, as technical advice can shape an investment only if partners use it, decision processes incorporate it, and institutions can carry it forward.

Evaluation literature has long recognized these challenges.

The Organisation for Economic Co-operation and Development’s (OECD’s) 2019 research identifies attribution, baseline shifts, and long-term effects as shared challenges in climate adaptation evaluation. This research also states that a comparison of conditions before and after an intervention may be insufficient because climate risks and the wider social and institutional context continue to change.

The same concern appears in the literature on NbS. The International Union for Conservation of Nature (IUCN) Global Standard for Nature-based Solutions uses broad criteria to assess NbS interventions beyond a single outcome. The standard considers the societal problem alongside ecological integrity, economic feasibility, inclusive governance, trade-offs, adaptive management, and the intervention’s ability to last and scale.

This breadth mattered to GCA because it did not implement standalone NbS activities. It sought to embed climate resilience, including nature-based approaches, within larger investment and planning processes. Its contribution could appear first in a revised design, technical assessment, planning method, stronger institutional capacity, or greater consideration of local priorities. Benefits for communities could come later.

The evaluation, therefore, needed to follow this pathway rather than rely on a single measure of success.

How did the evaluation approach respond?

Figure 1:  OECD’s Development Assistance Committee (DAC) criteria, Contribution analysis (Mayne, 2001; 2008) and Value for money (OPM, 2019)

Across all three approaches, MSC triangulated documents, performance data, and stakeholder perspectives. This evidence distinguished verified findings from early signals and outcomes that still depended on future uptake and implementation.

What did this mean in practice?

Each part of GCA’s change pathway required different evidence, so a customized design was essential. GCA had completed some activities, but the investments it sought to influence were still developing. The evaluation, therefore, did not treat future community-level benefits as if they had already occurred. Instead, it examined what could be verified at the time and whether credible signs showed that partners had adopted GCA’s approaches going forward.

The evaluation examined what happened after delivery of a technical product. For example, the value of climate risk assessment depended on what followed: Were its recommendations discussed? Did they enter planning or design decisions? Did the relevant institutions have the ability and incentives to use them?

Context also shaped value. A low-cost study offers little value if the decision-makers cannot use it. Similarly, training may appear efficient when it reaches many participants, but contribute little if they do not apply the knowledge. The evaluation therefore considered resources alongside quality, timeliness, results, and inclusion.

This is where customization becomes important. Complex evaluations rarely require a completely new method. They usually need established approaches, applied to the right questions and at the right point in the results pathway.

Customizing complex evaluations to context

The GCA assignment illustrates a broader principle that applies to many complex, multi-stakeholder programs: Evaluation design should align with how a program expects change to occur.

Programs that work through partnerships, technical assistance, policy influence, institutional change, or larger investment systems often face similar challenges. Multiple actors shape results. Some outcomes appear much later than others. The organization being evaluated may influence decisions without directly controlling implementation.

In such settings, when evaluators first select a standard design and then fit the program into it, important questions can go unanswered.

MSC starts with the program’s change pathway, identifies where evidence can realistically be generated, and customizes the evaluation design accordingly. The established methods can then be combined to address different parts of the problem.

This approach makes the evaluation fit the program without adding unnecessary complexity. These three lessons stand out:

  • Start with the change pathway: Evaluation questions should reflect how the program expects to influence decisions and results;
  • Match methods to questions: Performance, contribution, and value are related, but each question may require a different approach;
  • Keep claims proportionate to the evidence: Separate what can be verified from what still depends on future uptake, financing, or implementation.

Programs can apply these principles beyond climate adaptation wherever they work through several institutions, shape a chain of decisions, and influence the outcome without delivering it directly.

For a program that influences a road without building it, a customized evaluation can answer the question posed at the outset. It can trace how change happened, clarify the program’s role, and show what evidence supports the conclusion.

Beyond traditional digitisation: How ready are Nigerian States for modern tax administration?

Nigeria’s tax system plays an increasingly vital role in funding essential public services and supporting the government’s development priorities. Over the past decade, the share of the country’s mineral revenues in total revenues declined from 50% in 2015 to 30% in 2025. Across the country, there is growing recognition of opportunities to build capacity for digital domestic resource mobilisation (DDRM) while addressing challenges such as a narrow tax base, dependence on oil revenue, revenue leakages, and fragmented administration.

This momentum is creating an important opening to strengthen digital revenue administration to support sustainable economic growth. Governments are expanding the use of Digital Public Infrastructure (DPI), i.e., digital identity, payment, and data-sharing systems, to improve revenue performance, taxpayer support, and service delivery. At the sub-national level, the diversification of revenue sources and the opportunity to make digital tax administration more efficient, inclusive, and responsive have never been more promising. Domestic revenue has grown threefold since 2018, and the share of non-tax revenues has, for the first time, exceeded 37%.

Line chart showing tax and non-tax shares of IGR from 2018 to 2025. Tax revenue peaked at 66.5% in 2020 before declining to 54.9% in 2025, while non-tax revenue rose to 45.1%.

Figure 1: Composition of the Internally Generated Revenue (IGR) of States

The first blog in this series discussed Nigeria’s revenue challenges and the enabling role of DPI in strengthening public finance. This blog focuses on the Intelligent Revenue Authority (IRA) Readiness assessment, drawing attention to the findings, emerging capabilities, and opportunities for States to build smarter, more efficient, and taxpayer-centred revenue administration systems.

