NAIROBI, Kenya- Former Central Bank of Kenya Governor Dr Patrick Njoroge has called for changes to Kenya’s payment laws to require regular bonus payouts to mobile money wallet holders, arguing that customers should benefit from returns currently channelled into charitable causes.
In comments dated September 28 on the draft National Payment System Policy, August 2026, Njoroge proposes distributing returns remaining after the operating costs and related expenses of the trusts holding customer funds.
The proposal is among 11 recommendations covering consumer protection, competition, shared agent networks and payments during network outages.
Njoroge describes the draft as an important effort to prepare Kenya’s payments sector for the future but identifies gaps he says should be addressed in both the policy and the proposed National Payment System Bill, 2026.
Customers should benefit from wallet returns
Njoroge argues that the treatment of returns generated from customer funds should reflect the growth of mobile money beyond its early years.
“The Policy and the National Payment System laws should be amended to explicitly require regular distribution of bonus payouts beyond the operational costs and related expenses of the Trust,” he writes.
He says the proposal recognises wallets as customers’ legal financial property and points to practices in Tanzania, Uganda and Ghana.
According to Njoroge, Kenyan payment service providers have historically channelled these returns into charitable causes, an arrangement he describes as a holdover from the industry’s early development.
“Expectations that the total holdings in wallets would be small were overtaken and fears about competition with banks have dissipated,” he says.
His submission does not specify a payout rate or a distribution schedule.
The recommendation is a proposed reform, rather than an announcement of payments to customers.
Deposits and withdrawals at any authorised agent
Njoroge also wants the policy to support a shared agent network that would allow customers to deposit or withdraw cash at any authorised agent, regardless of their payment service provider.
He says the draft is silent on agent sharing, despite its importance to customers and businesses handling transactions.
Such an arrangement would also allow agents to manage their combined float more efficiently, he argues.
“The Policy could more explicitly recognize agent interoperability as a desirable objective within the broader interoperability agenda,” he writes.
The proposal would extend the push for payment systems to work together to the agent counters where customers exchange cash for electronic money.
Stronger protection against fraud
Njoroge identifies fraud, affordability and the privacy of personal information as the main concerns facing consumers.
He says the draft acknowledges some of these problems but does not give sufficiently clear guidance on how they should be addressed.
In particular, he calls for stronger principles on fraud prevention, responsibility for losses and remedies for affected customers.
He also wants clearer safeguards governing the collection, use and protection of personal data.
“Consumer data shall be shared only with the explicit, informed, and revocable consent of the customer,” he writes.
Njoroge links those protections to the need for a digital identity framework that allows users to verify their identities while protecting their privacy.
Warning over unfair competition
The former governor warns that companies operating payment services within larger corporate groups could use pricing arrangements that favour their own businesses over outside competitors.
He argues that allowing different platforms to transact with one another will not, by itself, resolve that risk.
Payment service providers’ governance and operations should be kept separate from the rest of their corporate groups, he says, while services offered to third parties should be provided on fair and non-discriminatory terms.
Njoroge also calls for clarity on the government’s role as a participant in the payments market, distinct from its responsibilities as policymaker and regulator.
He says the design of forthcoming instant payment infrastructure will be an important test of those principles.
Payments during network outages
Another gap, Njoroge says, is the absence of a clear proposal for secure offline payments.
He wants mechanisms that would allow individuals and businesses to continue making payments when networks are unavailable.
“This is a major vulnerability given the widespread use of mobile payments,” he writes.
He also identifies poor rural connectivity, restrictive social norms affecting women, lack of identification among young and marginalised people, and the high cost of mobile devices and services as barriers to wider financial inclusion.
A clearer direction for reforms
Beyond individual changes, Njoroge wants the policy to explain how it relates to earlier national plans on payments, digital development and financial inclusion.
He says it should make clear whether it replaces those frameworks or builds on them.
“The risk here is ending up chasing multiple rabbits,” he warns.
While welcoming the draft’s overall vision, Njoroge argues that clearer principles are needed to guide future decisions on competition, infrastructure, innovation and consumer protection.
