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The policy paradox at the heart of Bangladesh’s digital finance story

Posted on by harshita

Bangladesh Bank has mandated that 50% of agent-banking representatives must be women, while fewer than 3% of the country’s MFS agents, the channel that handles the lion’s share of daily cash-in, cash-out, remittance, and G2P transactions, are female.

Bangladesh stands at a critical inflection point in its digital financial services (DFS) journey. Agent banking and mobile financial services (MFS) have transformed the country’s financial landscape, taking formal transactions to millions of households and building one of the most extensive last-mile service architectures in South Asia.

Today, MFS channels  operate through over 1.5 million agents and support more than 200 million registered accounts, while agent banking has grown to over 16,000 agents and more than 21,000 outlets serving customers across all districts. Yet within this achievement lies a structural imbalance: Bangladesh Bank has mandated that 50% of agent-banking representatives must be women, while fewer than 3% of the country’s MFS agents, the channel that handles the lion’s share of daily cash-in, cash-out, remittance, and G2P transactions, are female.

This mismatch is more than policy oversight; it represents a deeper market design challenge. The gender mandate applies only to the smaller, slower-growing agent-banking channel, while the much larger MFS ecosystem remains almost entirely male. Women now hold 42% of the total 239.3 million registered MFS accounts, yet have almost no representation among the frontline providers who shape trust, privacy, grievance resolution, and usage. Representation at the last mile is not symbolic; it determines whether women can transact confidently and independently.

What appears to be a simple representation gap is, in reality, a question of whether the architecture of Bangladesh’s digital economy is built to recognise women as full economic actors. It echoes a broader global ambition to advance women’s empowerment, expand decent and dignified work, and strengthen inclusive, resilient digital infrastructure (SDG 5, SDG 8, SDG 9). And it raises a fundamental question: Can a digital economy be truly inclusive if women are consumers but not providers of financial services?

Why women agents matter 

The absence of women at the frontline reinforces gender gaps in trust, privacy, and confidence-patterns consistently observed in global evidence from India, Nigeria, and East Africa, as well as in recent women-led agent pilots in Bangladesh. Female agents build trust, improve customer retention, and help convert dormant or irregular women users into active ones, while reaching segments male agents often struggle to serve: young women, new mothers, informal entrepreneurs, and socially restricted female household members.

They also strengthen operational reliability, with lower churn and higher adherence to service standards, directly benefiting providers. Most importantly, women agents expand women’s economic agency, offering one of the most accessible pathways into formal entrepreneurship, digital capability, and income generation.

The constraint stack

Women’s exclusion from MFS agent networks is not driven by a lack of interest or capability; it stems from how the wider financial and retail ecosystem is structured. The MFS agent model in Bangladesh was built around male-owned retail shops, high-mobility cash cycles, and regulatory frameworks that do not monitor or incentivise gender-balanced networks. These sector wide design features interact with women’s lived realities-mobility constraints, discomfort in male-run environments, lower smartphone access, and household negotiations around public-facing work to produce a pipeline that few women can enter and even fewer can sustain. In effect, the system functions as if women were never intended to be agents.

The table that follows breaks these constraints down into the structural touchpoints where the exclusion becomes most visible:

Beyond the myths: Interrogating provider assumptions

Provider concerns about onboarding women agents: liquidity pressure, footfall, security risks, and training costs are rooted in practical realities. But these issues are not isolated barriers; they are symptoms of a wider lifecycle design that was built around male norms. At every stage of the agent journey i.e. selection, onboarding, training, day-to-day operations, and long-term sustainability, the system assumes a male agent: one with high mobility, ownership of formal retail space, access to documentation, and freedom to engage in public-facing commercial activity. When these assumptions go unquestioned, women appear “unsuitable,” when in reality the model itself is exclusionary.

The belief that “women don’t apply” simply mirrors limited entry pathways: providers recruit through male retail networks and offer training environments misaligned with women’s mobility and safety needs. Concerns about commercial viability assume that only market-center, high-footfall outlets are profitable; yet women-led outlets in community settings often deliver higher trust, deeper engagement, and lower churn, key drivers of sustainable profitability.