In the context of taxation, DPI enables reliable taxpayer identification, efficient payment processing, and effective data exchange across government entities. However, the extent to which these foundational capabilities translate into improved revenue outcomes depends on how they are integrated into the revenue administration system.

The IRA Readiness Assessment is a diagnostic tool that evaluates the digital maturity of State revenue authorities in Nigeria. It is designed to be applied across the taxpayer journey, i.e., the end-to-end experience a taxpayer, whether an individual or a business, has when interacting with a State revenue system, from registration through payment and post-payment services. Drawing on key DPI principles such as interoperability, scalability, security, and user-centric service delivery, the assessment evaluates how effectively revenue authorities leverage digital platforms, data systems, and automated processes throughout the taxpayer journey.

Covering all 36 States and the Federal Capital Territory (FCT), the assessment provides a State-by-State profile of digital maturity in tax administration. It draws on extensive consultations with the heads of Nigeria’s revenue authorities and digital agencies to understand their operating environment and priorities. The tool highlights gaps in automation, interoperability, data quality, and institutional capacity that affect States’ ability to register taxpayers, validate transactions, manage records, and mobilise revenue. It also recommends DPI-targeted actions to strengthen Digital Domestic Revenue Mobilisation (DDRM) and embed Digital Public Financial Management (DPFM) principles across the taxation lifecycle.

 

How the IRA tool measures digital maturity

 

The IRA Readiness tool was developed following an extensive review of global literature[1] and discussions with revenue stakeholders. It evaluates digital maturity across nine key indicators of the end-to-end taxpayer journey. These indicators assess the people, process, and platform dimensions of revenue administration to achieve a nuanced evaluation of rules, technological capabilities, operational practices, and institutional readiness that reflect the realities of Nigeria’s tax administration system. The following table elaborates on these indicators.

Table outlining the nine Intelligent Revenue Authority Readiness Index indicators: beneficiary onboarding, compliance verification, estimation, payment validation, human resource capacity, acknowledgment, system reminders, data security, and data management.

 

What the IRA assessment reveals about State readiness

 

The assessment provides a baseline against which States can track progress over time and measure the impact of future digital investments and reforms. Using composite digital maturity scores,[2] the 36 States and the FCT were categorised into three categories, namely high, medium, and low, to capture their level of digital readiness.

Infographic classifying revenue authorities by digital maturity: high maturity above 70% with integrated and automated systems, medium maturity at 40–70% with partially digitized processes, and low maturity below 40% with mainly manual and fragmented systems.

Figure 2: The three types of digital readiness levels

The assessment reveals significant variation in digital readiness across States, driven by differences in digital infrastructure, process automation, interoperability, governance practices, and institutional capacity. While some States have established integrated, highly automated revenue systems, others rely on fragmented or semi-manual processes for taxpayer onboarding, compliance verification, payment reconciliation, and data management.

Map of Nigeria showing Intelligent Revenue Authority digital maturity scores by state. High-maturity states are grey and medium-maturity states are blue, with scores ranging from 40.2 in Benue to 90.5 in Bayelsa.

Figure 2: States with IRA digital maturity scores

The IRA maturity score combines performance across all three payment streams (P2G, B2G, and G2G) to provide a composite measure of a State’s readiness for digital revenue administration. This composite approach will help governments identify strengths and gaps across all taxpayer-type journeys, rather than evaluating each journey in isolation.

Leading States such as Bayelsa, Borno, Kano, Gombe, and Delta deserve recognition for their progress in rolling out fully digital taxpayer onboarding, integrating their identity systems with the National Identification Number (NIN) and Bank Verification Number (BVN), enabling real-time payment validation, and adopting advanced tax compliance mechanisms. Medium-maturity States, on the other hand, can prioritise improvements that advance interoperability, backend automation, and data governance, while low-maturity States can focus on foundational reforms, including digital taxpayer onboarding, single taxpayer databases, standardised security controls, and improved digital skills for staff.

Of the 37 revenue administrations assessed, 18 States scored an aggregate above 70%, reflecting high digital maturity. Others clustered between 60–75%, highlighting moderate integration of digital infrastructure but persistent gaps in interoperability, automation, and comprehensive data security. Five other States scored below 55%, underscoring the prevalence of fragmented, semi-manual, or paper-based processes.

 

Person-to-government (P2G): strongest in onboarding and payments, weaker in compliance management

 

P2G systems demonstrate the highest levels of digital maturity in taxpayer onboarding, payment validation, and digital acknowledgments, making it easier for individual taxpayers to register, pay taxes, and receive transaction confirmations. However, progress is less consistent in compliance verification, tax estimation, automated reminders, and grievance resolution. Data management and security practices also vary widely, and limited technical capacity continues to constrain the implementation and maintenance of digital services. Evidently, many P2G platforms prioritise transactions over providing a comprehensive, citizen-focused digital tax experience.

P2G taxation system findings: 20 states show high digital maturity and over half use digital taxpayer onboarding, but fewer than 35% have fully digitised TCC processes and nearly half lack integration with NIN and BVN systems.

 

Business-to-government (B2G): stronger compliance systems, but uneven automation and integration

 

B2G systems exhibit relatively high maturity in business onboarding, compliance verification, payment validation, and data management, all of which are required to support larger and more complex business transactions. However, automation of tax estimation, reminders, grievance resolution, and end-to-end workflow integration lags in most States. While larger businesses generally benefit from more structured digital services, gaps in interoperability, cybersecurity, and technical capacity limit the efficiency and consistency of digital tax administration.

