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Consumer Empowerment and Market
Conduct Working Group (CEMCWG)

Consumer Empowerment and Market
Conduct Working Group (CEMCWG)

Consumer empowerment and market conduct (CEMC) refers to policies and practices designed to promote stable and inclusive financial services via two interconnected pillars:
• Empowering consumers to make more informed financial decisions via the provision of information, education and effective avenues for redress
• Protecting consumers via effective regulation, supervision and enforcement of market conduct by financial services providers (FSPs).

Consumer empowerment is a broad concept, which places responsibility on regulators and financial services providers to make use of easier, safer financial services and of greater benefit to consumers. Market conduct policies are used by regulators to shape, enhance and balance these three factors (i.e., the institutional framework, as well as supply-side and demand-side factors) to create a more sustainable, fair and sound financial ecosystem for consumers.

While consumer protection has often been a priority for regulators, alongside financial stability, the developments in financial services have highlighted the need for ‘strengthened, dedicated proportionate policy action to enhance financial consumer protection’. At the launch of the AFI CEMC Working Group (CEMCWG), in April 2011, it was acknowledged that expansion and innovation in products, services and technology have, undoubtedly, delivered many economic benefits –globally expanding the reach of financial services and bringing more consumers, including some who have historically struggled to access the market, into financial services. Nevertheless, the CEMCWG also recognized that the causes and effects of the 2007 global financial crisis clearly demonstrated the risk that innovation can disregard legitimate consumer needs and expectations of fair and responsible treatment by financial services firms. As a result, some consumers remain excluded from the market altogether, while others have access only to poor quality financial products or FSPs that do not treat them fairly. Renewed emphasis on consumer empowerment is often referred to as an attempt to re-balance the focus of financial services regulation towards ‘demand-side’ factors – i.e. consumer needs, behaviours and outcomes. This is viewed as both essential and timely.

CEMC regulation is viewed by policymakers and regulators – across the world and in relation to a range of different markets – as offering potential to improve outcomes for individuals, in general, and, in particular, those who are vulnerable, but also as a route to supporting economic growth by promoting and stimulating healthy competition while, at the same time, reducing the cost and burden of regulation.

CEMC policies deliver two important linked outcomes in relation to financial inclusion. First, they increase the potential for FSPs to extend access and choice to groups that are currently underserved or unserved via, for example, new products and services, alternative delivery channels or innovative technologies. Second, they have the potential to improve the quality of products available in the market to ensure that financial inclusion delivers meaningful benefit to consumers. Without this approach, consumers engaging with financial services for the first time are at significant risk of falling prey to poor quality or unsuitable products, resulting in erosion of income due to unexpected costs and charges, punitive terms and conditions, over-indebtedness, loss of savings, damage to their credit history, and repossession of goods and assets.

Fundamental and emerging topics under CEMC are explored in-depth through AFI’s Consumer Empowerment and Market Conduct Working Group (CEMCWG).

According to the Global Findex 2021, 23 percent of unbanked adults globally do not trust the financial system. Of all the unbanked adults, 54 percent are women. Apart from lack of trust in the financial system, women face other challenges that hamper their access to financial services. These include information asymmetry and social norms which pose unique consumer protection issues. It is therefore essential that regulators and policy makers begin to explore gender specific consumer protection practices. These include having laws, regulations, business practices, and information that enable women to use financial services safely and responsibly.

Consumer protection and empowerment are key to financial inclusion efforts and its aim of ensuring that everyone is included in their country’s financial sector. This is clearly demonstrated in the number of Maya Declaration targets that are categorized under CEMC – including targets on consumer protection, financial literacy and financial education.

