On 18th March, 2025, the Commission received an application from TNM Mpamba Limited for an Exclusive Dealing Arrangement (EDA) in the provision of e-ticketing solution in selling match tickets for Super League using Mpamba Debit Card.
The application followed a Notice of Investigation (NOI) dated 12th November, 2024 that the Commission issued to TNM Mpamba on alleged anticompetitive conduct. Specifically, the Commission came across a public statement to the effect that football fans will be required to purchase e-tickets using Mpamba only and loaded to the Mpamba Debit card effective 1st December, 2024.
The findings of the Commission’s investigations are as follows:
- TNM Mpamba Limited have developed an e-ticketing solution to help SULOM address the challenges brought about by the physical tickets and the manual verification of the tickets at the gates.
- The debit card will be accessed through a once-off price of K1,900.00 through various channels including agents, shops across the country and at multiple points at the football venues. Customers will be able to purchase tickets using TNM Mpamba Wallet. Non- TNM customers will be able to purchase the e-tickets through Mpamba agents.
- In Malawi, there are two main providers of mobile money services notably Airtel Mobile Commerce Limited and TNM Mpamba Limited. Other players in the market include banks and non-bank financial entities.
- With the introduction of the e-ticketing solution fans will be required to use Mpamba only together with the Mpamba Debit card to access the match tickets. Making the sale of match tickets exclusive to Mpamba only will not only affect football fans, who use other payment solutions but also other market players. The arrangement can potentially restrict access to competing payment service providers which could in turn lock them out of a significant market segment.
- The applicant is a subsidiary of TNM Plc who is the sponsor of the Super League. Additionally, TNM Mpamba Limited claims a relatively low mobile money market. It is evident, that making the sale of tickets exclusive to Mpamba only will limit consumer choice. The arrangement will restrict consumers from purchasing tickets using preferred mobile money platforms this transaction can potentially lessen competition in the relevant market.
- Further, the arrangement is contrary to the Payment Systems (Interoperability of Retail Payment Systems) Directive, 2017 and the Payment Systems (E-Money) Regulations, 2018, which emphasizes interoperability and discourages exclusivity among payment service providers.
- Additionally, the proposed arrangement is contrary to the vision of Malawi’s payments agenda, which aims to foster inclusive, efficient, and interoperable payment systems. Implementation of the EDA undermines the broader objectives of interoperability and market access.
- Awareness on the introduction of the e-ticketing solution is low as evidenced from most of the football clubs, the fans as well gate managers
- The Commission observed that the proposed agreement raises significant concerns from both the competition and public interest perspective than the benefits that would accrue from the implementation of the same. However, there is efficiency and public interest rationale to allow it roll out albeit on the understanding that the Respondent will timely allow interoperability with other payment systems so as to remove all aspects of market foreclosure.
Upon deliberations, the Commission made the following Orders:
- That the parties should implement the e-ticketing solution together with physical tickets for a period of 6 months from the date of the determination;
- That the parties should within one year from the date of the determination, open the e-ticketing solution to other financial/ payment service providers to ensure interoperability;
- That the parties should conduct awareness campaigns to educate the football clubs, football supporters and gate managers on the provision of e-ticketing solution during the period in above.
- That the parties should within every 90 days for the next 2 years; provide to the Commission verifiable evidence of compliance with Orders above.