Voice of the Industry

Getting ready for Open Finance: do's and don't's

Friday 12 January 2024 13:02 CET | Editor: Vlad Macovei | Voice of the industry

Anne-Sophie Morvan from LUXHUB provides expert insights into exploring key strategies and pitfalls for Open Finance. 


Anne-Sophie Morvan from LUXHUB provides expert insights into exploring key strategies and pitfalls for Open Finance.


A few months ago, the European Commission published the review of PSD2 as well as a proposal for the long-awaited Open Finance Framework legislative proposal. If PSD3 and PSR are more of an evolution of PSD2, the real revolution lies in FiDA (Financial Data Access, the new and official name for the Open Finance Framework). The final timetable is still to be defined, yet, Open Finance will require important strategic, technological, and operational transformations in many of the companies concerned by this new proposal.

Subject to the end-customer permission, financial institutions will have to provide third parties with certain customer data continuously and in real time. Such provision of data shall be performed in the context of a financial data sharing scheme, which will determine notably the compensation that the data holder can request for such provision of data. In other words, Open Finance becomes a reality with FiDA and will present a myriad of opportunities for all stakeholders – financial institutions, third-party providers, but also private companies or public administrations.

Entering into Open Finance, or switching from Open Banking to Finance, could be challenging for some organisations and means incremental transformations on several key aspects. Today, we share our ‘Open Finance Do’s and Don’t’s’ and hope to help/support/accompany you in this exciting transition.


  • Anticipate your role in this new ecosystem. The scope of FiDA has been defined. Besides the communicated data sets, one key question to ask is what your role will be in this new Open Finance economy. Do you qualify as a ‘data holder’ or ‘data user’? Or both?

Therefore, the next step is obviously to understand the implications of Open Finance and define the use cases you wish to pursue, the benefit of your organisation (in terms of efficiency, processes, for instance) and your customers, with added-value services that you could provide them with.
  • Take part in the discussions that will help define financial data-sharing schemes. The definition of data-sharing schemes will be one of the keys to the success of Open Finance, even before it actually exists.

Unlike Open Banking, the financial data-sharing schemes are to be defined by the industry and its key players. Be one of those players.
  • Think of a ‘compensation’ strategy. FiDA mentions the possibility for data holders to, in a way, ‘be rewarded’ for the information they have, and ask for ‘reasonable compensation’ for making data accessible.

Financial institutions in scope clearly have to define their data compensation strategy, according to what will be included in the different data-sharing schemes. And also think about how much they are willing to pay to have access to certain data sets (still keeping in mind that the initial consent of the user is needed).
  • Think ‘customer first’. The Financial Data Access framework introduces the concept of ‘Permission Dashboards’, which will be provided by the ‘data holder’. These will be accessible in real-time for all customers, with a view of the ‘consent’ they’ve given to this or that TPP or financial institution. Consent management at its best.

  • Get in touch with expert companies. Companies that rose in the wake of PSD2 – and now specialise in all things Open Banking – have developed strong expertise in connectivity and compliance topics. Open Finance, as the natural evolution of Open Banking, will benefit from the experience acquired during the first years of PSD2.


  • Close your eyes and let competitors take advantage. Many questions need to be answered upfront. And even if we are almost 2 years ahead of actual Open Finance – and the timeline laid down by the European Commission is very ambitious – start laying down your overall strategy because most of your competitors have already started investigating Open Finance and its many opportunities.

What place do you want to have in this new game of chess? First mover? Follower? Don’t take part in it (as if that was even possible…)?
  • Do everything on your own. Collaborate with companies that have developed deep expertise in the fields of Open Banking (from compliance to connectivity) and with the ones that have already started to explore the infinite possibilities brought by Open Finance.

As FiDA relies mainly on Application Programming Interfaces, pick a partner that already runs an API platform and that has a proven track record using this technology.
  • Ignore data use perimeters. The EBA (European Banking Association), in collaboration with the European Data Protection Board, is going to develop guidelines to determine which personal data are necessary to perform a consumer credit score. This means that financial institutions will have to pay extra attention to the personal data processed in this context. 

FiDA is a strong statement from the European Commission to bring the financial sector to the next level, into the data economy. At LUXHUB, we firmly believe that this proposal – even if it could be extended to a larger scope of data – goes in the right direction to unlock the development of new business cases and innovative products for all stakeholders of the value chain. Our motto, ‘shaping the future of finance, together’ has never been more accurate. We look forward to working with you all and embarking on this new Open Finance journey to favour collaborative innovation!

This editorial piece was first published in the Open Finance Report 2023. We encourage you to download the report and find out the latest trends and developments in the world of Open Banking and Open Finance, as the road to Open Data continues.

About Anne-Sophie Morvan

Anne-Sophie Morvan (Chief Commercial Officer, LUXHUB) is passionate about Open Banking and more broadly Open Finance. Trained as an IT/data protection lawyer, Anne-Sophie is active in several professional bodies and European associations, and regularly publishes on related topics.


LUXHUB is a Fintech from Luxembourg, born in the wake of PSD2. It has evolved into a leading Open Finance player, and a connectivity and mutualization expert. LUXHUB provides compliance services (PSD2 XS2A, CEDR, CESOP and IBAN-name check) and solutions revolving around financial data aggregation and payment initiation.

Free Headlines in your E-mail

Every day we send out a free e-mail with the most important headlines of the last 24 hours.

Subscribe now

Keywords: Open Finance, regulation, FIDA, PSD2, PSD3, PSR
Categories: Banking & Fintech
Companies: LuxHub
Countries: Europe
This article is part of category

Banking & Fintech


Discover all the Company news on LuxHub and other articles related to LuxHub in The Paypers News, Reports, and insights on the payments and fintech industry: