Objectives of this project

The primary objective of this project is to support the Central Bank of Kenya (CBK) in the design of an open finance framework for Kenya. The objective of the diagnostic study is to assess the preparedness of Kenya’s financial sector, regulatory and policy environment, and other necessary elements for the implementation of open banking/open finance. The study will provide a comprehensive analysis of the country’s financial ecosystem, develop an implementation roadmap, and provide specific recommendations on the design of a robust framework for open banking/open finance tailored to Kenya’s unique environment and the policy objectives of the CBK.

As a secondary objective, the vendor will support CGAP’s objectives of public knowledge generation by leveraging the work done to inform the development of a guide on how to apply the Key Considerations for Open Finance recently published by CGAP, the BIS, IMF, UNSGSA and World Bank.

Scope of Work

1)      The diagnostic study is expected to cover:

a)       Policy objectives

•      Define the key policy objectives for open banking/open finance in Kenya and the barriers in the current financial ecosystem open finance will address.

•      Determine the enabling elements needed for open banking/open finance to achieve key policy objectives, including parallel initiatives which could strengthen the impact of open banking/ open finance (e.g. the Fast-Payment System)

•      Explore opportunities and high-potential use cases in banking, payments, credit, investments, insurance, and pensions to support these objectives.

•      Identify the financial service providers needed to participate in open banking/open finance in order to achieve the desired objectives, assess their readiness and willingness to open banking/open finance, and any challenges associated with their participation.

b)      Legal and Regulatory Review

•      Evaluate existing laws and regulations to determine if CBK has the necessary mandate and powers to lead open banking/open finance implementation.

•      Identify complementary laws and regulations outside of CBK’s mandate which could support open banking/open finance implementation, and the relevant authorities to engage.

•      Identify and recommend changes to the regulatory framework required to accommodate the needs of an open banking/open finance framework.

•      Examine and identify any existing initiatives in the EAC region on Open Banking/Finance.

c)       Technical Capacity and Infrastructure

•      Assess the technical capacity of the financial ecosystem for secure and scalable API-based data sharing, identifying gaps in current practices, infrastructure, and capabilities.

•      Identify and assess any open banking/open finance initiatives undertaken or ongoing by the key stakeholders.

•      Identify the technical standard and technical architecture Kenya should adopt, based on global practices and local market context.

•      Determine the roles the public and private sector will take in developing the ecosystem’s APIs.

•      Review the adequacy of digital public infrastructure to support open banking/open finance and propose required changes.

•      Analyze successful global implementations to extract relevant lessons and adaptable models for Kenya.

d)      Governance and Stakeholder Collaboration

•      Determine the governance arrangements needed to support the objectives of open banking/open finance in Kenya.

•      Propose a governance model for open banking/open finance, with defined rules of participation, roles and activities for regulators and industry players, as well as decision-making and oversight processes

•      Outline strategies for CBK to foster collaboration among stakeholders to ensure effective implementation of open banking/open finance governance.

•      Develop draft policies and rules for open banking/open finance in key areas of governance, including, but not limited to: Data types and formats, quality and access standards, accreditation and liability frameworks, reciprocity, pricing and monetization, and dispute resolution.

e)      Oversight and supervision

•      Assess the current mandate, enforcement powers, capabilities and resources of CBK and other authorities to supervise ecosystem participants effectively.

•      Identify risks and challenges associated with open banking/open finance and propose mitigation strategies.

•      Recommend an oversight and supervision framework for open banking/open finance, including areas for oversight and responsibilities for oversight of different authorities, as well as appropriate RegTech tools for effective supervision of participants in the open banking/open finance ecosystem.

f)        Consumer protection and data protection

•      Review data privacy and protection and consumer protection regulations and determine any modifications, expansions, or further guidance needed to align existing frameworks and regulations to open banking/open finance.

•      Propose strategies to generate customer awareness and trust to support adoption of the open banking/open finance ecosystem, with particular consideration for the participation of vulnerable segments.

g)       Implementation Roadmap

•      Develop a phased implementation plan for open banking/open finance, detailing key requirements, technical needs, and short-term, medium-term, and long-term milestones.

2)      The general guide on how to apply the Key Considerations for Open Finance should cover the 10 key elements presented in the report: Objectives, Process Leadership, Governance, Regulation, Oversight and Supervision, Consumer and Data protection, Consumer information and awareness, Participation, Technical Infrastructure and Architecture, and Pricing. The guide will complement the report by offering practical recommendations and examples for countries looking to apply the key considerations.  The vendor is expected to produce a draft and would not be responsible for the copy-editing or design of the guide.