Liquidity challenges attributed to women arise from an operating model that depends on constant mobility. Once that model is adapted through micro-float credit lines, shared liquidity pools, or periodic cash-support women manage liquidity as effectively as men. And while onboarding women may require more tailored support at the outset, women agents consistently exhibit stronger compliance, lower misconduct, and greater operational stability, which reduce supervisory costs over time.

The evidence is consistent across markets: the perceived weaknesses of women agents are, in fact, weaknesses in a system that was never designed with women in mind. When the operating model shifts even slightly to reflect women’s realities, the business case strengthens rather than weakens.
Cross-country learning: What Bangladesh can actually borrow

Bangladesh is not alone in grappling with a stark gender gap in agent networks. Several countries have already experimented with ways to bring more women into frontline roles, and while contexts differ, three concrete lessons stand out from documented practice.

First, dedicated women-agent pipelines work when they are built through existing women’s networks.

In India’s BC Sakhi programme, state rural livelihood missions identify self-help group (SHG) members and train them as banking correspondents to serve their own communities. The “One Gram Panchayat, One BC Sakhi” mission in Uttar Pradesh has onboarded tens of thousands of women as village-level banking agents and channeled millions of transactions and significant commission income to them. This model shows that when recruitment is routed through women’s collectives, ot just existing retail shops, women agents emerge at scale and are able to serve as a trusted financial touchpoint in rural areas.

Second, access to working capital and liquidity support is a binding constraint but is a solvable problem.

Research on female cash-in, cash-out agents in Nigeria highlights that women’s ability to become or remain agents is heavily shaped by their access to startup capital and ongoing float, even when they have the skills and demand exists in their communities. The MicroSave study argues for bundled solutions: appropriate credit, business support, and liquidity tools tailored to women. Similarly, work on DFS agents in Indonesia shows that lending to agents using their digital transaction history as a basis represents a large, under-tapped opportunity and suggests that structured working-capital products for agents can strengthen network performance overall. While not always designed exclusively for women, these experiences demonstrate that capital and float are design variables, not fixed barriers: when providers and lenders intentionally create agent-focused credit solutions, entry for women becomes more feasible.

Third, there is evidence that women agents change how customers use and trust digital finance.

Experimental and observational work from African markets shows that women often express higher levels of trust when interacting with female agents and may be more willing to share information or seek help in such settings. Studies on agent banking find that women appear more willing to engage with other women in transactional settings, suggesting that the availability of female agents can increase comfort and uptake among female customers. These findings are consistent with global work on women’s digital financial inclusion, which emphasises that representation at the frontline is a key factor in moving from account ownership to active, confident usage.

Taken together, these experiences do not offer a single template that Bangladesh can copy, but they do point to three robust design principles:
•    build women-agent pipelines through women’s organisations and livelihood networks;
•    treat working capital and liquidity as solvable design problems, not reasons to exclude women; and
•    recognise that women agents can materially shift trust and usage patterns, especially for women customers.

Policy roadmap: Building a gender-inclusive agent network for Bangladesh

Bangladesh can break the <3% barrier in women’s MFS agents, but only with a coordinated shift in policy, provider design, and ecosystem partnerships. Three strategic levers matter most.

1. Regulatory realignment: Introduce gender-responsive MFS agent guidelines, require sex-disaggregated agent reporting, and extend the spirit of the agent-banking mandate to digital channels. Simplify KYC and licensing for home-adjacent women-run outlets and incentivise providers through supervisory nudges tied to network diversity, safety, and service quality.

2. Provider-level design shifts: Recruit through women-focused networks i.e. MFIs, NGOs, SHGs rather than male retail channels. Deploy gender-sensitive training, safe training venues, and community-based outlet models. Introduce agent working-capital tools (micro-float credit lines, shared liquidity pools) and redesign incentives to reward trust, compliance, and customer retention.

3. Ecosystem investments: Fund district-scale demonstration pilots, blended-finance guarantees for women-agent float, along with digital- and business-literacy pathways. Partner with women-centric MFIs to identify, onboard, and mentor women agents at scale.

A gender-inclusive agent network is not a social add-on; it is core digital infrastructure for Bangladesh’s next stage of financial inclusion.

Rebuilding inclusion from the frontline

Bangladesh’s digital finance journey shows that access alone does not produce inclusion; the architecture of participation matters. Women are central to the digital economy as users and earners yet structurally absent from the frontline. Rebalancing this requires redesigning recruitment, capital support, and incentives so that women can participate not as exceptions, but as a standard part of the agent network.

