From Regulatory Progress to Real Access for Refugees

Financial inclusion practitioners often focus on products, technology, and delivery channels. But for refugees and asylum-seekers, challenges in accessing formal financial services frequently begin much earlier, before they can even consider accessing a financial product. They begin with the regulatory environment.

These are some of the questions that come up:

• Can refugees use their identity documents to satisfy Know Your Customer (KYC) requirements? 
• Can they register a SIM card or have their credentials verified through existing systems? 
• Are both refugees and financial service providers aware of the applicable regulations? 

The answers to these questions determine whether millions of forcibly displaced people can access financial services and participate in the formal economy.

Analyzing the global regulatory landscape for refugees

A new UNHCR global comparative analysis of 79 countries provides a unique window into these issues. The study examines the legal and regulatory frameworks governing access to bank accounts, SIM registration, mobile money, digital wallets and electronic payments for refugees and asylum-seekers.

The findings, presented through a global summary, five regional overviews with accompanying country-level analyses, and a Financial Inclusion Regulatory Dashboard, reveal a regulatory landscape evolving rapidly towards greater access for refugees, but with significant gaps remaining. Here are four key takeaways from our research.

Finding #1: A global shift toward more enabling regulatory frameworks

One of the clearest findings is that regulatory approaches across most geographies are becoming more inclusive. This is great news, though there is some regional variation.

In Latin America and the Caribbean, many countries have incorporated international and regional protection standards into domestic law. Brazil, Ecuador and Chile increasingly allow refugees – and in some cases asylum-seekers – to access financial and digital services using nationally recognized documentation. These countries are also making efforts to raise awareness among financial service providers and strengthen financial literacy among displaced populations. 

Europe demonstrates strong regulatory foundations as well. European Union legislation has helped establish access to basic payment accounts as a component of financial inclusion for all legal residents in its Member States, including refugees and asylum-seekers. While implementation varies, the overall regulatory environment is generally supportive of access for recognized refugees and beneficiaries of international protection.

In Sub-Saharan Africa, enabling regulatory frameworks and expanding digital ecosystems – especially around mobile money – have helped broaden access to financial services for refugees, although implementation challenges persist. Uganda, Ethiopia and Malawi stand out for having developed some of the region’s more enabling frameworks.

By contrast, progress has been slower across much of Asia and the Middle East and North Africa (MENA). Access often remains constrained by limited legal recognition of refugee status, restrictive documentation requirements and systems tied to nationality- or residency-based identification. As a result, refugees and asylum-seekers face more systemic barriers than in other regions.

As a whole, however, the global regulatory landscape is becoming more enabling and progress is no longer confined to a few countries. Increasingly, governments recognize financial inclusion as part of broader economic and social inclusion policies.

Finding #2: Persistent gaps in implementation

Despite these advances, legal access does not always translate into practical access.

Many barriers stem not from explicit restrictions but from uncertainty in implementation. Financial institutions and mobile network operators may be unsure whether refugee documents, issued by governments or UNHCR, meet customer due diligence requirements. Frontline staff may not recognize valid documents, and internal compliance procedures may exceed regulatory requirements.

As a result, refugees can face obstacles even where regulations appear inclusive on paper. 

Documentation and identity verification emerge as the central challenge. While frameworks increasingly permit access, financial and telecommunications systems are not always configured to operationalize it effectively. This challenge gets compounded by administrative delays in obtaining documentation and limited connectivity in remote areas.

Finding #3: The uneven position of asylum-seekers

Another major finding is the persistent gap between refugees and asylum-seekers, whose claims for international protection are still pending.

Across nearly all regions, recognized refugees benefit from stronger access, largely due to documentation. Refugees often hold government-issued documents that can integrate into national systems. By contrast, asylum-seekers rely on temporary documents issued during status determination, which are often not recognized for KYC, SIM registration, or digital onboarding.

As a result, asylum-seekers remain one of the groups most consistently excluded from formal financial services globally.

Finding #4: Digitalization as the next regulatory frontier

Our research also highlights digitalization as a growing factor shaping inclusion. Digital wallets, electronic payments, remote onboarding and digital identity systems have expanded rapidly, creating new opportunities to reach displaced populations at scale.

At the same time, they raise new risks. If refugee documentation cannot be verified within digital identity systems, exclusion may become embedded in digital infrastructure. Future inclusion will depend not only on recognizing refugee documentation, but also on ensuring it functions effectively within digital ecosystems.

Looking Ahead

Our global analysis offers a cautiously optimistic view. The regulatory landscape for refugee financial inclusion has evolved significantly over the past decade. More countries provide legal pathways, more regulators are addressing documentation challenges, and examples of good practice are increasing.

Yet progress remains uneven. Implementation gaps persist, asylum-seekers continue to face disproportionate barriers, and digital transformation presents both opportunities and risks.

The next phase will depend less on new legal frameworks and more on making existing ones work in practice. In many countries, the challenge is no longer whether access is legally permitted, but whether regulatory intent translates into meaningful access for refugees and asylum-seekers on the ground.