Methodology

The vendor will be expected to adopt a mixed methods approach which will include desk research as well as direct engagement with public and private sector actors in Kenya. Direct engagement can involve one-on-one interactions and the facilitation of group discussions. CGAP expects the work to require at least three in-person convenings: (1) to launch the effort and define the policy objectives; (2) to gather input from industry participants on the preliminary design; and (3) to present and discuss the recommendations produced.

Deliverable(s)

The diagnostic will deliver a comprehensive report including: a detailed analysis of Kenya’s financial services ecosystem, policy reform areas to enable open banking/open finance, insights and learnings from international case studies and policy frameworks relevant to Kenya, and clear recommendations on rules, technical requirements, and infrastructure necessary for a successful open banking/open finance ecosystem.

The findings will be validated through feedback from policymakers, industry, and civil society, ensuring the diagnostic reflects a consensus-driven approach. The final report will include actionable recommendations and a roadmap for the Central Bank of Kenya and other stakeholders, setting the stage for a transformative and inclusive financial future for Kenya.

The consultant will deliver the following specific outputs:

a)       Project launch and objectives-setting workshop

Convening of relevant stakeholders to define objectives of open banking/open finance and build buy-in to consultation process.

b)      Inception Report

A comprehensive inception report detailing the planned activities for the diagnostic. It will include:

•      A detailed workplan, approach, and methodology.

•      Refined set of research questions which address the objectives of the diagnostic study and will be addressed through the diagnostic.

•      Data collection and stakeholder consultation process, including plans for conducting in-person meetings and workshops.

•      Clear deliverables and timelines for all activities.

c)       Capacity building workshop

A capacity building workshop for select CBK staff to improve their understanding of open finance.  

d)      Draft diagnostic report

A draft report to be shared with CBK and other relevant parties for feedback. The report must include:

•      Examination of Kenya's financial services ecosystem, including the current state of financial information sharing, key stakeholders in open banking/open finance, and potential benefits, risks, and challenges of adopting open banking/open finance in Kenya.

•      Legal and regulatory analysis of current state of ecosystem to support open banking/open finance.

•      Lessons learned and insights from global analysis of open banking/open finance, and their relevance to implementation approach in Kenya. This should include any challenges identified that may hinder the attainment of the open banking/open finance initiative in Kenya and how to address the said challenges.

•      Recommended policy reforms to facilitate implementation of open banking/open finance. Implementation roadmap for open banking/open finance, detailing key requirements, technical needs, and short-term, medium-term, and long-term milestones.

e)      Stakeholder Feedback Workshop(s)

Organized sessions with key stakeholders, to present initial design and receive feedback. It is expected that there will be a minimum of three workshops held over the duration of the diagnostic. Stakeholders should include: Policymakers, industry players, and civil society representatives. The vendor will receive guidance and support on stakeholder engagement from Central Bank of Kenya and FSD Kenya.  

f)        Final Diagnostic Report

A finalized report encompassing:

•      Detailed findings from the diagnostic.

•      Key recommendations for implementation of open banking/open finance in Kenya.

•      A phased implementation roadmap for open banking/open finance in Kenya.

g)       Presentation of final recommendations

Workshop with all relevant stakeholders to present final report and recommendations, as well as related small group interactions as necessary.

h)      Guide for applying the Key Considerations for Open Finance

Draft guide based on format and structured to be discussed with the CGAP Task Manager.

Timeline

The work is expected to be completed between May 1st, 2025 and October 31st, 2025.  

The following is an indicative timeline for the deliverables. All work should be completed within six (6) months.

SELECTION OF CONSULTING FIRMS BY THE WORLD BANK GROUP

REQUEST FOR EXPRESSION OF INTEREST (EOI)

Electronic Submissions through WBGeProcure RFx Now

ASSIGNMENT OVERVIEW

Assignment Title: CGAP Open Finance in Kenya

Assignment Countries:

• Kenya

ASSIGNMENT DESCRIPTION

Objectives of this project

The primary objective ofthis project is to support the Central Bank of Kenya (CBK) in the design of anopen finance framework for Kenya. The objective of the diagnostic study is toassess the preparedness of Kenya’s financial sector, regulatory and policyenvironment, and other necessary elements for the implementation of openbanking/open finance. The study will provide a comprehensive analysis of thecountry’s financial ecosystem, develop an implementation roadmap, and providespecific recommendations on the design of a robust framework for openbanking/open finance tailored to Kenya’s unique environment and the policyobjectives of the CBK.

