M Bank's card book looks healthy from the outside — 67,900 active cards, transaction volumes climbing month over month. But under the hood, the acquiring economics are inverted: the more our customers spend, the more we pay away. Here's the full anatomy.
Over the 11-month window from April 2025 to February 2026, the total value of card transactions originated by M Bank cardholders was ₮239.75 billion. Of that, only ₮5.58 billion — about one tögrög in every forty-three — was acquired on M Bank's own POS network. The remaining ₮234.17 billion was routed through competitor acquirers under the BOM arrangement, generating interchange revenue for someone else.
The chart below shows the monthly split. The green line (ON-US) is climbing — from 1.07% of volume in April to 3.21% in February — which is the fastest structural shift in M Bank's acquiring history. But the grey bars (BOM) are climbing faster in absolute terms. The gap is widening, not closing.
The table below is the same data, laid bare. ON-US share has tripled in ten months — from 1.07% to 3.21% — which would normally count as a triumph. The problem: the absolute BOM pool is expanding faster than the share is shifting. In April 2025 we forfeited ₮8.64 billion. In January 2026 we forfeited ₮29.53 billion — 3.4x more, in ten months.
The conclusion is uncomfortable: at the current rate of share gain, M Bank is running harder just to stand still. A linear trajectory does not close this gap in any reasonable horizon. Only a discontinuous intervention can.
| Period | ON-US (₮M) | BOM (₮M) | ON-US Share | Merchants |
|---|---|---|---|---|
| Apr 2025 | 93.2 | 8,640.6 | 1.07% | 863 |
| May 2025 | 242.4 | 17,299.5 | 1.38% | 984 |
| Jun 2025 | 266.3 | 18,131.5 | 1.45% | 1,042 |
| Jul 2025 | 247.9 | 17,762.7 | 1.38% | 1,064 |
| Aug 2025 | 298.0 | 20,218.1 | 1.45% | 1,186 |
| Sep 2025 | 410.7 | 21,141.0 | 1.91% | 1,311 |
| Oct 2025 | 430.0 | 23,110.1 | 1.83% | 1,434 |
| Nov 2025 | 550.1 | 24,954.5 | 2.16% | 1,602 |
| Dec 2025 | 1,084.6 | 27,501.0 | 3.79% | 1,795 |
| Jan 2026 | 1,095.9 | 29,533.5 | 3.58% | 2,214 |
| Feb 2026 | 858.9 | 25,877.0 | 3.21% | 2,264 |
| TOTAL | 5,578.2 | 234,169.5 | 2.33% | — |
M Bank has issued 153,375 cards. Of those, 67,900 are currently active — a 44% activation rate, which is healthy. But only a small fraction of those active cards ever touch an M Bank POS terminal. The bottleneck is not issuance. It is not activation. It is routing — and routing is exactly what M idea attacks.
The funnel below shows the four stages, measured on the one-month snapshot window (Jun 2026). Each step is a moment where volume could have been captured ON-US and wasn't.
Only 3.3% of active cards crossed the ₮50,000 ON-US threshold in a given month — which is the exact population M idea is designed to mobilise. Scaling this to ~40% of active cards is the mechanical path to ₮10 billion monthly.
1. Network inertia. Cardholders default to whichever terminal is in front of them. If a merchant uses a competitor acquirer, the transaction goes BOM regardless of which card is tapped. We do not lose at the customer decision point — we lose at the terminal decision point, months earlier, when the merchant chose their PSP.
2. No reason to prefer. From the cardholder's perspective, a ₮50K grocery run feels identical whether it's routed ON-US or BOM. There is no in-moment cue, no visible benefit, no tangible reward. The routing decision is economically invisible to the person making it.
3. Merchant acquirers compete on price. The 3,230 merchants in scope — those paying 0.6% or higher MDR — are exactly the segment most vulnerable to competitor discounting. Without a reason to stay, they churn to whoever offers the tightest spread. We need them actively rooting for M idea, not passively accepting any terminal.
All three failures share one structural feature: they are incentive-shaped. Which means they are fixable with incentive design. That's Chapter 02.