This article was first published on “The business standard” platform on 18th December 2025.

The Digital Public Infrastructure Readiness Report

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This report is drafted on behalf of the Nigeria Governance Forum (NGF) to assess the readiness of 37 Nigerian states to utilize the DPI approach in public service delivery. Following this, we developed state-specific roadmaps tailored to each state’s current DPI maturity to facilitate their inclusive digital transformation. This report reflects our year-long collaboration with Nigerian states, during which we identified strengths and weaknesses across digital identity systems, interoperable payment systems, data exchange platforms, and foundational connectivity infrastructure.

Connecting innovation, institutions, and the missing middle: Insights from the 2025 Nobel for building labs and market creation

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A seismic shift emerged in how we view society and civilizational progress when Philippe Aghion, Peter Howitt, and Joel Mokyr received the 2025 Nobel Prize in Economic Sciences. The trio reminded the world that innovation results from deliberate design, not luck. Their collective work explains why societies grow when they enable new ideas to replace old ones. This process, and its dependencies, lies on entrepreneurs, innovators, and on institutions that learn, compete, and collaborate. 

The Nobel Prize feels personal for those who are building innovation labs and market-creation programs. It validates the messy, iterative work to incorporate startups into bureaucracies, align funders and regulators, and turn pilots into real markets. It tells us that the job is to design systems that enable continuous innovation rather than to simply “do innovation.” From this research, we can draw three vital lessons that link with MSC’s work in the startup space under our Startup Innovation and Acceleration (SIA) team. 

Lesson 1: Innovation requires institutions that learn: Joel Mokyr’s research shows that economic progress occurs when societies build institutions that value useful knowledge and share experiments, failures, and cumulative lessons rather than hiding them.

The Bihar Krishi digital platform embodies this spirit. Developed in collaboration with the Bihar Agriculture Department in India, Bihar Krishi is among MSC’s leading innovation-lab projects. It has unified 50-plus government programs and services for more than 750,000 smallholder farmers within 18 months of launch. The platform has transformed a state department into a living digital entity that continually learns and builds institutional muscle beyond technology. The department now has its own innovation cadence, which intends to expand toward 4 million farmers through AI-driven advisory, market linkage, and financial services modules. 

Bihar Krishi offers three simple yet profound takeaways for any innovation lab. 

The lab must capture lessons as deliberately as it funds experiments; 

Every pilot should leave behind codified knowledge, whether templates, APIs, procurement notes, or data taxonomies, which reduces the cost of the next experiment; 

Innovation without institutional memory is mere performance art. 

Lesson 2: Creative destruction needs safe spaces to function: If we move to the work of Mokyr’s partners, Phillippe Aghion and Peter Howitt, the core idea of creative destruction can sound brutal. Yet, the essence of creative destruction is renewal. New ideas must be allowed to challenge the old, or progress stalls. For governments, banks, and large agencies, this is uncomfortable territory.

Yet, when we examine initiatives, such as the FPS Sahay program in India, we see a controlled pathway for responsible innovation. FPS Sahay enables fair price shop (FPS) entrepreneurs to access invoice-backed digital working-capital loans and allows FinTechs to pilot alternative approaches within a supervised setting. The platform is the brainchild of the Small Industries Development Bank of India (SIDBI) and the Department of Food and Public Distribution, with technical support from MSC (MicroSave Consulting).  

The FPS Sahay program carved new credit pathways for 60 entrepreneurs in the pilot phase. Post-pilot discussions are underway to explore the potential to scale to 500,000 microenterprises and create a policy pathway for embedded finance.  

The lesson is that labs must make room for controlled disruption, which helps simplify onboarding for innovators, provides clear “go or no-go” decision gates, and includes honest sunset clauses. This structure enables pilot programs that do not work to end smoothly, and those that do work to scale quickly. Institutions need permission structures to let new programs replace old ones without fear. 

Lesson 3: Markets require active engineering: Innovation fails when the ecosystem is unprepared to absorb it. Mokyr’s “useful knowledge” meets Aghion-Howitt’s “competition” only when markets, regulation, and capital align. This is the key logic of MSC’s SIA team’s market-creation stream, which works to design accelerators, challenge funds, and centers of excellence (CoEs). Together, these mechanisms serve as vehicles to engage with innovators, absorb new business models or systems of product and service delivery, shape demand, and unlock private investment around complex public problems. 