As a secondary objective, the vendor will support CGAP’s objectivesof public knowledge generation by leveraging the work done to inform thedevelopment of a guide on how to apply the KeyConsiderations for Open Finance recently published by CGAP, the BIS, IMF,UNSGSA and World Bank.

Scope ofWork

1) Thediagnostic study is expected to cover:

a) Policyobjectives

• Definethe key policy objectives for open banking/open finance in Kenya and thebarriers in the current financial ecosystem open finance will address.

• Determinethe enabling elements needed for open banking/open finance to achieve keypolicy objectives, including parallel initiatives which could strengthen theimpact of open banking/ open finance (e.g. the Fast-Payment System)

• Exploreopportunities and high-potential use cases in banking, payments, credit,investments, insurance, and pensions to support these objectives.

• Identifythe financial service providers needed to participate in open banking/openfinance in order to achieve the desired objectives, assess their readiness andwillingness to open banking/open finance, and any challenges associated withtheir participation.

b) Legaland Regulatory Review

• Evaluateexisting laws and regulations to determine if CBK has the necessary mandate andpowers to lead open banking/open finance implementation.

• Identifycomplementary laws and regulations outside of CBK’s mandate which could supportopen banking/open finance implementation, and the relevant authorities toengage.

• Identifyand recommend changes to the regulatory framework required to accommodate theneeds of an open banking/open finance framework.

• Examineand identify any existing initiatives in the EAC region on Open Banking/Finance.

c) TechnicalCapacity and Infrastructure

• Assessthe technical capacity of the financial ecosystem for secure and scalableAPI-based data sharing, identifying gaps in current practices, infrastructure,and capabilities.

• Identifyand assess any open banking/open finance initiatives undertaken or ongoing bythe key stakeholders.

• Identifythe technical standard and technical architecture Kenya should adopt, based onglobal practices and local market context.

• Determinethe roles the public and private sector will take in developing the ecosystem’sAPIs.

• Reviewthe adequacy of digital public infrastructure to support open banking/openfinance and propose required changes.

• Analyzesuccessful global implementations to extract relevant lessons and adaptablemodels for Kenya.

d) Governanceand Stakeholder Collaboration

• Determinethe governance arrangements needed to support the objectives of openbanking/open finance in Kenya.

• Proposea governance model for open banking/open finance, with defined rules ofparticipation, roles and activities for regulators and industry players, aswell as decision-making and oversight processes

• Outlinestrategies for CBK to foster collaboration among stakeholders to ensureeffective implementation of open banking/open finance governance.

• Developdraft policies and rules for open banking/open finance in key areas ofgovernance, including, but not limited to: Data types and formats, quality andaccess standards, accreditation and liability frameworks, reciprocity, pricingand monetization, and dispute resolution.

e) Oversightand supervision

• Assessthe current mandate, enforcement powers, capabilities and resources of CBK andother authorities to supervise ecosystem participants effectively.

• Identifyrisks and challenges associated with open banking/open finance and proposemitigation strategies.

• Recommendan oversight and supervision framework for open banking/open finance, includingareas for oversight and responsibilities for oversight of different authorities,as well as appropriate RegTech tools for effective supervision of participantsin the open banking/open finance ecosystem.

f)Consumer protection and dataprotection

• Reviewdata privacy and protection and consumer protection regulations and determineany modifications, expansions, or further guidance needed to align existingframeworks and regulations to open banking/open finance.

• Proposestrategies to generate customer awareness and trust to support adoption of theopen banking/open finance ecosystem, with particular consideration for theparticipation of vulnerable segments.

g) ImplementationRoadmap

• Developa phased implementation plan for open banking/open finance, detailing keyrequirements, technical needs, and short-term, medium-term, and long-termmilestones.

2) Thegeneral guide on how to apply the Key Considerations for Open Finance shouldcover the 10 key elements presented in the report: Objectives, ProcessLeadership, Governance, Regulation, Oversight and Supervision, Consumer andData protection, Consumer information and awareness, Participation, TechnicalInfrastructure and Architecture, and Pricing. The guide will complement thereport by offering practical recommendations and examples for countries lookingto apply the key considerations. Thevendor is expected to produce a draft and would not be responsible for thecopy-editing or design of the guide.

Methodology

The vendor willbe expected to adopt a mixed methods approach which will include desk researchas well as direct engagement with public and private sector actors in Kenya. Directengagement can involve one-on-one interactions and the facilitation of groupdiscussions. CGAP expects the work to require at least three in-personconvenings: (1) to launch the effort and define the policy objectives;(2) to gather input from industry participants on the preliminary design; and(3) to present and discuss the recommendations produced.

