Financial inclusion institutions in emerging countries are increasingly important as expansive savings and investment vehicles for households and the public in general. A large part of these institutions carry out financial activities that play the part of bank credit, but within a regulatory framework that is either non-existent or much more lax than that which exists for formally-constituted banking institutions. The same thing happens with regulation of new financial inclusion instruments – such as electronic and mobile phone banking – which in many countries is limited or non-existent.
In order to guarantee the stability of the financial system, it is necessary to do more than provide greater financial access to the population. The nature and characteristics of access and use, the so-called quality dimension of financial inclusion, is a key element in ensuring that greater access and use do not endanger financial stability. This dimension is related to the change in the nature and risk levels entailed by the new financial inclusion instruments and institutions, as well as new clients. Although concrete indicators still do not exist, it is commonly accepted that the referential framework to measure this dimension ought to take into account the existence of: i) adequate regulation and supervision of new financial inclusion instruments and institutions, ii) effective financial consumer protection policies, and iii) programs of financial education. In general, this dimension takes on greater relevance in more advanced stages of financial inclusion, when the problem of access is eventually resolved.
The fundamental measures that should accompany greater access and use, in order that they not endanger stability, might seem to be related to those that were outlined after the crisis for the most advanced stages of financial development: prudential regulations, financial consumer protection policies and financial education. Nevertheless, the risks and frictions associated with financial inclusion are different to and less pronounced than those associated with financial development in its most advanced stages, as are the measures to be applied.
In this regard, it is important to specify what type of state intervention or regulation is necessary in the particular case of financial inclusion, rather than automatically applying measures derived from the financial crisis. The application of standards and other measures that guarantee financial stability might prove to be a setback to the inclusion processes, hence, a key element is the application of the principle of proportionality: the balance of risks and benefits in the face of the welfare costs of regulation and supervision of different financial inclusion instruments and institutions . An example of the application of this principle is delegated supervision, which seems to be the most recommendable alternative, as in the case of federations and confederations for the supervision of cooperatives.
It seems fitting to conclude by highlighting the need to continue studying the potential links between financial stability and inclusion through the development of theoretical frameworks, evaluated with adequate empirical methodologies. The theoretical framework of traditional financial markets could be extended to give space to new, stability-endangering frictions related to greater access to and use of financial markets. In addition, there are enormous gaps in the information on financial inclusion institutions, given that a large part of them are outside the regulatory perimeter of state authority. It is also necessary that databases be developed that contain information on the nature of financial inclusion institutions and instruments, as well as regulatory and supervisory structures.
 Basel Committee on Banking Supervision (2015), Range of practice in the regulation and supervision of institutions relevant to financial inclusion, January.