Digital public infrastructure: the trust layers Namibia is assembling

A working definition

There is no single agreed definition. A policy brief for the G20 under India’s presidency argues a single definition is neither possible nor feasible. The UNDP compendium on digital public infrastructure and the sustainable development goals, published in December 2023, discusses the idea alongside a G20 consensus. Common definitions describe shared digital systems for identity, payments and data exchange, built on open standards and governed as public goods. This triad is practical for a small market: three things a service needs before it serves a citizen or a business at scale.

The test of an infrastructure is reuse. If each bank, each ministry and each app builds its own identity check, its own consent screen and its own signing method, the country pays for the same thing many times and users learn many different rituals.

The payments layer already exists

Namibia’s National Payment System is governed by determinations of the Bank of Namibia. PSD-7 asks for payments which are fast, safe and priced reasonably. PSD-11, published in July 2025, defines instant payments and sets their interchange. PSD-12 sets cybersecurity and resilience duties. Together they describe a rail with clear rules even before the instant payment programme is fully live.

The payments layer is the most mature of the three because the central bank has been its single regulator for years. The other layers have several authors.

The data layer is written but not yet binding

The Namibian Open Banking Standards, version 1.0, were finalised on 25 April 2025. Konsentus wrote them for the industry under the control of the Bank of Namibia, and the document says its content is not necessarily endorsed by the Bank. It also says the delivery timeline after the standards phase is not defined, with a live date expected in 2026.

The design is consent first. Nobody shares credentials. The account holder consents to a named third-party provider for a named scope and a named duration, using an authorisation code flow with proof key for code exchange and pushed authorisation requests. Consent expires after at most 180 days, after which the account holder confirms again. Phase 1 covers account information and payment initiation only, for consumers and small businesses. Enterprise accounts are excluded, and instant payments are listed as a future addition.

Notable gaps are named in the document itself. Who the scheme administrator is, the eligibility and capability criteria for participants, contract standards and the testing programme are marked as future or out of scope, and production pricing is to be decided.

The trust layer connects them

The open banking standards require mutual TLS on every request and response. Each participant holds a credential profiled under ETSI technical specification 119 495, a qualified website authentication certificate carrying the participant’s identifier, its role and the identifier of the national competent authority. The standards also list a certificate authority among the components of the scheme.

This is where the trust layer meets the data layer. CRAN presents the National Root CA as the anchor for accredited certification service providers, and Chapter 5 of the Electronic Transactions Act supplies the legal basis for accreditation. The open banking standards do not say which authority will issue participant certificates. The sensible design is one chain of trust for signatures, websites and participants alike, so each new service does not invent its own.

The identity layer is where reuse would pay most.

Three pillars of trust

The open banking standards describe a trust framework in terms useful beyond banking. Trust rests on three pillars. Trusted participants: only trusted players have access to data, and they are trusted to look after it. Trusted interfaces and data exchange: data moves securely. Trusted management processes: when problems occur they are resolved, account holders know where to turn, and measures exist if standards are not followed. Each pillar needs rules, standards, processes and infrastructure, and the document lists examples of the last: developer portals, interface catalogues, test environments, conformance systems and digital certificates.

Apply the three pillars to the other layers of public infrastructure. A population identity system needs trusted participants, meaning who is allowed to check an identity and for what. It needs a trusted exchange, meaning how an attribute is shared, with whose consent. And it needs trusted management, meaning who handles complaints and corrections. A country which designs the three pillars once and applies them across payments, data and identity avoids building a different trust arrangement for each.

Roles which recur across layers

The standards name roles which reappear in any shared infrastructure. A scheme administrator owns the rules and standards. A competent authority admits participants and issues their identifiers. Data providers hold the data or funds. Third-party providers offer services using them, with the account holder’s consent. Fourth parties, such as aggregators, work on behalf of third-party providers. A fifth party is a beneficiary receiving data or money at the account holder’s request, for example a tax authority or a credit checker.

The point of the vocabulary is accountability. When a customer complains, someone must be responsible, and the law needs to say who. In the open banking text the third-party provider is the party which legally captures consent and answers for the data, even if a fourth party touches it. The same principle suits identity and signatures: the party which collects the consent answers to the person, whoever runs the plumbing.

Accounts, wallets and inclusion

One annex of the open banking standards takes on a question with large inclusion stakes: whether an e-wallet is an account. From a consumer’s view, anywhere money is held counts as an account. From a compliance view, differences exist. A wallet holder might not have gone through full customer due diligence, the provider might not know the holder’s name, authentication is tied to the phone, balances are read through a USSD code on a feature phone, and wallets from different providers have not been interoperable. The standards include e-wallets in phase 1 for consumers and small businesses regardless.

The lesson for public infrastructure is plain. A system designed only for people with smartphones, bank accounts and identity documents will miss those who most need low-cost services. Digital public infrastructure earns its name when it works for the person at the edge: feature-phone access, assisted channels, local languages and offline-tolerant design.

Tax and customs sit in the same layers

The revenue chain shows how the layers join. The Namibia Revenue Agency’s 2023/4 annual report describes the Trade Verification System, launched on 16 October 2023 with the Bank of Namibia, which checks bank payment data against customs declarations. A declaration and its payment carry the same Unique Consignment Reference, and a mismatch in value is a signal to look. This is the payments layer, the data layer and the trust layer working on one case, and the Electronic Transactions Act gives each electronic message in it legal effect.

What this means for organisations in Namibia

A product team building for Namibia should design to the standards before they bind: consent with scope and duration, no credential sharing, and mutual authentication between parties. Retrofitting is costlier than starting right.

A policy maker should ask who owns the join between layers. A certificate issuer, a consent standard and a payment rule might each be sound while the user still faces three different journeys.