Executive Summary
An estimated 850 million people globally lack any form of officially recognised identification, and a further 1.5 billion possess identity documents that are functionally inadequate for accessing financial services. This "identity gap" is the single largest barrier to financial inclusion: without verifiable identity, individuals cannot open bank accounts, access credit, purchase insurance, or participate in the formal economy. The World Bank's Global Findex Database 2025 identifies lack of documentation as the primary reason cited by 26% of unbanked adults for not having a financial account.
Digital identity systems — leveraging biometrics, mobile connectivity, and distributed databases — offer a transformative pathway to closing this gap. India's Aadhaar system, covering 1.39 billion enrolled individuals, has enabled the opening of 520 million new bank accounts since 2014 and facilitated $380 billion in direct benefit transfers. The EU's eIDAS 2.0 regulation, mandating European Digital Identity Wallets by 2026, represents a fundamentally different architectural approach centred on user sovereignty and data minimisation. Across Africa, national digital ID programmes in Nigeria, Kenya, Ethiopia, and Rwanda are at various stages of implementation, with the African Union's Digital Transformation Strategy targeting universal digital identity coverage by 2030.
This research report provides a comparative analysis of these three models — centralised foundational ID (Aadhaar), decentralised self-sovereign identity (eIDAS 2.0), and emerging federated systems (Africa) — evaluating their effectiveness in driving financial inclusion, their governance trade-offs, and the institutional conditions required for success. We apply public goods theory and information economics to explain why digital identity is a natural public good with positive externalities that justify public investment, while analysing the privacy and surveillance risks that require careful institutional safeguards.
The Economics of Identity: Information Asymmetry and Financial Exclusion
Financial exclusion is fundamentally an information problem. Financial institutions require identity verification to comply with Know Your Customer (KYC) and Anti-Money Laundering (AML) regulations, assess creditworthiness, and manage counterparty risk. Without verifiable identity, the information asymmetry between financial institutions and potential customers is too severe for market transactions: adverse selection drives institutions to exclude unidentifiable populations rather than bear the risk of serving them.
Akerlof's (1970) market for lemons framework applies directly: in the absence of identity verification, financial institutions cannot distinguish between high-risk and low-risk customers, leading to either prohibitively high pricing (risk premiums that exclude the poorest) or market withdrawal. The World Bank estimates that the cost of traditional KYC processes — involving physical document verification, in-person interviews, and manual record-keeping — averages $15–25 per customer in developing economies, rendering accounts unprofitable for low-balance customers who represent the unbanked majority.
Digital identity dramatically reduces these information costs. India's eKYC process — using Aadhaar biometric verification — costs approximately $0.03 per verification, a reduction of over 99% from traditional KYC. This cost reduction fundamentally alters the economics of serving previously excluded populations: at $0.03 per verification, even accounts with minimal balances become economically viable for financial institutions.
India's Aadhaar: The Centralised Foundational Model
Aadhaar, administered by the Unique Identification Authority of India (UIDAI), assigns a unique 12-digit number linked to biometric data (fingerprints and iris scans) to each enrolled individual. Launched in 2009 and covering over 99% of India's adult population by 2025, Aadhaar has become the backbone of India's digital public infrastructure stack — the "India Stack" — comprising identity (Aadhaar), payments (UPI), data (Account Aggregator), and consent layers.
The financial inclusion impact has been transformative. The Pradhan Mantri Jan Dhan Yojana programme, leveraging Aadhaar-enabled eKYC, facilitated the opening of 520 million bank accounts between 2014 and 2025 — the largest financial inclusion initiative in history. The World Bank's Findex data shows India's account ownership rate rising from 53% in 2014 to 78% in 2021 and an estimated 87% by 2025. Direct Benefit Transfers (DBT) through Aadhaar-linked accounts totalled $380 billion cumulatively, with the government estimating $33 billion in savings from reduced leakage and fraud in subsidy distribution.
However, the centralised model raises significant governance concerns. The 2018 Supreme Court of India ruling (Puttaswamy v. Union of India) upheld Aadhaar's constitutionality while restricting mandatory linkage, responding to concerns about surveillance potential and data security. The centralised biometric database creates a single point of failure: security breaches affecting the central database could compromise the identity of 1.39 billion individuals. Furthermore, authentication failures — estimated at 6–12% of biometric verifications for manual labourers with worn fingerprints — can exclude the most vulnerable populations the system aims to serve.
EU eIDAS 2.0: The Decentralised Self-Sovereign Model
The European Union's eIDAS 2.0 regulation (Regulation (EU) 2024/1183) mandates that all EU member states offer citizens a European Digital Identity Wallet by 2026. The architectural philosophy differs fundamentally from Aadhaar: rather than a centralised identity database, eIDAS 2.0 envisions a decentralised ecosystem where individuals hold verifiable credentials in personal digital wallets, presenting only the minimum necessary attributes for each transaction.
This "self-sovereign identity" approach addresses privacy concerns by design. A user proving their age to purchase age-restricted products need only present a verifiable attestation of being over 18, without revealing their exact date of birth, name, or address. Selective disclosure and zero-knowledge proofs enable this data minimisation at the cryptographic level.
The financial inclusion potential in the EU context is more nuanced than in developing economies, given existing high levels of account ownership (95%). The primary impacts are expected in: cross-border financial services (reducing the friction of cross-border KYC, currently estimated at €5–8 per cross-border verification), financial product portability (enabling credit histories and insurance records to move with individuals across member states), and inclusion of marginalised populations (an estimated 12 million EU residents lack sufficient identity documentation for standard financial services).
The European Commission's impact assessment estimates that eIDAS 2.0 digital identity wallets will generate €3.8–9.6 billion annually in economic value through reduced verification costs, faster onboarding, and cross-border service access. However, implementation challenges are significant: achieving interoperability across 27 member state systems, ensuring relying party adoption, and building user trust in a novel technology paradigm.
Africa's Emerging Digital ID Landscape: Federated Approaches
Sub-Saharan Africa faces the most acute identity gap: approximately 500 million people — nearly half the population — lack proof of legal identity according to the World Bank's ID4D dataset. This gap directly constrains financial inclusion: the continent's unbanked adult population stands at approximately 350 million, the largest of any region.
African digital ID initiatives vary widely in design and maturity. Nigeria's National Identification Number (NIN), targeting 200 million enrolments, combines biometric capture with a centralised database model similar to Aadhaar, but has faced implementation challenges — reaching approximately 105 million enrolments by 2025. Kenya's Huduma Namba initiative, launched in 2019, was struck down by the High Court over data protection concerns and has been restructured. Rwanda's national ID system, with near-universal coverage, is often cited as a model for smaller African nations.
The African Union's Digital Transformation Strategy (2020–2030) envisions interoperable national digital ID systems enabling cross-border financial services, labour mobility, and trade facilitation. The emerging approach is federated: rather than a continental centralised system, national systems would interoperate through standardised protocols and mutual recognition agreements. The Smart Africa initiative and the Pan-African Payment and Settlement System (PAPSS) both depend on interoperable identity infrastructure for cross-border transactions.
Mobile network operators play a uniquely important role in Africa's digital identity ecosystem. With mobile money accounts (214 million active in Sub-Saharan Africa, per GSMA 2025) often exceeding formal bank accounts, SIM registration data provides a de facto identity layer. The World Bank estimates that mobile money has independently increased financial inclusion by 12 percentage points across Sub-Saharan Africa since 2011, functioning as an identity-adjacent system even in the absence of formal digital ID.
Comparative Assessment: Trade-offs and Design Principles
The three models represent different positions on a fundamental trade-off triangle: inclusion effectiveness (speed and coverage of identity provision), privacy and autonomy (individual control over personal data), and implementation feasibility (cost, institutional capacity, and technical complexity).