PRIMARY THEMATIC AREA 2012 2013 2014 2015 2016 2017 2018 2019 2020 2021 2022 2023

Consumer Empowerment
and Market Conduct

  • Consumer Protection
  • Financial Literacy and Financial Education
Maya Declaration Targets 49 72 99 102 122 134 142 192 192 199 233 282
Completed 31 37 50 51 55 58 58 70 84 90 105 131
In Progress 20 17 14 12 16 9 84 122 106 109 128 151
Completion Rate 63% 51% 51% 50% 45% 43% 40.8% 36% 44% 45% 45% 46.45%


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AFI’s Consumer Empowerment and Market Conduct Working Group (CEMCWG)

A platform to discuss policy and regulatory issues related to consumer empowerment initiatives and market conduct regulations.

Launched in April 2011, CEMCWG aims to support consumer empowerment and protection in order to help secure access to and improve the quality of financial services. Its prime objective is to develop and share a common understanding of lessons learned and cost-effective policy tools, and to promote their adoption at the national level as well as in a broader international context.



Wati Seeto, Reserve Bank of Fiji

Co-Chair I

Natalia Sanchez, Superintendencia de Bancos de la República Dominicana

Co-Chair II

Sevak Mikayelyan, Central Bank of Armenia

Gender Focal Point Lead

Ligia Marcela Herrera, Comisión Nacional de Bancos y Seguros de Honduras

Gender Focal Point Co-Lead

Gérard Nsabimana, National Bank of Rwanda

  • Develop a shared understanding of good practices and cost-effective policy tools
  • Promote policy adoption at national and international levels


    The CEMC Working Group achieves these objectives by:

  • Promoting transparency and disclosure
  • Encouraging effective sales and marketing practices
  • Promoting the harmonization of international initiatives
  • Creating avenues for help and redress
  • Championing the benefits.

Financial Education Subgroup

Increased access and usage of financial services and products is a catalyst for economic empowerment and development for marginalized and vulnerable target groups such as women, the youth and forcibly displaced persons. Financial education means a process of providing people with knowledge, understanding, skills and confidence to make financial decisions and take actions which are appropriate to their circumstances and needs. On the other hand, financial literacy is the outcome of financial education programs which means the knowledge, understanding, skills and confidence that people have to assist them in making sound financial decisions and actions. Financial literacy programs can help to promote financial education programs that are scalable and sustainable and can also help to pave the way for their financial inclusion in the medium to long term.

Planned deliverable: 1) Repository of online financial literacy tools, 2) Update of two knowledge products: Financial Capability Barometer and Financial Education LAC Case Study.

Market Conduct Supervision Subgroup

Until recently, the main objective of a Risk-Based Supervision (RBS) approach was ensuring the safety and soundness of the financial system. Originally used for prudential supervision of banks and insurance companies, RBS has been modified for use in pensions and is now being considered for market conduct supervision. The challenges of supervising consumer protection are the same: deploying sufficient resources, focusing on both present and future risks, preventing risks from escalating and taking early corrective actions. There is still a need to assess the effectiveness of CEMC supervision by regulators especially as it relates to planning and implementation of onsite examinations. To address main challenges related to complaint handling in Central Banks, including (but not limited to) human resource management, feedback mechanism, enabling regulations required for effective complaint handling and effective enforcement mechanisms.

Planned deliverable: 1) Guideline Note on Impact Assessment of Financial Service Providers, 2) Market Conduct Supervision Manual.

Consumer Protection for Innovation Subgroup

This new subgroup was formed with the objective to tackle issues around consumer protection and innovations. As technology advances, so do the risks associated with data breaches and unauthorized access. Robust data protection laws and practices are essential to safeguard consumer information. Encryption, access controls, and transparent data handling are critical components. With the rise of digital transactions, consumers need assurance that their financial assets are secure (e.g. with multi-factor authentication, real-time fraud detection, and secure payment gateways). Innovations often introduce new products and services and ensuring their safety and reliability is paramount. Regulatory oversight, product testing, and clear liability frameworks protect consumers. Financial literacy programs, awareness campaigns, and accessible information empower consumers about their rights, risks, and choices. In an era of complex contracts and terms, consumers must understand what they’re agreeing to. Plain language contracts, disclosure requirements, and transparent pricing foster trust. As AI, Internet of Things (IoT), and blockchain gain prominence, consumer protection must adapt. Ethical AI, data ownership, and smart contract security are pivotal.