The Financial Inclusion Lab (India), co-built with IIMA Ventures and MSC, exemplifies this approach. It brought 49 startups, mostly FinTechs, into the same room as regulators, investors, and banks, to translate sandbox pilots into investable ventures. Those startups went on to raise USD 250 million in follow-on capital and reach 45 million low-income customers.

The lab accelerates startups that engineer a market for inclusive finance, much akin to what the Nobel trio modeled theoretically. 

The design rule is clear for innovation labs elsewhere. The priority is to build the ecosystem handholding, which includes regulatory dialogue, data interoperability, and blended-finance pools, before private markets can scale solutions. These three lessons inform the efforts of the SIA practice at MSC, which works on two interconnected fronts: 

  1. Institutionalinnovation labs:We help governments, banks, and public programs create arm-length labs that change how they learn, procure, and deliver by testing solutions safely, working with startups, and building institutional capability. 
  2. Market-creation programs (accelerators, challenge funds, andCoEs):These programs shape demand for new solutions in a sector. They allow institutions to engage with innovators, absorb new business models, and direct private capital toward complex public problems. 

Institutional labs improve how a single institution learns and delivers. In contrast, market-creation programs establish the broader ecosystem conditions of demand, capital, and partnerships that individual labs cannot achieve on their own. 

When these two fronts connect, institutional labs validate what works, while market-creation programs help scale these solutions. The resulting market signals feed back into labs with new data and partners. This feedback loop, what Nobel economists call cumulative innovation, is how experimentation grows into a system. 

Why does it matter now? 

Whether we discuss climate adaptation, farm productivity, or AI for public purposes, the challenge is not a shortage of ideas but rather a shortage of systems that allow ideas to survive in contact with reality.

As the Bihar Krishi Digital Platform digitizes agri-services, FPS Sahay rewires credit for microentrepreneurs, and Financial Inclusion Lab alumni expand access to digital finance. Together, these programs offer glimpses of the decade ahead. This future shows innovation anchored in institutions, scaled through markets, and continuously improved by ecosystem feedback. This is good economics and good governance that proves how creative destruction becomes constructive inclusion. 

Today, institutions spend trillions yet innovate with decades-old capacity. In this scenario, MSC’s SIA practice has a clear mandate. Our mission is to build labs that turn experimentation into permanent capability and markets that make innovation inevitable. That is the heart of SIA’s mission and exactly what this year’s Nobel prize reminded us to keep doing. 

The Intelligent Revenue Authority Readiness Report

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This report evaluates the digital public infrastructure readiness of revenue authorities across Nigeria’s 36 states and the FCT using the Intelligent Revenue Authority (IRA) framework. It analyzes maturity across person-to-government, business-to-government, and government-to-government payment systems, highlighting significant variation in digital adoption. While some states demonstrate advanced integration, automation, and data use, many rely on manual processes and fragmented systems. The report proposes phased, state-specific roadmaps to strengthen interoperability, automation, digital governance, and human capacity, aiming to improve revenue mobilisation and service delivery.

Timely Wages, Trusted Payments: Smart Payments for Urban Livelihoods

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Urban livelihoods in India are predominantly informal, leaving workers vulnerable to insecure employment and limited social protection. This vulnerability was starkly exposed during the COVID-19 pandemic, when millions of migrant and low-income urban workers faced sudden income losses. The Housing and Urban Development Department (H&UDD) of the Government of Odisha responded to this crisis by working with existing community networks to create mass employment opportunities for the urban poor, informal, and migrant laborers. While MUKTA provided a critical safety net, its effectiveness was undermined by severe delays in wage payments to beneficiaries. These challenges undermined the intended outcomes of MUKTA. They not only strained workers’ livelihoods but also resulted in weak fiscal accountability at the urban local body (ULB) and state levels.  

To address these challenges, MSC, in partnership with the state government, designed and implemented a scalable Smart Payments Solution (SPS).  The solution combined a digital program management platform, MUKTASoft, with a just-in-time funding system. MUKTASoft digitized every stage of scheme implementation using a rule-based smart payments engine. The JIT funding mechanism ensured that funds were released directly from the state treasury to beneficiaries’ bank accounts.   

