The state of Open Banking in North America, 2025

The past year has been turbulent for Open Banking in North America. Here's what's happening in the US and Canada, and what it means for the industry.

Open Banking in the US

The US hit a milestone and an unexpected twist. On 22 October 2024, the Consumer Financial Protection Bureau (CFPB) finalised Section 1033 of the Dodd-Frank Act, introducing regulated Open Banking. That same day, the Kentucky Bankers Association, Forcht Bank, and the Bank Policy Institute filed a lawsuit claiming 1033 contained deficiencies and that the CFPB overstepped its authority.

Despite the lawsuit, Section 1033 was signed into law in January 2025, and the CFPB recognised FDX as an official Standard Setting Organisation. The administration change that month and the introduction of the Department of Government Efficiency (DOGE) led to major CFPB restructuring. Later in the year, the CFPB filed to vacate 1033, then reversed course and opened the regulation for revisions. Meanwhile, the Financial Technology Association (FTA) filed a motion to defend 1033 and preserve the regulation.

Open Banking in Canada

Canada made key progress on its Open Banking framework, named Consumer-Driven Banking. Canada’s Consumer-Driven Banking Act was passed in June 2024 as part of Bill C-69. The Consumer-Driven Banking framework was updated in December 2024, indicating a full launch projected for 2026. The Financial Consumer Agency of Canada (FCAC) was granted oversight of the framework’s ongoing development, implementation, and participant accreditation. Consultations are underway to form the regulation, which includes liability rules, security and privacy guardrails, and technical standards. While no official technical standard was named, market efforts have centred on FDX.

FDX hits all time high

In April 2025, the Financial Data Exchange (FDX) reported a record high of 114 million connected accounts via APIs aligned to its standard, a 50% year-over-year increase. This demonstrates FDX’s scale and the strength of industry-led collaboration driving Open Banking adoption in North America.

Pay to play

Open Banking traditionally operates on the premise that account holders own their financial data, and most jurisdictions don't charge for basic data access. Section 1033 aligned with this, explicitly requiring free access to covered data. Following the 1033 shake-up, JP Morgan announced in July 2025 its intention to charge data recipients for API access. This sparked support by some and fierce opposition by others.

Two months later, adaptation emerged: JP Morgan and Plaid announced an updated partnership where Plaid pays JPMorgan for data access. While the details of the deal aren’t published, this creates significant industry implications:

1. The precedent is set. Financial institutions will likely price their Open Banking APIs if permitted by regulation.
2. Monetisation becomes more straightforward. The cost of building and running APIs isn’t trivial, and now banks have direct monetisation options.
3. Industry-wide cost impact. Costs will pass to data recipients and consumers. Data recipients’ unit economics will shift, requiring adaptation.
4. Platform business models evolve. Other providers will likely announce similar paid deals.
5. Differentiation intensifies. Value-add services and out-of-the-box use cases will become even greater differentiators for Open Banking platforms, as data recipients shop for the best value.

Visa exits US Open Banking

Visa ceased US Open Banking operations just over a year after launching Tink in the market. Visa announced it will redirect its focus with Tink, which it acquired in 2022, toward Europe and Latin America.

While unexpected, this isn't surprising. Regulatory uncertainty and new data access fees created a challenging climate, especially for new entrants. Visa’s exit from US Open Banking underscores the need for platform differentiation and wholesome offerings that address the needs of both data providers and data recipients.

What’s next?

Despite rapid evolution, financial institutions can maintain momentum through three key actions:

1. Continue eliminating screen scraping. Whether 1033 stays or goes, replacing screen scraping with secure APIs provides a competitive advantage. Moving to APIs creates synergies that include tech stack rationalisation, efficiency, and improved data governance, identity, and security.

2. Evaluate API monetisation options. Fees for API access are no longer off the table. Examine monetisation options and model their impact on your business and clients.

3. Focus on key use cases to deliver customer value. The greatest value of Open Banking comes from implementing use cases such as streamlined account opening, enhanced payments, cashflow-based lending, and others. Prioritise and implement the top use cases to drive differentiation, personalisation, and customer value.

Open Banking in North America may be in a turbulent state, but make no mistake: it is here to stay. The organisations that move decisively now by building secure APIs and implementing value-driving use cases, won't just survive the evolution. They'll win with leading offerings, enhanced customer experiences, upgraded security and higher efficiency.

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.

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