Nicola Breyer believes that AI and Open Finance can unlock trusted, data-driven services at scale, if Europe turns policy into products and builds identity, governance, and real-time trust.
AI accelerates the transformation of our industry. Open Finance provides consented, regulated, and standardised data so banks, wealth managers, and fintechs can serve customers with personalised solutions. Brazil shows what frameworks can deliver at scale. Europe keeps pace only if we turn policy into products. In the UK, Open Banking usage reached 15.16 million active users in July 2025.
EU — FIDA: laying the foundations for Open Finance across 27 countries
FIDA is in trilogue under the Danish Council presidency. The intent is intact: give customers and SMBs access to all their financial data beyond the current account - savings, credit, investments, insurance, and pensions (occupational pensions under debate). The defining shift from PSD2 is scheme-based governance: designated schemes set technical and data standards, define liability, and agree compensation for data holders. If we want firms to invest, customers to consent, and supervisors to audit end-to-end, this is the right direction, although we still need the industry on board. We also require investment to build the data infrastructure that operates FIDA (FISP licence holders). Late calls to abandon FIDA miss the point.
UK — from Open Banking to Open Finance and Smart Data
In summer 2025, the Data (Use and Access) Act received royal assent, enabling economy-wide Smart Data schemes. Open Finance is first in line, complementing – not replacing – Open Banking. The practical signal is simple: design consent journeys and data contracts once, then reuse them across industries; also, start designing cross-industry solutions early. Adoption in payments keeps rising, supported by the government, which helps the credibility and viability of Open Finance players in the market.
Switzerland — market-led Open Banking and Open Wealth
Switzerland is taking an industry-led path. SIX bLink is the open-banking platform connecting banks and fintechs via standardised APIs for retail and wealth use cases (Account Information, Payment Submission, Open Wealth Order Placement). The OpenWealth Association maintains the wealth API standard (custody, order placement, customer management), while bLink operationalises it across participating institutions. This pairing – a platform rail plus a focused wealth standard – is a pragmatic model EU schemes can adapt as FIDA comes to life.
The Open Finance ecosystem — enabler of (agentic) AI
The time for silos is over. Regulation alone won’t deliver value. We need schemes, digital identity (eIDAS2/EUDI Wallet; the UK’s DI work), strong fraud controls, model governance, and modern cloud – plus agentic technologies that can act under supervision. That requires trust frameworks. Success means strong collaboration with customers at the centre. Building AI solutions at scale will require a human in the loop mid-term, but we need to build and learn how to solve unresolved questions around governance, security, and identity.
We need a strong data focus
Today, APIs are quicker to build, institutions run in the cloud, and customers are digital-first. Wealth will be moving between generations, while inflation and job insecurity strain households. Technology and AI can provide support at scale, but only if it runs on reliable, permissioned data – not PDFs and screen-scrapes. As domain-specific systems emerge, the imperative is to make institutional data AI-ready: accurate, timely, and well-labelled. If CEOs talk about AI governance, they should already be fluent in ‘data’.
So, where do payments fit in?
Real-time rails and payee verification reduce risk at the moment of execution. Pan-European wallets like Wero move from A2A to ecommerce acceptance – important progress, but I maintain value creation is still more in data, identity, and consent. Variable recurring models let assistants carry out small, reversible steps – keeping humans in the loop. We create new rails, but the key is: safe, explainable money movement that follows trusted data.
Looking into the crystal ball
Here are potential risks and upsides I foresee for the coming year and beyond:
- FIDA stalls – or Europe cannot align identity, AI, security, and data-protection regimes – causing fragmentation and delays across EU/UK/CH.
- Divergent scopes, consent UX, and liability models keep cross-border products brittle, especially in wealth.
- Death by prototype. Pilots that never scale because organisations avoid operating-model change; progress remains slideware. AI fails in scaling as governance cannot keep up.
- Disintermediation. Capital-rich global entrants capture the customer interface.
But what about the upside?
My hope is for: a pragmatic, phased FIDA implementation with workable economics; the UK’s Open Finance scheme moving from design to rollout; and in Switzerland, OpenWealth + SIX bLink serving retail and wealth use cases via standardised APIs. Add wallet-anchored consent so assistants act within explicit, revocable permissions, and pair it with safer real-time rails and payee checks. The result is a coherent European story: consented data, strong identity, explainable AI, and small, trustworthy actions that clearly improve outcomes.
My ask right now: prototype and learn, but also build security, governance, and consent management around customer expectations. Create value from the data you have. Pass FIDA and create sensible schemes. Learn from international successes. Move from defence to opportunity creation. The jury is out; what we do now counts. Let’s make it happen – as an ecosystem.
This editorial piece was first published in The Paypers' Open Finance Report 2025, the latest comprehensive market overview and analysis focusing on the key players and products within the Open Banking and Open Finance ecosystem. Download the full report to discover more insightful content.
About Nicola Breyer
Nicola Breyer is a former Open Banking CEO turned Open Finance Advisor. She is focused on agentic AI in financial services and the value of data for financial advisers and wealth managers.