The pilot implementation of SPS delivered substantial results. Wage delays were reduced, approval times fell sharply, utilization certificate pendency dropped to zero, and overall fund management efficiency improved. Women SHG members also reported faster receipt of payments, reduced administrative burden, and greater financial independence. The success of the pilot led to the statewide rollout of SPS across all ULBs in Odisha. This case study demonstrates how smart payments, grounded in sound public financial management principles, can improve welfare delivery systems, and strengthen livelihood outcomes for urban informal workers at scale.

Performance over assets in Bangladesh’s credit reform

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In this three-part series, we scrutinized the shift toward multiple credit bureaus for financial service providers (FSPs) in Bangladesh. The first part discussed the implications of the framework for multiple credit bureaus, while the second part focused on regulators and development partners (DPs). In this final part, we examine market incentives and global lessons that show how a multi-bureau system can drive financial inclusion on a large scale. 

The multi-bureau reform enables Bangladesh to shift from a collateral- and relationship-based credit identity to a performance-based one. This change creates opportunities for MSMEs, informal workers, and new borrowers who previously struggled in the formal financial system. 

Private credit bureaus can expand the basis to assess creditworthiness for these segments of borrowers, as they primarily assist borrowers without formal income documentation or collateral. While many low-income households and informal workers repay their debts reliably, their financial discipline remains hidden within single lenders.  

Alternative data, such as mobile money transactions and utility payments, holds immense potential to serve such thin-file borrowers. However, the near-term priority for the regulator and the market must remain on standardizing and ensuring full-file reporting of traditional credit data from banks, MFIs, and cooperatives. Alternative data can only strengthen scoring after this core foundation becomes robust and reliable, which means its full utility is a second-stage integration.  

When bureaus participate in the credit ecosystem, they make repayment history portable across the financial sector. This portability allows lenders to evaluate borrowers based on their repayment track record rather than their physical assets. The transition enables gradual increases in loan size over time. Eventually, as borrowers build their credit profiles, they can then move from microfinance products to formal enterprise loans. This progression represents a fundamental shift in how financial institutions view the creditworthiness of customers in emerging markets. 

Most lenders globally treat bureau scores as only a first-level filter in their decision process. This initial screening may restrict credit access for borrowers with limited credit histories and thin credit files for lenders to assess their creditworthiness accurately. Still, borrowers typically can access more credit over time, as their data becomes richer and more comprehensive. The challenge lies in how consistently the market applies these scores and filters rather than rely solely on credit scores. 

For Bangladesh, consistency has emerged as a more critical issue as the country moves forward with its reforms. The Bangladesh Bank issued letters of intent (LoI) to five companies to form credit bureaus: Creditinfobd, TransUnion, bKash Credit, First National Credit, and City Credit. Later, TransUnion and bKash announced that they would establish a joint company, which reduced the number of credit bureaus to four. These four private bureaus will now enter the market with different methodologies.  

Consistency will be paramount for the market to trust this multi-bureau system. This depends on three core elements: 

  • Data definitions: The exact borrower attributes being captured and reported, such as loan type, repayment status, and delinquency buckets; 
  • Weighting logic: How different variables, such as repayment behavior, outstanding exposure, and frequency of defaults, are weighted within the score; 
  • Score calibration: How raw risk estimates are translated into standardized score ranges so that scores are comparable and predictive. 

If the scoring models diverge significantly, lenders may over-rely on the most conservative scores available. They may also avoid bureau insights altogether and return to traditional assessment methods, which include requiring collateral, relying solely on fixed income in the form of pay stubs, or using manual relationship-based assessments. This outcome would limit the benefits for low-income and MSME borrowers who need these new pathways the most. 

The Bangladesh Bank maintains direct oversight over the scoring process to prevent this fragmentation. These regulatory safeguards are central to consistency and consumer trust: 

  • Mandatory model approval: The central bank requires mandatory model approval for all credit bureau scoring methodologies. 
  • Non-discriminatory scoring: Guidelines explicitly prohibit the collection of sensitive attributes, such as political affiliation or religious beliefs, to prevent bias. 
  • Score as a filter: A critical protection mandates that lenders cannot rely solely on a bureau’s score; it must be used as only one structured input among others in the credit decision process. 

The impact of this bureau reform also depends on the digital readiness of lenders across the market. Smaller FSPs with manual data workflows struggle with consistency and timeliness. Borrowers cannot fully use their reputation capital when technical limitations obscure credit history. The infrastructure must support seamless data exchange to realize the reform’s full potential. 

True inclusion requires the definition of creditworthiness to expand beyond formal loan repayment data. The system must incorporate behavioral indicators, such as mobile money patterns, utility payments, and savings behavior. These indicators accurately reflect financial reliability in informal settings where traditional credit histories are absent. The challenge lies in how bureaus translate diverse data sources into robust models that lenders will trust. 

Pakistan offers relevant examples through platforms, such as Jumo and JazzCash, which use mobile money transaction patterns to determine internal credit scores. Bangladesh can adopt similar approaches where bureaus recognize financial progress through non-traditional indicators.  

Similarly, Africa offers valuable lessons from credit bureau transitions. If participation remains uneven, a “two-speed” credit market emerges. Global lessons, particularly from Tanzania and Kenya, demonstrate that when reporting is mandatory only for banks and not fully integrated by MFIs, credit discipline improves in the formal sector. However, this change merely shifts over-indebtedness to the segments that remain unreported. This is the key risk for Bangladesh in terms of financial stability.  

If MFIs and cooperatives lag in both reporting and the use of bureau data, credit risk migrates into unregulated segments. Bangladesh must address this immediately to ensure the reform strengthens the financial sector. 

Tanzania and Kenya saw banks adopt bureaus early, but microfinance institutions (MFIs) and savings and credit cooperative organizations (SACCOs) lagged significantly. This gap shifted over-indebtedness problems to unreported segments. Meanwhile, Ghana shows that broad visibility across all lender types is achievable. The country sequenced onboarding by institutional capacity and provided smaller lenders with dedicated technical support.  

Bangladesh must integrate MFIs and cooperatives early in the implementation process to prevent a two-tier system where only formal banks benefit from shared data. The integration should follow a phased approach that starts with standardized batch submissions. The system can transition to real-time API checks as capacity improves. 

Comparative lessons from the implementation of credit bureaus in Africa 

Source: Created by MSC with inputs from Maxwell Investment Group and Zeeh 

Credit bureau pricing structures must support high-volume, small-ticket transactions that characterize MSME and microfinance markets. Per-inquiry fees discourage routine use by MFIs and merchant lenders, which operate on thin margins. Volume-based or institutional flat-rate models support regular bureau checks without prohibitive cost barriers.  

Beyond access fees, bureaus must provide decision-ready intelligence over raw data dumps. They should deliver standardized scorecards and risk dashboards that help lenders apply bureau information meaningfully in their underwriting processes. Many smaller lenders lack the technical capacity to build proprietary models from scratch.  

Regulatory authorities and governments must establish consumer protection frameworks alongside technical infrastructure. Kenya’s experience shows that negative-only systems can entrench exclusion rapidly when borrowers cannot recover from mistakes. Borrowers must have clear rights to access, dispute, and correct their records. Improved data infrastructure alone will not automatically change credit decisions in the market. FSPs must treat bureau information as a primary input that actively influences loan amounts, interest rates, and repayment terms.  

A major tension in the transition is between regulatory enforcement (reporting data) and voluntary participation (using data). Specifically for MFIs and high-volume digital lenders, cost and workflow friction often drive this tension. If bureau access is priced per inquiry or per user, institutions may report data to comply with regulations but limit bureau checks in practice, which would render the bureau a passive repository rather than a live decision-making tool.  

Regulators must, therefore, establish a supportive pricing model, such as volume-based or institutional pricing, which makes high-frequency, low-cost access viable for all lender segments to ensure lenders use the bureau in underwriting. 

Regulators, DPs, and FSPs must prioritize three critical elements in their execution:  

  1. Ensure broad participation across all lender types from the start;  
  1. Establish strong data standardization that creates consistency across bureaus;  
  1. Enforce proactive consumer protection measures to build trust in the system.  

The success of Bangladesh’s multi-bureau system depends on operational choices and specific implementation plans, rather than broad policy goals. The sequence of implementation matters more than the speed of rollout. If made sensibly, these coordinated efforts will unlock the full potential of Bangladesh’s credit bureau reform and carve pathways to financial inclusion for people who have been excluded for far too long.