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 <https://www.cgap.org/research/publication/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