The Gambia
The Gambia is a small West African nation with a population of approximately 2.7 million people. The Financial Supervision Department of the Central Bank of The Gambia (CBG) has the responsibility for licensing, regulation and supervision of the banking sector and mobile money operations, pursuant to Section 71 of the Central Bank Act, 2018.
Despite economic challenges, the outlook is positive, with projected GDP growth of 6.1% in 2024 and 5.8% in 2025. Tourist arrivals are recovering and nearing pre-pandemic levels, while remittance inflows remain strong.
The country’s financial sector faces significant inclusion challenges. Financial inclusion is low in The Gambia, at just 19%, and there are low levels of financial literacy. 77% of youth are financially excluded, along with 83% of those who are informally employed. Only 5% of people are financially served via a bank, 3% by a microfinance institution, 2% borrow through formal financial institutions and 2% use mobile money.
According to the UNCDF, in 2022, approximately 69% of the population remained unbanked.
Open banking has not been formally introduced in The Gambia. There is no regulatory framework governing API-driven financial services or third-party data-sharing agreements. The country’s immediate priorities center on basic financial inclusion and payments infrastructure development rather than open banking implementation.
In January 2021, the Central Bank of the Gambia (CBG), in collaboration with key stakeholders, launched the National Financial Inclusion Strategy (NFIS) 2021–2025, with an ambitious goal of increasing the national financial inclusion rate from 19% to 70% by 2025.[1]
The strategy is built on five core pillars: enhancing access, quality, and usage of financial services; developing enabling financial infrastructure; promoting financial innovation and digital services; improving financial literacy; and strengthening consumer protection and empowerment. Recognizing the transformative role of technology, the NFIS emphasizes financial innovation, particularly the potential of mobile phones and digital financial services such as mobile money to reach underserved populations. This approach aims to create a more inclusive financial system, especially for those in rural and remote areas who are often excluded from traditional banking networks.[1]
There is great enthusiasm with the rapid emergence of FinTechs and the Central Bank’s regulatory sandboxes which should allow and accelerate innovation. The Bank is working on strengthening the Gambia National Switch (GAMSWITCH) to widen the national platform for DFS, strengthen the payments connections for peer-to-peer (P2P), government-to-peer (G2P) and other digital transactions.[3]
The Central Bank of The Gambia is encouraging financial institutions to digitize their services and align with the national Gambia EFT Switch for interoperability and faster settlements.[4]
Efforts on financial deepening are underway and should be intensified while strengthening the financial sector’s supervisory and regulatory framework. The authorities are implementing the National Financial Inclusion Strategy, leveraging the deployment of a new payment system by the CBG, the recent launch of the capital market, the expansion of mobile money and fintech, and the expansion of the women enterprise and youth development funds.[6]
DFS has significant potential as a lever for financial inclusion, as the Gambia has one of the higher mobile penetration rates in the subregion.[3]
With mobile money providers, people without bank accounts can also conduct financial transactions. Mobile money providers have enabled people to purchase airtime, cash power, pay utility bills via their mobile phones. With the current trajectory, we project that the uptake of such services will increase dramatically, contributing to the important role of digital payments in fast-tracking financial inclusion.[3]
In The Gambia, mobile money platforms like Wave offer microloans, enabling users to access small-scale credit services.[5]
The Bank has developed FinTech Guidelines with a view to stimulating growth of the sector, accelerating the pace of financial inclusion and onboarding vulnerable women and youth.[3]
The government has taken a landmark step in safeguarding digital rights by passing the Personal Data Protection and Privacy Act, 2025, its first comprehensive legislation dedicated to protecting personal information in Gambia. Approved unanimously by the National Assembly on September 29, 2025, the act awaits presidential assent to become law.[7]
The act fills a long-standing gap in Gambia’s legal framework, where privacy was previously enshrined only in the 1997 Constitution but lacked specific enforcement mechanisms for personal data handling.[7]
Enforcement falls to a newly established National Data Protection Commission, an independent authority tasked with oversight, investigations, audits and public education. The commission can issue guidelines, handle complaints and impose administrative fines up to 4 percent of annual global turnover for serious violations.[7]
The data protection bill also directly aligns with the Gambian government’s Open Data Strategy 2023-2026.[2]
The financial sector is sound and stable. Banks’ capital adequacy and liquidity ratios are well-above the regulatory minimum, standing at 28.3 and 82.3 percent, respectively, at end-December 2023. Non-performing loans remain low at 3.3 percent, and banks have maintained an adequate level of provisioning.[6]
Several structural factors would need to be addressed before open banking becomes viable in The Gambia:
Current constraints involve access to financial services. For example, distance to services, limited rural finance infrastructure, high transaction costs for both demand and supply sides, etc. To overcome these constraints, digital financial services (DFS) bring finance to the doorsteps of customers with several consumer-centric products that can be easily accessed if adequate digital infrastructure is available.
There are problems in the way of digital banking in Gambia like limited smartphone penetration, lack of digital literacy and trust issues.
The Gambia’s ICT infrastructure is not yet fully developed, with low penetration of key infrastructure components such as fiber optic cables and data centers.[1]
The Gambia’s path toward open banking will depend on successfully achieving its more fundamental financial inclusion goals first. With only 19% financial inclusion at baseline and an ambitious target of 70% by 2025, the immediate focus remains on getting people into the formal financial system through mobile money, agent banking, and digital payments infrastructure.
Digital payment usage is growing, but remains an area with substantial room for further expansion, especially as digital financial services continue to develop. The data reflects both progress and ongoing challenges in achieving the ambitious NFIS 2025 target of 70% financial inclusion.
The passage of the Personal Data Protection and Privacy Act, 2025 is a significant development that lays groundwork for future data-sharing frameworks. However, open banking remains a longer-term consideration contingent on building the foundational infrastructure, achieving meaningful financial inclusion, and developing the regulatory capacity to oversee API-based data sharing.
Open Banking Nigeria (Open Technology Foundation) is a non-profit backed by a group of industry experts across banking, fintech, risk management, and more to drive and launch the open banking standard in Nigeria.
