Fintech growth assured, except for potential bumps such as AfCFTA’s definition of digital products
Written by Gitura Mwaura
When the global management consulting firm McKinsey & Company asked leading fintech players how optimistic they were about opportunities in Africa, the survey returned an average score of 4.5, where 5 indicates the most optimistic. ‘We are still only scratching the surface,’ one partner observed. ‘There are still millions of Africans yet to be served by fintechs and yet to have access.’
The numbers support the optimism. Almost 300 million adults remain unbanked, particularly in rural and low-income communities, underscoring both the scale of exclusion and the size of the opportunity. McKinsey projects that Africa’s fintech revenues could grow almost fivefold, from about $10 billion in 2023 to $47 billion by 2028.
Yet beneath the glowing outlook lie structural constraints that could slow the sector’s expansion. One is familiar: a global decline in venture capital funding since 2023, already flagged by the Global Finance and Technology Network (GFTN), co-host of the 2026 Inclusive Fintech Forum in Kigali.
Another less obvious, but potentially more consequential for cross-border growth, concerns the definition of a ‘digital product’ under the Protocol on Digital Trade of the African Continental Free Trade Area (AfCFTA).
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At the heart of the matter is a deceptively simple question: Is a digital product, which subsumes fintech, a good or a service?
Under the AfCFTA Protocol, adopted by African Union General Assembly in February 2024, a ‘digital product’ generally means a ‘product that is digitally encoded, that is produced for commercial sale or distribution.’ The definition does not state whether digital products are goods or services. This has far-reaching regulatory and commercial implications.
As explained by Ify Ogo, Regional Specialist on the AfCFTA at the United Nations Development Programme, the ambiguity partly reflects a pending question at the World Trade Organisation. The WTO’s General Agreement on Trade in Services (GATS), negotiated more than 30 years ago, does not explicitly recognise digital services in its traditional 12-sector classification. Since GATS informs the AfCFTA and many other trade agreements, this legacy gap has been reproduced in newer frameworks.
This carries significant implications. Without a clear definition of digital services, as is currently the case in most countries, firms may be forced to rely on outdated GATS-based regulatory categories. A fintech company may be classified as a payment service provider in one country, a bank in another, or fall into a regulatory grey zone in jurisdictions without dedicated fintech frameworks. This fragmentation raises compliance costs, deters cross-border expansion, and undermines the promise of a unified continental market.
More troublingly, notes Ms Igo, where regulations are contradictory or applied inconsistently, fintech providers may find their operations deemed illegal despite acting in good faith. Legal uncertainty of this kind discourages long-term investment and disproportionately affects startups, the very actors expected to drive continental financial inclusion.
Even so, progress is emerging at the national level. Several African countries are proactively updating their regulatory frameworks to balance innovation with financial stability. Kenya’s Virtual Asset Service Provider Act of 2025 establishes a legal foundation for digital assets. Nigeria’s 2025 Investment and Securities Act clarifies rules governing crypto assets and market conduct. South Africa’s Intergovernmental Fintech Working Group Innovation Hub provides regulatory sandboxes that enable controlled experimentation, while Rwanda’s National Fintech Strategy 2024–2029 aims to boost adoption and attract investment with the Kigali International Finance Centre (KIFC) as a strategic partner.
Rwanda’s five-year strategy, for example, aims to support fintech-led economic growth and broader socio-economic transformation while mitigating emerging risks. At a continental level, this national effort is complemented by the fintech licence passport framework between Ghana and Rwanda, launched in February 2025. The framework is intended to enable seamless cross-border operations, enhance financial inclusion, and support intra-African trade.
As a first-of-its-kind initiative on the continent, the passport framework, which other countries are being encouraged to join, forms part of the broader Next-Generation Digital Public Infrastructure (Next-Gen DPI) initiative. These efforts aim to create the regulatory and technical foundations necessary for scalable, interoperable digital financial services across Africa.
However, such initiatives must ultimately operate under the aegis of the African Continental Free Trade Area (AfCFTA), which provides the continent’s overarching integration blueprint. But while 49 have ratified the AfCFTA agreement, fewer than 10 have fully operationalised it at the domestic level, highlighting a significant obstacle to the seamless cross-border integration envisaged. This is not to mention the pending ratification of the digital trade protocol.
Fintech will continue to grow, as the data makes clear. Yet for fintech to scale continentally, national regulatory frameworks and regional commitments and their definitions must be better aligned to enable the cross-border mobility of digital services. It is this necessity that underscores the relevance of the Inclusive FinTech Forum, whose 2026 edition addresses these issues under the theme ‘Shaping the Future of Inclusive Finance: Innovation. Impact. Connection.’
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Media Contacts
Joie-Grace Ruzibiza
Communications Manager, Rwanda Finance Limited
joie.ruzibiza@rfl.rw
+250 788 675 042
