THE Fair Trading Commission (FTC) has concluded that while bank account portability (BAP) offers clear benefits that can strengthen competition in Jamaica’s banking sector, the implementation of such initiatives may be a challenge on the economy’s resources.

The report, which was prepared by Alrick Livingston and Shavanne Smith, looked into different aspects of BAP, especially as the Bank of Jamaica (BOJ) moves to implement some of these initiatives to further spur competition in Jamaica’s banking system. The BOJ is aiming to launch a comparative banking web platform in March 2026 to improve customer awareness of banking fees, charges, and interest rates. That should be followed by an eKYC (electronic know your customer) platform which is 50 per cent complete and targeted to be launched in 2027.

“The Bank of Jamaica (BOJ) notes that limited account mobility is a key structural constraint hindering greater competition in the banking sector. The BOJ further notes that low competition is evidenced by high deposit concentration and various friction in the customer-switching process. Additionally, the BOJ notes that these issues contribute to inefficiencies in price formation and service delivery,” the report noted.

Currently, Jamaica’s banking system is dominated by National Commercial Bank Jamaica Limited (NCBJ) and the Bank of Nova Scotia Jamaica Limited (BNSJ), which have a 60 per cent market share. BOJ Governor Richard Byles has previously highlighted that there is inertia in customers moving between banks due to KYC requirements. KYC requirements are a regulatory requirement for customers to open accounts with financial institutions. While there has been an improvement with the removal of the reference requirement, the KYC process continues to be a hurdle for new accounts.

“BAP promotes competition by reducing market frictions (in particular switching costs). In the context of banking, switching costs are the opportunity costs customers incur when moving their accounts from one bank to another. These costs can include administrative hassles, updating automatic payments and direct deposits, KYC, potential service interruptions, and even emotional attachment or familiarity with the existing bank,” the FTC report added on the benefits of BAP to Jamaica’s banking sector.

The FTC’s report highlighted that BAP is split into different components such as deposit portability, payment portability, data portability, and credit portability. These components have been implemented in different markets such as the United Kingdom, European Union, India, Brazil, and Australia. Whilst each jurisdiction implemented a different form of BAP to benefit consumers, there were constraints with each model. The UK and EU’s models allowed easy switching of accounts between banks, but the account number/details could not be transferred between banks. Australia implemented a consumer data right (CDR) approach in 2020 to allow consumers to have their banking data shared with accredited third parties. However, the adoption process has been slow despite significant costs since 2018.

“At the same time, the evidence and international experience reviewed show why full, immediate implementation of BAP may challenge the economy’s resources. Technical complexity, heavy operational and coordination demands, legal and data-protection issues, meaningful implementation costs, and entrenched behavioural inertia all mean that BAP remains a large system reform rather than a single policy tweak. These multi-dimensional barriers help explain why no jurisdiction has yet rolled out seamless BAP at scale, even where strong political will exists,” the FTC noted in the constraints to implement full BAP.

While the BOJ continues to work on initiatives to improve competition in Jamaica’s banking sector, the FTC highlighted that there are lessons that Jamaica can adapt from other markets. These included improved switching services, open-banking APIs (application programming interface), credit portability, targeted data portability measures, and centralised utilities built on clear governance and liability rules. The FTC pointed out that BAP shouldn’t be seen as a single endpoint to be forced immediately, but as a sequence of complementary reforms and infrastructure investments.

“Policymakers can take the practical first steps identified in this paper, leverage electronic KYC and open banking building blocks, and address legal and consumer-protection gaps to steadily unlock the competitive and consumer benefits of portability while managing the technical, operational, and security risks. These measured actions offer a realistic road map for translating the promise of BAP into tangible gains for Jamaican consumers and the wider economy,” the FTC closed.