B2G taxation system findings: 21 states have high digital maturity and 17 have digitised business registration, but fewer than 40% integrate identity verification with CAC or NIN, and few offer sectoral dashboards or e-KYC.

 

Government-to-government (G2G): progressing slowly due to interoperability and institutional constraints

 

G2G systems demonstrate the lowest level of digital maturity across the three payment streams. While half of the States have digitised internal payment processing and basic validation workflows, progress is limited in compliance verification, data management, automated reminders, and end-to-end process automation. Weak interoperability among MDAs, inconsistent cybersecurity practices, and limited technical capacity further constrain information sharing and coordinated decision-making. As a result, many States rely on fragmented systems and manual processes for managing intergovernmental fiscal relations.

G2G taxation findings: 16 states have high digital maturity, 20 have medium maturity, and one has low maturity. Fewer than 35% use real-time dashboards, while over half lack sufficient capacity for full digital adoption.

 

Charting the path forward: from insights to action

 

The direction of travel is clearer for States, with the next frontier of digitalising tax coming from linking identity, payment, and data systems into seamless taxpayer journeys and pairing this infrastructure with the institutional capacity required to sustain it. As these building blocks come together, digital readiness will translate into stronger revenue, fairer systems, and greater public trust, giving every State a stronger footing to finance its own development. The IRA tool shows that the key barrier to digital revenue transformation is no longer the absence of digital platforms. Fragmented taxpayer records, limited automation, weak interoperability, inconsistent data governance, and gaps in institutional capacity are the main binding constraints. These gaps span the taxpayer journey, from registration and compliance verification to payments and post-payment services. Addressing them requires a DPI approach that connects systems, enables secure data exchange, and supports integrated revenue administration. The roadmap for States will include the following actions:

Strengthen taxpayer registration and data foundations: Fragmented taxpayer records and limited cross-system verification make it difficult to build a reliable view of taxpayers. A Single Customer Account (SCA) can address this by consolidating taxpayer information and linking it to foundational digital infrastructure, including the National Identification Number (NIN), Bank Verification Number (BVN), the Joint Revenue Board (JRB) Tax Identification Number (TIN), the Corporate Affairs Commission (CAC), and the Nigeria Inter-Bank Settlement System (NIBSS). A single or integrated source of truth can reduce duplication, improve data quality, and strengthen compliance monitoring.

Automate compliance and service delivery: While digital onboarding and payments have advanced, compliance verification, tax estimation, Tax Clearance Certificate (TCC) processing, grievance redressal, and system reminders are less mature. Rules-based workflows, automated verification, digital TCC issuance, and automated notifications can reduce manual intervention and improve turnaround times. An interoperable payments infrastructure, including bank and fintech platforms, USSD, agent banking, and mobile money, can also expand convenience and make payment options more accessible.

Enable data-driven revenue administration: Revenue authorities are generating increasing volumes of taxpayer data, yet its use for compliance management and decision-making remains limited. Integrated customer relationship management (CRM) platforms, risk-based compliance tools, real-time dashboards, and automated reminders can transform this data into actionable insights. This will help authorities identify compliance risks early, target interventions more effectively, and reduce the high cost of compliance.

Strengthen trust through security and governance: Greater data integration increases the need for stronger safeguards. The roadmap emphasises baseline cybersecurity measures, including multi-factor authentication, encryption, access controls, and incident response protocols, along with clear data governance standards to protect taxpayer information and maintain trust in digital services.

Build institutional capacity to sustain transformation: Digital systems require capable teams to implement, manage, and continuously improve them. The roadmap includes strengthening digital leadership, building dedicated technical capacity, improving staff digital skills, and embedding structured change management within revenue authorities. Targeted taxpayer awareness and inclusion initiatives, particularly for women, youth, and small businesses, can further support adoption and ensure that digital services translate into broader participation in the formal revenue system.

States may structure their path of change into phases based on their level of digital maturity (See Figure 3). This phased approach will help States address foundational gaps before implementing more sophisticated reforms to achieve efficient, transparent, and resilient revenue administration.

Three-phase digital tax reform roadmap: immediate onboarding and basic service improvements in months 0–3; interoperability and automation in months 3–12; and advanced integrated platforms, predictive analytics, and intelligent compliance beyond 12 months.

Figure 3: The phased roadmap for implementing recommendations in the IRA report

This blog was first published on ‘Nigeria Governors’ Forum’ on 12th October 2026.

 

[1] The literature review draws on leading publications, including Tax Administration Digitisation and Digital Transformation Initiatives (OECD), Tax and Customs Administration – Digitalisation Resources (IMF), and Tax Administration 2023 – Digital Transformation Journeys (OECD).

[2] The composite digital maturity score represents the aggregated assessment of dimensions such as digital infrastructure, system automation, data management, interoperability, governance, cybersecurity, and institutional capacity.

From prevalence to program response: How the NFHS-6 and the Poshan Tracker can strengthen nutrition decision-making

What does it take to turn nutrition data into action? 

In India, the answer lies not in a single database or survey, but in a connected information ecosystem. Periodic household surveys, routine beneficiary monitoring, health and supply systems, and an extensive frontline network each provide a different piece of the puzzle. Together, they power an integrated decision cycle that answers four critical questions: Where is the burden greatest? Which households need support now? What intervention is most likely to help? And are those efforts delivering results? 