Planned deliverable: 1) Webinar series, 2) Focus group on Bank Supervision Assessment (BSA) tool.












  • Central Bank of Lesotho
    National Financial Education Strategy
  • Central Bank of Lesotho
    Regulation on Disclosure of Information
  • Bangladesh Bank
    Financial Literacy Guidelines
  • RMA Bhutan
    Bhutan’s Financial Literacy Capability measurement
  • Centrale Bank van Suriname
    Draft DSS Financial Inclusion/Education Baseline Study
  • Bank of Uganda
    Financial Literacy Strategy
  • National Bank of Tajikistan
    Disclosure for Credit Institutions
  • Papua New Guinea
    Financial Consumer Protection Framework
  • Royal Monetary Authority of Bhutan
    Guidelines for Financial Consumer Protection
  • Central Bank of Seychelles
    Consumer Protection Regulation
  • Royal Monetary Authority of Bhutan
    National Financial Education/ Literacy Strategy
  • Banque de la République du Burundi
    Consumer Protection Regulation
  • Reserve Bank of Fiji
    NFIS 2022-2030
  • CFI Eswatini
    National Financial Literacy Strategy
  • Bank of Sierra Leone
    National Financial Education/ Literacy Strategy
  • SBS Peru
    Help and redress mechanisms (alternative dispute resolution)
  • Central Bank of Armenia
    Help and redress mechanisms (alternative dispute resolution)
  • Ministry of Finance Swaziland
    National financial education/literacy strategies
  • Banco de la República de Colombia
    National financial education/literacy strategies and help and redress mechanisms (alternative dispute resolution
  • West African Economic and Monetary Union (WAEMU)
    National financial education/literacy strategies
  • National Bank of the Republic of Belarus
    National financial education/literacy strategies
  • Central Bank of Kenya
    Consumer protection guideline
  • Banco Central de Timor-Leste
    Instruction on Consumer Protection for Financial Service Providers
  • Central Bank of Seychelles
    Financial Education Structure
  • Nepal Rastra Bank
    Financial Literacy Framework
  • Superintendencia de Bancos de la República Dominicana
    Legal Framework for consumer protection
  • Central Bank of Solomon Islands
    Draft for Financial Consumer Protection Guidelines
  • Comisión Nacional de Bancos y Seguros de Honduras
    National Financial Education Strategy
  • Banco Central de Reserva El SalvadorTechnical Standards for the Submission of Information on Financial Education Programs or Initiatives
  • Central Bank of Nigeria
    CBN Digital Financial Services Awareness Guidelines
  • Bank of Uganda
    NFIS II (focus on consumer protection section)
  • Bank of Ghana
    Draft Market Conduct Risk-based Supervision Framework
  • Agency of the Republic of Kazakhstan for Regulation and Development of Financial Market
  • Autorité de Contrôle de la Microfinance
  • Banco Central de Reserva de El Salvador
  • Banco Central de São Tomé e Príncipe
  • Banco Central de Timor-Leste
  • Banco Central del Paraguay
  • Banco de Moçambique
  • Banco Nacional de Angola
  • Bangko Sentral ng Pilipinas
  • Bangladesh Bank
  • Bank Al-Maghrib
  • Bank Negara Malaysia
  • Bank of Ghana
  • Bank of Namibia
  • Bank of Papua New Guinea
  • Bank of Sierra Leone
  • Bank of Tanzania
  • Bank of Uganda
  • Bank of Zambia
  • Banque Centrale de la République de Guinée
  • Banque Centrale de Madagascar
  • Banque Centrale de Mauritanie
  • Banque Centrale de Tunisie
  • Banque Centrale des Etats de l’Afrique de l’Ouest (BCEAO)
  • Banque Centrale du Congo
