Elemegious Mugamba’s 2025 paper advances a firmly state-centric digital finance thesis: Uganda’s financial inclusion gap—where more than 40% of adults remain outside formal banking—will not be materially reduced through incremental banking expansion but through a coordinated digital monetary triad anchored by a central bank digital currency (CBDC). The paper’s central contribution is its effort to treat CBDC, fintech, and cryptocurrencies as interlocking components of a single ecosystem, with the Bank of Uganda cast as the primary system designer and supervisor.
The study approaches exclusion largely through a supply lens. Financial marginalization is attributed mainly to access frictions, including documentation requirements, limited rural branch coverage, relatively high transaction costs, and strict KYC thresholds that exclude low-documentation users. Uganda’s mobile money experience is central to this framing. The paper highlights mobile penetration exceeding 65% and the widespread use of platforms such as MTN Mobile Money and Airtel Money as evidence that digital channels have already expanded financial access at scale, inferring that once delivery barriers fall, latent demand for formal financial services emerges more readily. The policy implication is to formalize this digitally mediated access rather than expanding conventional banking infrastructure.
Within this framework, CBDC sits at the center of the proposed solution. Mugamba argues that a retail CBDC—particularly one delivered through mobile wallets and supported by simplified digital identification—could extend sovereign money to users operating at the margins of the formal system. Fintech is framed as essential enabling infrastructure., Cryptocurrencies receive a more cautious treatment: while the paper acknowledges their usefulness for low-cost remittances and peer-to-peer transfers, it emphasizes volatility and regulatory risk, ultimately recommending a containment posture. This is where the paper’s internal tension is most visible. Mugamba’s own data shows remittances at 3.4% of GDP while traditional transfer services charge 7–10% per transaction, yet this cost gap, which cryptocurrencies demonstrably address, is treated as secondary to containment concerns.
The analysis reflects a pronounced Bank of Uganda system-optimizer lens and gives limited weight to demand-side constraints such as trust in digital money, digital literacy, and continued reliance on informal finance. Experience across Africa suggests that these factors are material. Nigeria’s eNaira rollout illustrates that technical readiness does not guarantee adoption, while the South African Reserve Bank’s “no immediate need” stance on retail CBDC underscores uncertainty about marginal user value where mobile payments are already expanding through private channels.
Beyond bank disintermediation, retail CBDCs raise questions around operational concentration, cyber resilience, and potential crowding out of private payment innovation. In markets where mobile money already performs core retail functions, a CBDC must demonstrate clear incremental utility to achieve meaningful uptake.
Finally, the paper’s treatment of cryptocurrencies would benefit from greater differentiation. Bitcoin’s unique design contexts distinguish it from more speculative tokens and lightly backed stablecoin experiments. Aggregating these instruments into a single risk category obscuring where practical utility is already emerging in African markets.
