Competition in Mobile Payment Services
OECD Competition Committee 18 June 2025
Maria Pilar Canedo | Senior Competition Expert
Beatriz Marques | Competition Expert
Categories of mobile payments
Representation of a bank-centric retail-level payment rail
8. Payment completed
Merchant receives funds in account; transaction is complete
7. Merchant’s bank
2. Merchant’s bank
Merchant’s bank (acquiring bank) submits transaction 3. Card network
1. Purchase
User chooses mobile payment to make a purchase
Card network routes transaction to user’s bank (issuing bank) for authorisation 4. User’s bank User’s bank (issuing bank) accesses
are received by merchant’s bank (acquirer) after settlement
6. Foundational Payment Infrastructure
network
Representation
User
User gives cash to authorised agent in person
Authorised Agent
User mobile device
Authorised agent, enabled by the user’s telecom network, deposits this money into the user’s mobile app or wallet
Merchant’s fees
Percentage of the transaction amount, subject to caps or minimums
Purchase
User can use this money to purchase goods or services through the app or wallet
Merchants (or peers)
Authorised agents can accept this payment
User fees
Charged tiered fee based on amount spent
Characteristics of digital markets affecting competition
Network effects
Switching costs for consumers
Economies of scale and scope
Data as a driver of competition
“Zero prices” Multisided markets
Vertical integration
Conglomerate/ecosy stem business models
Innovation and nonprice competition
Competition risks
Market tipping
Regulation as a potential barrier
Foreclosure
Raising rival’s costs
Tying
Bundling
Leveraging
MFN clauses
Anti-steering provisions
Interdependencies between providers
Collusion
Steered or co-opted innovation
Opportunities for competition, in addition to keen and timely enforcement…
Open banking Data portability Interoperability
API standard design Reciprocal data access Asymmetric digital market regulations
Alternative retail-level payment rails National payment switches Fast payment systems
Considerations for pro-competitive interventions
Context matters
Timing is critical
Consider
effects on innovation
Pro-competitive framing to policy is crucial