Answering these questions requires looking at nutrition through multiple lenses. Each data source has a distinct role at both the population and individual levels. The National Family Health Survey-6 (NFHS-6) provides a population-level view of nutrition outcomes, their distribution, and associated factors. The Poshan Tracker brings the picture closer to real time and offers insights into beneficiary growth patterns and the continuity of program responses. Additional health, supply, entitlement, and community data help explain what lies behind the numbers, which enable decision-makers to identify likely drivers and tailor interventions accordingly. 

The  NFHS-6 presents a varied picture of progress in child nutrition. Stunting among children under five declined from 35.5% in NFHS-5 to 29.3% in NFHS-6. Severe wasting also fell from 7.7% to 5.2%. However, overall wasting changed only marginally, from 19.3% to 19.0%, while underweight declined from 32.1% to 31.8%. Complementary feeding practices improved, although few children receive an adequate diet.  

These findings highlight two priorities. First, India must consolidate gains in reducing chronic undernutrition. Second, it must strengthen responses to acute undernutrition and multiple forms of deprivation. This requires early detection of growth faltering, tailored case management, and closer assessment of service, behavioral, and household factors associated with persistently poor diets.  

These findings support strategic prioritization rather than causal attribution. As a cross-sectional survey, the NFHS estimates population patterns at specific points across survey rounds. It does not follow individual children over time or isolate nutrition services from concurrent improvements in health care, sanitation, food security, education, or social protection. Separate evaluation designs are necessary to establish causal links. For program management, the NFHS-6 identifies priority outcomes, geographic areas, and vulnerable groups that require targeted action.  

While the NFHS-6 helps establish strategic priorities, the Poshan Tracker supports decisions about individual beneficiaries and service delivery. The two sources answer distinct but complementary operational questions. The NFHS-6 estimates the prevalence and distribution of nutrition outcomes and highlights associated maternal, household, and service factors. The Poshan Tracker records repeated physical measurements and service contacts for registered beneficiaries. When measurement quality and record continuity remain adequate, these observations show whether a child grows as expected, begins to falter, or recovers after support.  

Connecting both sources preserves their distinct purposes. The NFHS-6 provides a population benchmark for national, state, and district priority-setting. The Poshan Tracker supports active case management and operational oversight between survey rounds. Decision-makers can assess discrepancies against differences in coverage, definitions, measurement quality, and program reach. This approach helps them interpret each source on its own terms and use the combined evidence appropriately.  

Administrative and frontline data complete the decision picture. Health data provide evidence on illness, anemia screening, and referral completion. Supply systems track continuity of supplementary nutrition and equipment functionality. Social protection records confirm whether eligible households access broader entitlements. Frontline observations and community feedback provide essential context on food affordability, care practices, migration, and service delivery. A Poshan Tracker-plus framework combines these sources through structured triangulation to guide targeted action.  

Together, these three layers support different decisions: The NFHS-6 informs strategic prioritization, the Poshan Tracker supports beneficiary and service delivery management, and complementary data help identify causes and select responses. An effective operating model must translate these insights into clear responsibilities, standard response protocols, regular reviews, and measurable outcomes at every administrative level. 

The Poshan Tracker, launched in 2021, enables near–real-time tracking, dynamic identification of stunting, wasting, and underweight, and last-mile service monitoring. It digitizes anganwadi registers across 24 languages. Its growth-history feature provides a foundation for shifting from activity reporting to beneficiary tracking and program response management.  

Programs can realize this potential through designated decision-makers, standard response protocols, regular review schedules, and clear closure criteria at every administrative level:  

Initial implementation should target a limited set of high-value decisions. Teams should select use cases based on outcome relevance, geographic concentration, data timeliness, clear ownership, and the potential for actionable responses. Population and real-time data together help identify where problems cluster, who faces the greatest risk, what factors contribute to these problems, and which interventions offer value. Three use cases illustrate this approach:  

  • Childhood growth faltering: Repeated failure to gain weight or a sustained decline in growth signals an urgent need for a structured care pathway. Population data identify geographic areas with elevated risk. Real-time data trigger immediate measurement verification, feeding assessments, illness checks, tailored counseling, entitlement support, and time-bound follow-ups to track growth changes.  
  • Infant and young child feeding (IYCF): The NFHS-6 identifies areas where feeding practices lag, while the Poshan Tracker flags counseling milestones and gaps in contact. Community feedback helps determine whether poor diets stem from limited awareness, food affordability, time constraints, or social norms. These insights guide responses, from stronger counseling to coordination with livelihood programs.  
  • Implementation quality: When service coverage and nutrition outcomes diverge, structured reviews assess measurement quality, service content, supply continuity, and referral completion. Comparisons across administrative levels help distinguish systemic operational bottlenecks from local field constraints. This approach helps teams deliver timely, appropriate, and sufficiently high-quality interventions to improve outcomes.  

Effective implementation requires a focused management framework that moves beyond data availability to consistent operational use. Five enablers can support this shift:  

  1. Define the decision and supporting indicators: Link each priority measure to a specific decision, designated user, review frequency, action threshold, and expected program response.
  2. Track trajectories and case closure alongside status: Complement static coverage indicators with changes over time, follow-up timeliness, completed referrals, and resolution of the original concern.
  3. Embed data quality in supportive supervision: Use plausibility checks, sequences of missing data, and unusual patterns to guide supervisory coaching, verify measurements, and recalibrate field equipment.
  4. Institutionalize triangulation: Conduct monthly block reviews and quarterly district reviews. Assess the Poshan Tracker indicators alongside health, supply, entitlement, and community evidence through standardized review frameworks.
  5. Assess contribution before scaling: Implement defined response pathways in selected high-burden areas. Evaluate operational feasibility, implementation fidelity, and measurable outcome improvements before expanding the approach nationally.

