Market System Approach in Cambodia

Beyond Box-Ticking: How a Market Systems Approach Is Shaping Client Protection in Cambodia

With a new consumer empowerment report on Cambodia set to be released in the coming weeks, attention is once again turning to a question that has shadowed the country’s financial sector for years: how do you expand access to finance without causing harm?

Cambodia’s experience offers a timely lens into that question, not because the answers are simple, but because the stakes are so high.

For years, Cambodia’s microfinance sector was celebrated as a global success story. From the mid-2000s through the 2010s, the sector grew at breakneck speed, hailed as a model of innovation and financial inclusion. But the shine began to wear off. Reports of over-indebted families, land seizures, aggressive loan collection practices, and even suicides shattered the narrative. Self-regulation and one-off financial literacy workshops were not enough. The sector needed something deeper—a rethink of how the entire financial ecosystem worked.

That rethink arrived in the form of the market systems approach, or MSA.

What Makes the MSA Different?

The market system approach doesn’t rely on checklists or isolated projects. Instead, it takes the view that responsible finance can only work when every part of the financial ecosystem pulls in the same direction.

✅ Clients need to feel empowered to make informed choices, raise their voices, and maintain dignity and control in their financial lives.

✅ Financial service providers must move beyond good intentions and embed client protection into their daily operations.

✅ Regulators must create the enabling environment that reinforces accountability, whether by backing stronger self-regulation, convening stakeholders, or, when needed, stepping in with formal rules.

✅ Investors need to use their leverage to demand responsible practices, while sector associations coordinate and set shared standards.

The message is simple but powerful: when one link fails, the entire chain breaks.

Cambodia as a Test Case

Cambodia became one of the first places to test this approach. Starting in 2021, Cerise+SPTF acted as a catalyst, working with the Cambodian Microfinance Association (CMA) and later the Association of Banks in Cambodia (ABC) to translate global Client Protection Standards into concrete, sector-wide practices. This included co-developing tools, facilitating alignment across institutions, and supporting the harmonization of codes of conduct so they became clearer, more consistent, and measurable across the sector.

This shift did not happen in isolation. The National Bank of Cambodia (NBC), alongside UN partners, played a critical convening role—bringing together regulators, financial institutions, and development actors to align on reform priorities.

The work didn’t stop at policy. At the community level, the Safe Finance initiative, launched by the National Bank of Cambodia and CMA and co-designed with technical support from Cerise+SPTF, reached more than 15,000 participants by the end of 2024. Most participants, living in rural areas, attended sessions on financial rights, responsible borrowing, and protecting themselves from scams, including via digital platforms. Meanwhile, in Ratanakiri province, an area hard-hit by over-indebtedness, Cerise+SPTF supported a pilot project that helped 331 participants across five villages, covering an estimated 219 unique households through local “village debt counsellors.” These counsellors worked directly with households to renegotiate loans, manage debt, and create a safe space for borrowers to share their struggles.

At the other end of the spectrum, Cerise+SPTF and its partners brought Cambodia’s boardrooms into the process. More than 350 CEOs and shareholders participated in governance workshops on client protection, reframing the issue not as a compliance burden but as a matter of risk management and long-term sustainability.

Through these coordinated, market-systems-level initiatives, Cerise+SPTF helped translate abstract principles into practical tools: training local and external actors, structuring outreach models, and ensuring that client protection reached beyond discussions into everyday financial decisions.

Wins and Warnings

A 360-degree evaluation of Cerise+SPTF’s Cambodia MSA found real momentum. For the first time, regulators, banks, microfinance institutions, investors, and development partners were sitting at the same table. Cerise+SPTF played a catalytic role in this process by helping surface client perspectives, identifying gaps in provider practices, and facilitating dialogue across stakeholders. This work contributed to the definition of 22 priority actions for responsible finance, many of which are already underway.

In practice, this has meant Cerise+SPTF acting less as an implementer and more as a system orchestrator—connecting actors who do not usually sit at the same table and helping them move from shared diagnosis to coordinated action. The process made clear that change cannot happen in silos: grassroots empowerment must move in step with board-level reform.

But the story is far from finished. Clients still lack strong channels to make their voices heard, particularly in rural areas where fear of formal lenders often silences complaints. Not all financial institutions embrace client protection with equal conviction; some act out of genuine commitment, while others respond only to external pressure. And while some investors have integrated client protection standards into their due diligence, their influence alone cannot solve the deep-seated issue of over-indebtedness.

Importantly, regulators have not remained passive. NBC has supported stronger self-regulation while keeping the option of formal regulatory intervention on the table.

Lessons That Travel

What Cambodia’s experience shows is that success in financial inclusion is not a single milestone but a continuum. Real change comes from building block upon block—codes of conduct, training sessions, community pilots, governance reforms—that gradually shift culture and behavior. Trust has been a critical currency, and in a market systems approach, progress often moves at the speed of that trust.

The Cambodian experience also demonstrates that the MSA is not confined to one country. Similar approaches are being explored in Laos, Benin, Dominican Republic, and beyond. Yet each rollout requires careful adaptation to local realities, local champions, and alignment with national priorities.

Why This Matters

Financial inclusion was built on the promise of lifting people out of poverty. Without strong safeguards, that promise can collapse into exploitation and harm. The market systems approach, tested under difficult circumstances in Cambodia, is showing that responsible finance is not corporate social responsibility fluff or ESG window dressing. It is about market stability, customer dignity, and long-term trust.

As one investor put it: “It’s not about looking good on paper. It’s about not harming the very people you claim to serve.

As new evidence on consumer empowerment in Cambodia emerges, the question is no longer whether reform is needed, but how to sustain and scale it.

The Cambodian story is still being written—but it is already offering something rare: not a perfect model, but a practical pathway for turning a microfinance or inclusive finance sector under scrutiny into one capable of learning, adapting, and rebuilding trust.

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