  • Banque de la République du Burundi
  • Central Bank of Armenia
  • Central Bank of Egypt
  • Central Bank of Eswatini
  • Central Bank of Jordan
  • Central Bank of Kenya
  • Central Bank of Lesotho
  • Central Bank of Liberia
  • Central Bank of Nigeria
  • Central Bank of Samoa
  • Central Bank of Sudan
  • Central Bank of Seychelles
  • Central Bank of Solomon Islands
  • Central Bank of Sri Lanka
  • Central Bank of The Gambia
  • Central Bank of the Republic of Uzbekistan
  • Centrale Bank van Suriname
  • Comisión Nacional Bancaria y de Valores de México (CNBV)
  • Comisión Nacional de Bancos y Seguros de Honduras
  • Direction Générale du Trésor, Ministère de l’Economie et des Finances, Madagascar
  • Financial Regulatory Commission of Mongolia
  • Maldives Monetary Authority
  • Microcredit Regulatory Authority of Bangladesh
  • Ministère de l’Économie et des Finances de la Côte d’Ivoire
  • Ministère des Finances et du Budget du Sénégal
  • Ministère des Finances de la République Tunisienne
  • Ministry of Finance Eswatini
  • Ministry of Finance and National Planning Zambia
  • National Bank of Cambodia
  • National Bank of Rwanda
  • National Bank of Tajikistan
  • National Reserve Bank of Tonga
  • Nepal Rastra Bank
  • Palestine Monetary Authority
  • Reserve Bank of Fiji
  • Reserve Bank of Malawi
  • Reserve Bank of Zimbabwe
  • Reserve Bank of Vanuatu
  • Superintendencia de Bancos de la República Dominicana
  • Superintendencia de Bancos del Ecuador
  • Superintendencia de la Economía Popular y Solidaria de Ecuador
  • Superintendencia General de Entidades Financieras de Costa Rica (SUGEF)
  2011 2012 2013 2014 2015 2016 2017 2018 2019 2020 2021
Events 1st: Kuala Lumpur, Malaysia
2nd: Riviera Maya, Mexico
3th: Bangkok, Thailand
4th: Cape Town, South Africa
5th: Lima, Peru
6th: Kuala Lumpur, Malaysia
7th: Minsk, Belarus
8th: Port of Spain, Trinidad and Tobago
9th: Kuala Lumpur, Malaysia
10th: Maputo, Mozambique
11th: Yerevan, Armenia
12th: Nadi, Fiji
13th: Mahe, Seychelles
14th: Sharm El Sheiikh, Egypt
15th: Merida, Mexico
16th: Sochi, Russia
17th: Nassau, The Bahamas
18th: Kigali, Rwanda
19th: Virtual Meeting
20th: Virtual Meeting
21th: Virtual Meeting
22th: Virtual Meeting
Member Institutions N/A 30 41 49 52 59 57 60 62 62 65
Knowledge Products
2 2 6 6 8 9 11 12 12 15 21
Policy Changes
5 16 20 26 34 42 62 82 130 157 25
Peer Reviews
0 0 0 7 7 8 9 11 13 15 19


Why join AFI's Consumer Empowerment and Market Conduct Working Group (CEMCWG) ?

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When financial service providers offer measures to consumers to cushion the effects of COVID-19, particularly through access to emergency funds, increasing limits for their credit cards or easy access to additional loans, it stringent oversight and enforcement are required to ensure that consumers are not overindebted. Consumer Empowerment and Market Conduct Working Group webinar on Consumer Protection Amidst A Pandemic: Case of COVID-19 discussed policy and regulatory interventions, opportunities for cooperation and partnership, and the role of consumer protection amidst a pandemic.

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Policymakers and regulators face the challenge of increasing the level of engagement with financial services while at the same time ensuring consumer protection. Webinar session looked into how to design consumer protection strategies that take into account the behaviors of consumers.

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