Deliverable(s)

The diagnostic will deliver a comprehensivereport including: a detailed analysis of Kenya’s financial services ecosystem,policy reform areas to enable open banking/open finance, insights and learningsfrom international case studies and policy frameworks relevant to Kenya, and clearrecommendations on rules, technical requirements, and infrastructure necessaryfor a successful open banking/open finance ecosystem.

The findings will be validated throughfeedback from policymakers, industry, and civil society, ensuring thediagnostic reflects a consensus-driven approach. The final report will includeactionable recommendations and a roadmap for the Central Bank of Kenya andother stakeholders, setting the stage for a transformative and inclusivefinancial future for Kenya.

The consultant will deliver the followingspecific outputs:

a) Project launch and objectives-setting workshop

Convening of relevant stakeholders to define objectives of openbanking/open finance and build buy-in to consultation process.

b) Inception Report

A comprehensive inception report detailing the planned activitiesfor the diagnostic. It will include:

•A detailed workplan, approach, andmethodology.

•Refined set of research questions whichaddress the objectives of the diagnostic study and will be addressed throughthe diagnostic.

•Data collection and stakeholder consultationprocess, including plans for conducting in-person meetings and workshops.

•Clear deliverables and timelines for allactivities.

c) Capacity building workshop

A capacity building workshop for select CBKstaff to improve their understanding of open finance.

d) Draft diagnostic report

A draft report to be shared with CBK and other relevant partiesfor feedback. The report must include:

•Examination of Kenya's financial servicesecosystem, including the current state of financial information sharing, keystakeholders in open banking/open finance, and potential benefits, risks, andchallenges of adopting open banking/open finance in Kenya.

•Legal and regulatory analysis of current stateof ecosystem to support open banking/open finance.

•Lessons learned and insights from globalanalysis of open banking/open finance, and their relevance to implementationapproach in Kenya. This should include any challenges identified that mayhinder the attainment of the open banking/open finance initiative in Kenya andhow to address the said challenges.

•Recommended policy reforms to facilitateimplementation of open banking/open finance. Implementation roadmap for openbanking/open finance, detailing key requirements, technical needs, andshort-term, medium-term, and long-term milestones.

e) Stakeholder Feedback Workshop(s)

Organized sessions with key stakeholders, to present initialdesign and receive feedback. It is expected that there will be a minimum ofthree workshops held over the duration of the diagnostic. Stakeholders shouldinclude: Policymakers, industry players, and civil society representatives. Thevendor will receive guidance and support on stakeholder engagement from CentralBank of Kenya and FSD Kenya.

f)Final Diagnostic Report

A finalized report encompassing:

•Detailed findings from the diagnostic.

•Key recommendations for implementation of openbanking/open finance in Kenya.

•A phased implementation roadmap for openbanking/open finance in Kenya.

g) Presentation of final recommendations

Workshop with all relevant stakeholders to present final reportand recommendations, as well as related small group interactions as necessary.

h) Guide for applying the Key Considerations for Open Finance

Draft guide based on format and structured tobe discussed with the CGAP Task Manager.

Timeline

The work is expected to be completed between May1st, 2025 and October 31st, 2025.

The following isan indicative timeline for the deliverables. All work should be completedwithin six (6) months.

SUBMISSION REQUIREMENTS

The World Bank Group invites eligible firms to indicate their interest in providing the services. Interested firms must provide information indicating that they are qualified to perform the services (brochures, description of similar assignments, experience in similar conditions, availability of appropriate skills among staff, etc. for firms; CV and cover letter for individuals). Please note that the total size of all attachments should be less than 5MB. Firms may associate to enhance their qualifications unless otherwise stated in the solicitation documents. Where a group of firms associate to submit an EOI, they must indicate which is the lead firm. If shortlisted, the firm identified in the EOI as the lead firm will be invited to the request for proposal (RFP) phase.

Expressions of Interest should be submitted, in English, electronically through WBGeProcure RFx Now

NOTES

Following this invitation for EOI, a shortlist of qualified firms will be formally invited to submit proposals. Shortlisting and selection will be subject to the availability of funding.

Only those firms which have been shortlisted will be invited to participate in the RFP phase. No notification or debrief will be provided to firms which have not been shortlisted.

If you encounter technical difficulties while uploading documents, please send an e-mail to the Help Desk at corporateprocurement@worldbank.org prior to the submission deadline.