India has the essential institutional foundations for this approach: periodic population surveys, a national nutrition monitoring platform, extensive frontline networks, and administrative systems. The next opportunity lies not in collecting more data or building more dashboards, but in linking existing evidence to defined decisions and faster program responses. Artificial intelligence (AI)-enabled analytics can accelerate this shift. These tools can integrate signals across data sources, identify emerging hotspots, prioritize vulnerable cases, and help managers select effective responses. Human judgment and program ownership must remain central to these decisions.  

A mature nutrition information system tracks the entire results chain. It verifies measurements, detects emerging risks, deploys targeted responses, resolves service delivery bottlenecks, and records improvements in nutritional trajectories. By combining population-level evidence from the NFHS-6 with real-time intelligence from the Poshan Tracker, administrators can establish a coherent framework for targeted action, adaptive management, and shared accountability at every level of governance. 

Fish cross the border. Financing does not.

Adhis leaves Kalokol before 4 a.m. to buy sun-dried tilapia from fishers around Lake Turkana. She has pre-financed some of their catch. No single fisher has enough to fill her truck, so she builds the consignment one crate at a time before starting the long journey to regional markets. 

By sunrise over the Chalbi Desert, Adhis has secured the last tarpaulin and loaded the truck. The difficult part is only beginning. The fish will travel south and west through a corridor linking Kenya with Uganda, Rwanda, and the eastern Democratic Republic of the Congo (DRC). Markets such as Goma and Bukavu offer higher prices than those in Kenya. 

The 1,400 km journey crosses four countries and four currencies: Kenyan shillings, Ugandan shillings, Rwandan francs, and Congolese francs. It also passes through several border posts, each with its own documentary requirements, unofficial fees, and processing delays. Those delays can hold a refrigerated, and more often unrefrigerated, truck for hours in equatorial heat. 

Working capital may come from personal contacts or informal lenders. Adhis must often settle border-related costs and unexpected expenses immediately. 

Yet the commercial history behind these transactions remains fragmented. Supplier and buyer relationships, mobile-money transactions, consignment records, border crossings, and repayments are kept in separate records rather than forming a credit profile that a lender can assess across markets. 

The trade exists, yet formal finance has not matched this cross-border model at scale. 

The fish is already crossing 

Africa’s cross-border fish trade predates the African Continental Free Trade Area (AfCFTA). Fish already moves through established regional corridors as traders connect producing areas with markets with stronger demand. 

Women traders move omena from Lake Victoria into Uganda and Rwanda. Traders deliver Nile tilapia from Kenya to buyers deep in the DRC. Marine fish travel from Tanzania’s coast north to Nairobi and south to Mozambique. Informal supply chains carry fish along the Zambia-DRC copper belt corridor to mining communities in Lubumbashi and Kolwezi. In West Africa, Nigeria and Cameroon share one of the region’s highest-volume informal fish corridors, which rotating savings groups finance. 

The Women and Youth Economic Empowerment in Fisheries through Inclusive Market Access (WYEEFIMA) program operates within this reality. TradeMark Africa and the AfCFTA Secretariat implement the program in partnership with the Mastercard Foundation. MSC (MicroSave Consulting) supports access to finance across Kenya, Tanzania, Uganda, Nigeria, the DRC, and Zambia. 

Five financing gaps stand out. 

  1. Working capital that can move across markets

A trader operating across Kenya, Uganda, Rwanda, and the DRC may incur costs and receive payments in several currencies during one trading cycle. Exchange-rate movements, conversion costs, and payment timing can all affect margins. 

Corporate and commercial banks already offer multi-currency facilities, yet smaller fisheries traders often struggle to access them. Many manage liquidity through cash, mobile money, personal networks, or informal borrowing. 

Financial institutions can adapt working-capital products to businesses whose transactions span several markets. Transaction histories, repeat trading relationships, purchase records, and predictable routes can help lenders assess these businesses as cross-border traders rather than purely domestic borrowers. 

  1. Trade finance is suited to smaller transactions

A fish consignment sold to a known buyer across a border creates familiar trade-finance needs. The seller needs liquidity before payment arrives, and both parties face the risk of delay or non-payment. 

Letters of credit, guarantees, invoice finance, and similar instruments already address these needs in larger transactions. The gap lies in making suitable structures and ticket sizes accessible to smaller fisheries enterprises. 

Without such products, traders may finance purchases and transit costs themselves or through expensive informal credit. They carry much of the liquidity and payment risk personally. Confirmed buyers, repeat orders, invoices, consignment documents, and transaction histories can help formal lenders assess these transactions. 

  1. Insurance that reflects how fish move

Cross-border fish trade combines transport and product risk. Accidents, theft, breakdowns, border delays, and poor handling can reduce a consignment’s value before it reaches the buyer. 

Cargo and goods-in-transit insurance already exists, yet many smaller fisheries businesses struggle to access coverage that fits their operations. 

Tailored fisheries insurance is possible. GA Insurance launched Samaki Bima in August 2025, providing coverage designed around the risks fish farms face. 

This example suggests potential for similarly tailored products that cover cargo and transit risks for fisheries businesses moving perishable goods across borders. 

  1. A credit profile that can travel with the trader

A trader such as Adhis may already produce valuable information about her business, including mobile-money transactions, repeat buyers, supplier relationships, consignment records, and repayment behavior. 

These records sit across different systems and jurisdictions, making it difficult for a lender to form a consistent view of the business. 

