Data sharing has the potential to positively impact both consumers and the financial services industry.
The Payments Services Directive (PSD2) is a piece of sectoral legislation and does not break the silos to create an overarching and cross-sectoral data economy. However, it has brought experiences with user-controlled real-time data access. The experience with its implementation over the last few years therefore provides valuable lessons that should be considered during the Commission’s impact assessment work, the review of PSD2 as well as the Open Finance proposal itself.
The lessons learned from PSD2, in terms of the asymmetry in data access, misaligned incentives and the unbalanced liability regime, as well as the constantly evolving nature of the market must be taken into consideration for future legislation on open finance, where a focus on defining principles and outcomes should prevail over prescribing specific solutions that have proven to become ineffective and technically obsolete at a rapid pace.
If designed with the right framework, data sharing has the potential to positively impact both consumers and the financial services industry. However, given the experience with PSD2, EFR calls for the future Open Finance framework to follow a different approach and ensure that these lessons are taken into account.