Aadhaar maximises inclusion effectiveness and implementation feasibility (a single system, centrally managed, rapidly scaled) at the cost of privacy and autonomy. eIDAS 2.0 maximises privacy and autonomy (user-controlled credentials, data minimisation) but faces implementation complexity and limited inclusion impact in an already well-served population. African federated models attempt a middle path but face capacity constraints and fragmentation risks.
From institutional economics, the optimal model depends on the pre-existing institutional environment. Aadhaar's success relied on India's unique combination of strong central government capacity, massive unserved population creating political will, and a pre-existing national ID mandate. eIDAS 2.0 builds on the EU's robust data protection framework (GDPR), high digital literacy, and established cross-border institutional cooperation. African models must contend with limited government IT capacity, lower digital literacy in rural areas, and the absence of continental governance institutions with binding authority.
Policy Recommendations: Toward Inclusive Digital Identity
1. Digital Identity as Public Infrastructure. Governments should treat digital identity systems as essential public infrastructure — comparable to roads, electricity, and telecommunications — with dedicated public investment and governance frameworks. The World Bank estimates a return on investment of 3–13x for digital identity infrastructure in developing economies through increased tax collection, reduced fraud, and financial inclusion gains.
2. Privacy by Design with Contextual Integrity. All digital identity systems should incorporate privacy-preserving technologies (selective disclosure, zero-knowledge proofs, data minimisation) appropriate to the institutional context. The goal is not absolute privacy — which would undermine KYC/AML objectives — but contextual integrity: ensuring that information flows match the norms appropriate to each context.
3. Interoperability Standards. The proliferation of incompatible national digital ID systems risks recreating in the digital domain the barriers that physical document requirements create in the physical domain. Investment in interoperability standards — building on W3C Verifiable Credentials, DIDComm, and ISO/IEC 18013-5 — is essential for cross-border financial inclusion.
4. Inclusive Design for Marginalised Populations. Digital identity systems must account for populations that face particular barriers: biometric capture challenges (manual labourers, elderly persons), digital literacy gaps, connectivity limitations, and documentation requirements for stateless persons and refugees. Offline-capable verification, multi-modal biometrics, and assisted enrolment processes are essential design features.
Implications for GDEF's Finance & Economy Working Group
Digital identity infrastructure is foundational to virtually every dimension of digital economic participation. GDEF's Finance & Economy Working Group will develop a set of Digital Identity for Financial Inclusion Principles, drawing on the comparative analysis presented here, to guide multilateral policy coordination and investment prioritisation.
References & Sources
- World Bank, Global Findex Database 2025. worldbank.org/en/publication/globalfindex
- World Bank, ID4D Global Dataset 2025. Identification for Development Initiative. id4d.worldbank.org
- GSMA, State of the Industry Report on Mobile Money 2025. gsma.com/mobilemoneymetrics
- European Commission, eIDAS 2.0 Impact Assessment. SWD(2021) 124 final. digital-strategy.ec.europa.eu
- UIDAI, Aadhaar Dashboard: Enrolment and Authentication Statistics. Unique Identification Authority of India. uidai.gov.in
- Akerlof, G.A. (1970). "The Market for 'Lemons': Quality Uncertainty and the Market Mechanism." Quarterly Journal of Economics, 84(3), 488–500. doi.org/10.2307/1879431
- African Union, Digital Transformation Strategy for Africa 2020–2030. au.int
- Supreme Court of India, Justice K.S. Puttaswamy v. Union of India. (2018) 1 SCC 809. sci.gov.in
- Gelb, A. and Metz, A.D. (2018). Identification Revolution: Can Digital ID Be Harnessed for Development? Center for Global Development / Brookings Institution Press. cgdev.org
- W3C, Verifiable Credentials Data Model 2.0. World Wide Web Consortium. w3.org/TR/vc-data-model-2.0