Desta serves as the bookkeeper for her local savings group in Ethiopia and recently began using a smartphone for the first time. The nonprofit organization that supports her group has introduced a mobile app to help record financial transactions digitally. Through this app, the group’s records can be shared with a local microfinance institution (MFI) to help members apply for loans in the future.
With guidance from her 10-year-old son, Desta manages to navigate the app and provide consent for sharing the group’s financial information with the MFI.
At first glance, it looks like a success story. But it also raises an important question: did she truly understand what she agreed to?
If she needed help navigating the app and has limited formal education, can we be certain she understood the terms and conditions related to data sharing? Did she fully grasp how the information would be used or how to limit the sharing of sensitive details to protect the group’s privacy?
The Ethical Dilemma Around Digital Consent
Questions like these became very real when developing DreamSave at DreamStart Labs in 2023. The project highlighted a difficult balance between expanding financial access and ensuring ethical data practices.
On one side, there is broad agreement that data sharing can drive financial inclusion. By using alternative data sources—such as mobile money records or digitized savings group data—financial institutions can evaluate people who traditionally lack formal credit histories.
For example, sharing savings group records through platforms like DreamSave helped women-led businesses demonstrate financial activity and gain access to loans.
However, another concern quickly emerges: Is consent truly ethical if users don’t fully understand what they are agreeing to? This question becomes especially important when working with vulnerable populations who may have limited literacy or digital experience.
Consent Should Be More Than Clicking “Agree”
Today, the issue is even more pressing as financial systems increasingly adopt open finance frameworks. Instead of simple one-to-one data sharing, open finance allows financial data to move between multiple providers with a customer’s permission.
By 2025, at least 54 jurisdictions worldwide had either implemented or planned open finance regulations. Many of these regions are in emerging markets, including several African economies where financial literacy and digital access vary widely.
In this environment, consent cannot simply be a checkbox. It must act as a foundation for consumer empowerment and protection.
Under the EU’s General Data Protection Regulation (GDPR), consent is defined as a clear and informed agreement made freely by the user to allow data sharing for a specific purpose. For digital financial services operating within open finance systems, this means looking far beyond the moment when a user taps “Agree.”
True consent requires systems that allow consumers to:
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Authenticate securely
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Authorize data access easily
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Continuously manage who can access their information and why
In other words, consent should be treated as an ongoing process, not a single action.
The Problem of Consent Fatigue
Even with regulations in place, many users rarely read or fully understand digital terms and conditions. One major reason is consent fatigue—a situation where users are overwhelmed by repeated requests for permissions and lengthy explanations.
When people face too much information at once, the experience becomes frustrating. Instead of reading carefully, they simply click “Accept” to move forward.
This problem is especially common among individuals who face:
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Language barriers
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Limited financial literacy
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Restricted digital access
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Low familiarity with smartphones or apps
For financial service providers working in these markets, the challenge is finding the right balance: giving users enough information to make informed decisions without overwhelming them.
This balance is not easy to achieve. It can also be expensive to design and implement.
The early rollout of open finance in Brazil in 2021 offers an example. Banks achieved only about half the consent success rate of fintech companies, showing how poor user experience design and weak industry coordination can undermine participation.
Why Consumer Experience Standards Matter
If open finance is going to expand responsibly, regulators and financial service providers must focus on clear consumer experience (CX) standards.
Countries like Australia and the United Kingdom have already established frameworks that prioritize user-friendly consent processes. Similar approaches could help emerging economies address the unique barriers people face when adopting digital financial services.
Strong CX standards should include several key principles throughout the user journey—from the initial consent request to ongoing data management.
Control
Consumers should have real authority over their data, with clear choices about what is shared and with whom.
Security
Security measures should be explained clearly and calmly, avoiding language that causes unnecessary fear or confusion.
Speed
Processes should remain efficient, while still including moments that allow users to understand what they are agreeing to.
Transparency
Information should be presented gradually and in simple language so users are informed without feeling overwhelmed.
Trust
Every interaction should build trust through reliable safeguards and clear solutions when mistakes occur.
Accessibility and Inclusivity
Platforms should support local languages, work across different devices, and include visual tools that help users with limited literacy.
Simplicity
Navigation should be straightforward, with clear instructions and minimal steps for users who are new to digital systems.
Making Open Finance Work for Everyone
Open finance has enormous potential to expand access to financial services, especially in emerging economies. However, this promise can only be fulfilled if users truly understand and control how their data is shared.
By designing thoughtful consent systems and applying strong consumer experience standards, regulators and service providers can ensure that data sharing benefits those who need it most.
Moving beyond the checkbox means transforming consent from a simple formality into a meaningful tool that gives people genuine choice and control.
And when done right, individuals like Desta will not only grant consent—they will fully understand, manage, and benefit from how their financial data is used.