Domestic transaction data also misses cross-border risks, which include currency movements, buyer default, border delays, spoilage, theft, and changes in documentation requirements. 

Bringing transaction histories, buyer relationships, route performance, and repayment records together could make the opportunity and its risks easier to assess. MSC’s work on meaningful financial inclusion for women similarly highlights the value of information that women already generate through their businesses, rather than relying only on conventional collateral. 

The challenge is to make these records consistent, consent-based, and usable across institutions and markets. 

  1. Finance for preservation and logistics

Cross-border fisheries trade depends on transport, storage, handling, and refrigeration, as required by the product. 

Leasing and asset finance can help businesses acquire trucks, cold rooms, insulated storage, and handling equipment without paying the full cost up front. Enterprises with limited formal credit histories may still struggle to access this finance. 

The financing structure must also reflect how the business earns money. Seasonal volumes, border delays, variable asset use, and irregular payment cycles can make standard monthly repayments a poor fit, even when the asset is commercially useful. 

Lenders must determine whether the asset supports a viable trade flow and generates sufficient cash for repayment. 

Making cross-border businesses visible to finance 

Under the WYEEFIMA program, MSC works with both fisheries enterprises and financial providers. 

For fisheries enterprises, this means strengthening the records lenders can assess, including transaction histories, consignment documents, buyer relationships, and cash flow records. For banks, microfinance institutions, savings and credit cooperatives (SACCOs), FinTechs, and insurers, it means understanding the fisheries value-chain economics and adapting products and risk assessment to these businesses. 

Better information does not remove risk. It helps lenders identify and price exposure to foreign-exchange movements, buyer default, transport disruption, product loss, and regulatory uncertainty. It can also prevent viable businesses from being excluded simply because domestic lending templates do not account for cross-border operations. 

Financial infrastructure is beginning to emerge 

Several building blocks are already in place. 

Afreximbank’s African Collaborative Transit Guarantee Scheme is designed to reduce the cost and friction of moving goods through several African customs territories. The Pan-African Payment and Settlement System (PAPSS) is building infrastructure for cross-border payments in African currencies. 

The next challenge is to extend this infrastructure to smaller fisheries enterprises and make it commercially viable. 

Financial institutions must recognize cross-border cash flows. Insurers and guarantors must cover transit and payment risks, while payment systems must reduce the cost and complexity of moving money between markets. Better records can help traders demonstrate the commercial history behind these transactions. 

Adhis will continue moving fish, whether the financial system catches up or not. Supporting her requires more than a loan. Payments, insurance, guarantees, portable records, and financing must move with the trade. The fish has already crossed the border; the opportunity is to ensure that the financial system can cross with it. 

The two-thirds opportunity: Where capital should flow

The previous blog in this series showed the scale of Kenya’s fisheries opportunity. In 2024, domestic production of 168,424 metric tons met about one-third of an estimated annual requirement of 510,000 metric tons. Data from MSC’s Women and Youth Economic Empowerment in Fisheries through Inclusive Market Access (WYEEFIMA) program also show the sector relies substantially on informal finance. 

This brings us to the question of where formal finance can work across Kenya’s fisheries value chain. As we will see, the answer may emerge from enterprises with viable markets, visible cash flows, and financing structures that match how they operate. 

Seven places where capital can work 

MSC’s work under the WYEEFIMA program points to seven areas where formal finance could support growth. 

  1. Working capital for fish-feed suppliers

Feed is among the highest operating costs in aquaculture. For cage and pond farmers, it can account for more than 60% of production costs. Moreover, Kenya depends partly on imported aquafeed, which exposes suppliers and producers to pressures related to working capital, inventory, and foreign exchange. 

For lenders, this creates a clear use case for working capital. Facilities linked to purchase orders, confirmed supply contracts, established sales histories, or recurring customer relationships could help suppliers stock ahead of demand. Financing suppliers can strengthen more than one enterprise. More reliable feed availability can ease a constraint for farmers further down the value chain. 

  1. Financing hatchery expansion

Aquaculture depends on a reliable supply of quality fingerlings, which places hatcheries near the start of the production cycle. WYEEFIMA data show that hatchery capital requirements range from relatively small working-capital needs to investments of more than KES 15 million (USD 117,238) for larger commercial operations. 

Hatcheries, therefore, need different products. Smaller businesses may need short-term finance for broodstock, feed, labor, and operating expenses. Larger hatcheries may require longer-term funding for tanks, pumps, water systems, equipment, and expansion. Meanwhile, lenders must assess whether production records, survival rates, customer demand, and repayment capacity support the requested finance. 

  1. Working capital for women aggregators and traders

Women play a major role in fish aggregation, processing, and retail. Yet, many have limited working capital and few productive assets that conventional lenders recognize as collateral. Their immediate need is often straightforward. They need enough liquidity to buy fish when supply is available, move it quickly, sell it, and return to the market for the next cycle. 

A cash-flow-based, collateral-light facility could assess these businesses through transaction histories, repeat supplier relationships, mobile money records, and established trading patterns, rather than relying only on fixed assets. 

Why does this matter? It matters because MSC’s WYEEFIMA market study found that informal borrowing remains an important source of working capital for most fish traders. Formal lenders could replace some of that high-cost, short-term borrowing with products matched to actual trading cycles. 

  1. Cold-chain infrastructure

Capital is also needed after fish leave the water. Recent research estimates losses at about 25% of production, which means post-harvest losses reduce the share of fish that reaches consumers in saleable condition. Cold storage, ice, handling equipment, and transport infrastructure are therefore vital opportunities to finance fisheries. 

For lenders, much of this is a use case of asset finance. Cold rooms, ice-making machines, insulated boxes, refrigerated transport, and related equipment can generate identifiable revenue when demand and use are sufficient. 

Yet, equipment is only part of the credit decision. Lenders must also understand throughput, energy costs, utilization, location, maintenance, and who will pay to use the infrastructure. The opportunity is strongest when a cold-chain asset serves an established fish-supply chain and a visible market. 

  1. Cluster finance for cage farming

In 2024, Kenya had approximately 5,975 fish cages in operation, which shows that cage aquaculture had already reached a meaningful scale. Further expansion may require more capital than individual microloans can provide. 

One option is cluster finance for farmers who share infrastructure, purchase feed collectively, coordinate market access, or sell through common off-takers. This structure can give lenders better visibility into production and transactions and allow farmers to share some operating costs. 

MSC’s pond-farming data also illustrate why repayment structures must follow biological cycles. A lender cannot finance a farmer whose revenue arrives only after harvest on the same schedule as a trader who turns stock every few days. Finance must therefore follow the production cycle instead of forcing the cycle to fit the loan. 

  1. Working capital and equipment for processors

Processors create value after fish are landed, yet many lack sufficient capital. Some need equipment, such as improved smoking kilns, drying racks, handling tools, or small cold-storage units. Others need working capital to buy fish when supply is available, before limited liquidity costs their business. 

Asset finance can support equipment with a useful life extending beyond a single production cycle. Short-term working capital can help processors purchase inputs and maintain throughput. Meanwhile, lenders should compare revenue and investment over consistent periods. Even so, these financing needs may be modest enough to fit within existing small and medium-sized enterprise (SME) portfolios. 

  1. Trade finance for fish-feed importers

Domestic fish-feed production will take time to expand. High-quality extruded feeds require formulation, manufacturing technology, quality control, and scale. Kenya’s experience illustrates these barriers. Take the Unga Group, for instance. One of the country’s long-established grain and animal-feed businesses, it expanded its feed business through a partnership with Nutreco to establish Tunga Nutrition Kenya and expand fish-feed production at its existing Nairobi plant. The partnership combined Unga’s local manufacturing and distribution network with Nutreco’s feed expertise and technology, increasing the capacity to produce fish feed locally. 

Meanwhile, importers and distributors must place bulk orders, clear consignments, carry inventory, and wait for payment from customers whose cash flows follow production cycles. 

These cash-flow gaps create a sizeable need for trade finance. Kenya imports about 7,000 tons of aquafeed annually, equivalent to roughly one-fifth of the country’s estimated annual feed demand of 34,000 tons. With published feed-cost benchmarks of about USD 850–950 per ton and more recent commercial feed prices averaging around USD 1.24 per kilogram, the value of inventory moving through this part of the value chain is substantial.  

Importers must finance bulk orders, freight, clearance, and inventory before recovering those costs through sales to distributors and farmers. Bank guarantees, letters of credit, and other trade-finance instruments could help established importers bridge that period, while lenders assess supplier reliability, currency exposure, inventory risk, off-take arrangements, and receivables. 

Fisheries finance requires a portfolio 

Across these seven use cases, fisheries finance requires a portfolio of distinct products. The mix should include short-term working capital for feed suppliers and traders, longer-tenor production finance for hatcheries and farmers, asset finance for processors and cold-chain businesses, and trade-finance instruments or guarantees for importers. 

Capital alone is unlikely to close the gap. A financial institution can design a suitable product and still struggle to find enterprises with reliable records or visible cash flows. A fisheries business may become more productive yet remain invisible to lenders that do not understand its operating cycle. The opportunity lies in matching the right capital and tenor to businesses that can use them productively. 

MSC’s analysis of youth entrepreneurship and financial inclusion reinforces this point: Finance and enterprise support must move together. Either one has limits without the other. 

The final blog in this series looks beyond Kenya. It examines how the African Continental Free Trade Area is expanding regional fisheries trade opportunities and what financial institutions need to finance cross-border flows. The answer to the opening question remains clear: Capital should go to enterprises with viable markets, visible cash flows, and financing structures that fit how they operate. 

The financing opportunity inside Kenya’s fish supply gap

Kenya’s fish market has a sizable supply gap. In 2024, the country produced 168,424 metric tons (MT) of fish, enough to meet about one-third of its estimated annual requirement of 510,000 MT. 

The remaining gap, roughly 342,000 MT, represents about two-thirds of the estimated demand. For lenders, that scale raises a crucial question: how much can viable domestic fisheries businesses supply, and what finance would help them grow? 

For financial institutions, that distinction matters. The opportunity extends beyond financing businesses that serve Kenya’s current production base. It also includes viable hatcheries, producers, input suppliers, traders, processors, and cold-chain businesses that can help close part of the supply gap. 

The two-thirds gap does not automatically define a bankable market. Affordability, consumer preferences, infrastructure, production constraints, and market access determine how much potential demand becomes actual sales. Still, the gap’s scale suggests that the financing opportunity could extend well beyond the businesses currently visible to formal lenders. 

As the first blog in this series argued, the gap in Africa’s USD 22 billion fisheries sector presents a development challenge and a potential commercial opportunity for financial institutions that understand how different parts of the value chain operate. 

A large gap between potential demand and domestic supply 

Kenya’s fish production is struggling to meet demand. Lake Victoria landings fell 29.9% between 2021 and 2024 amid overfishing and habitat degradation. 

Kenya currently fills part of its fish supply gap through imports, using foreign exchange on a protein source that it has the land, water, and workforce to produce domestically. 

How can domestic producers capture more of this demand? The answer depends on how much local supply can grow and what capital will enable that growth. 

Expanding domestic production could reduce import dependence and create opportunities throughout the fisheries value chain. 

Cage farming in Lake Victoria shows how quickly managed production can reach meaningful scale. In 2024, Kenya had 5,975 operational cages managed by 634 farmers. These cages produced approximately 25,547 MT of fish and accounted for 76.4% of the country’s total aquaculture production of 33,423 MT. 

Scaling fisheries production involves far more than adding cages. Farmers need fingerlings and feed. Hatcheries need equipment and working capital. Traders need liquidity to purchase fish, while processors and distributors need cold-chain infrastructure. Each business has a distinct investment cycle, cash flow, and risk profile. 

Expansion, therefore, creates a series of distinct financing needs across the value chain. 

One value chain, very different capital needs 

MSC’s market study under the Women and Youth Economic Empowerment in Fisheries through Inclusive Market Access (WYEEFIMA) program, implemented by TradeMark Africa and the African Continental Free Trade Area (AfCFTA) Secretariat in partnership with the Mastercard Foundation program, illustrates this diversity. 

MSC’s research identifies nine fisheries value-chain actor profiles whose capital needs range from KES 1,833 (about USD 14) for a micro-retailer to KES 15.2 million (about USD 117,000) for a commercial hatchery. 

These differences matter for lenders. A lender cannot finance a trader seeking short-term working capital to purchase fish in the same way it finances a hatchery investing in equipment with a multi-year useful life. Similarly, a cage farmer’s repayment schedule must reflect an eight-month production cycle rather than the repayment pattern of a conventional retail business. 

Yet, formal finance reaches only a small share of these enterprises. MSC’s WYEEFIMA research estimates formal credit access at 9% among women and 14% among youth in Kenya’s fisheries sector. The study also found that some actor groups, including fish traders and seaweed farmers, rely heavily on informal finance. 

These enterprises have identifiable capital needs, yet formal lenders have not reached many of them. 

What early lending data shows 

Does additional finance help these enterprises generate enough income to justify greater lender interest? 

Early data from participating financial institutions (PFIs) in the WYEEFIMA program offer an encouraging signal. The analysis associates each additional unit of capital provided to fisheries enterprises with about 7.3% additional monthly enterprise income. The relationship became statistically significant within six months. 

In practical terms, every USD 1 of additional capital was associated with approximately USD 0.07 in additional monthly enterprise income. That equals about USD 0.88 over 12 months if the estimated monthly association persisted. 

Employment data points in the same direction. Between August 2025 and February 2026, 115 fisheries borrowers in the program generated 63 jobs, or about 0.55 jobs per borrower. Among borrowers who received loans above KES 100,000 (USD 771), the observed ratio was 1.33 jobs per borrower. 

The sample remains relatively small, so the pattern deserves further study as more lending data becomes available. Lenders often view larger fisheries loans primarily as a greater exposure risk. The WYEEFIMA data raises another question: could some fisheries enterprises productively absorb larger loans than lenders currently offer? 

Why lenders need a portfolio of fisheries products 

No single standardized product can close the gap. 

Closing part of Kenya’s supply gap requires different forms of finance across the value chain. Traders and input suppliers may need short-term working capital. Hatcheries and producers may need longer-tenor loans. Cold-chain operators and processors may need asset finance for equipment. Larger businesses may need trade finance or guarantees to purchase inputs at scale. 

Digital credit can meet some short-term liquidity needs. It cannot finance the full range of investments required to expand production and move more fish efficiently to market. 

For financial institutions, the opportunity lies in building a portfolio of financing solutions matched to how fisheries businesses operate. 

Yet this opportunity brings risks that lenders may struggle to assess or price. Some businesses have limited formal transaction histories or conventional collateral. Seasonal cash flows may also conflict with standard monthly repayment schedules. Capital alone cannot solve these problems. 

What can help lenders enter the sector? Better transaction data, alternative collateral approaches, guarantees where appropriate, and products structured around fisheries cash flows and production cycles can help lenders assess and manage early risks. 

Why the timing matters 

Kenya’s supply deficit is already evident, and pressure on wild-catch fisheries is increasing the importance of aquaculture and other forms of managed production. Cage farming demonstrates that aquaculture can produce at a meaningful scale when producers have suitable production systems, inputs, markets, and capital. 

Financial institutions that enter the sector now can begin building transaction histories, sector knowledge, underwriting experience, relationships with viable fisheries businesses, and portfolio data that later entrants will still need to acquire. 

Yet Kenya’s supply gap alone does not justify lending. A commercial case emerges when lenders identify businesses that can use capital productively, understand their cash flows, and structure finance around the risks they carry. 

WYEEFIMA’s early evidence suggests that such opportunities exist across the value chain and at widely different ticket sizes. For a financial institution sitting across the table from a fisheries client, the practical question is: where can it deploy capital productively, which enterprises are ready, and what products fit their operations? 

The third blog in this series examines that question through seven concrete financing use cases across the fisheries value chain. It explains how MSC works on both sides of the financing equation to make formal-sector entry viable. The lesson here is clear: Kenya’s supply gap becomes a financing opportunity only when lenders match the right capital to viable businesses across the value chain.