The proposed financial data access regulation (FIDA), presented in June 2023 and still under negotiation in trilogues, aims to take open banking beyond payments: savings, investments, insurance and pensions, with authorized FISPs and data-sharing schemes with compensation.
Is open finance on your roadmap? We help you position yourself
Tell us whether you hold customer data or want to use it, and we will explain what FIDA means for your model and what to prepare now.
FIDA is not yet law, but the direction is clear. Six services to reach the final text with your strategy, data and licenses in order.
We analyze your position in the data ecosystem (who holds the data, who wants to use it), follow the FIDA negotiations and design your phased plan: what to decide today, what to leave until the final text and what never to do.
Access to payment accounts is already law. If your model needs financial data, the operational route today is PSD2 and the AISP and PISP roles: we help you set it up while open finance matures.
The current role for reading payment account information with the customer’s consent. The direct precedent of the FISP.
Initiating payments from the customer’s account without being their bank: the other pillar of open banking, which you can already activate.
Access rights, strong customer authentication and payment account APIs: what is already required, and of whom.
The review of the EU payments framework is moving forward alongside FIDA. The two files are best read together.
Four different positions on FIDA: data holders, would-be FISPs, firms that want to use data and providers that will build the plumbing.
"We have decades of savings, insurance and pension data on our customers. Under FIDA we would have to give third parties access within schemes with compensation: either we design our strategy now, or others will design it for us."
"Today we aggregate payment accounts as an AISP. FIDA would open up investments, insurance and pensions to us: we would go from showing balances to building the customer’s complete financial picture. We want to be first in line for authorization."
"Our advice improves if we can see the customer’s positions at other institutions, with their permission. Open finance would make standard what we now solve by asking for PDF statements."
"Data-sharing schemes will need APIs, standards and permission management. We are positioning ourselves as the technical provider for institutions that will not want to build it on their own."
The proposal is still in trilogues and its text may change, but the direction of the leap is clear. Compare it with what already exists under PSD2.
Actual status of the file: FIDA is a June 2023 proposal for a regulation under negotiation between the EU institutions. There is no final text and there are no binding application dates: be wary of specific timelines and work with scenarios.
The scope multiplies: from access to payment accounts (PSD2), it would extend to savings, investment, insurance and pension data, with new categories of data that can be shared at the customer’s request.
The economic model changes: unlike access under PSD2, FIDA proposes data-sharing schemes in which access is organized with compensation, turning data into a line of business and not just an obligation.
| Open banking (PSD2, today) | Open finance (FIDA, proposal) | Impact |
|---|---|---|
| Access to payment accounts: balances and transactions | Access to savings, investment, insurance and pension data, at the customer’s request | The customer’s complete financial picture comes into play: more use cases and more responsibility for the data |
| AISP and PISP roles with a payments license | New authorized FISPs for access to financial data | Anyone who wants to use data will need an enabling status; getting the license early will be a competitive advantage |
| Access provided within the PSD2 framework | Sharing organized in schemes with compensation among participants | Data stops being just a compliance cost: scheme contracts, fees and governance come up for negotiation |
We help you decide your position in open finance: what data you hold and what data you will want to use, which licenses enable you today (AISP, PISP) and how to reach the future FISP status with the groundwork done. Tracking of the negotiations included, with no hype and no made-up dates.
FIDA (Financial Data Access) is the proposed EU regulation on financial data access, presented by the Commission in June 2023. It is the centerpiece of the open finance agenda: allowing customers to authorize third parties to access their financial data beyond payments.
Important: it is a proposal under negotiation (trilogues between the EU institutions). Its final content may change and it does not yet create enforceable obligations.
There are no binding dates as of today. The file is still under negotiation and, until the final text is published, any specific timeline is speculation. Once it is adopted, we can expect (as is usual for this type of legislation) transitional periods before it fully applies, on the terms set by the regulation itself.
Our recommendation is to work with scenarios: data and architecture decisions that are worthwhile whatever the outcome, and licensing decisions that are triggered once the text stabilizes.
The proposal extends access, at the customer’s request, to categories of financial data beyond payment accounts: savings, investment, insurance and pensions, among others provided for in the text under negotiation.
For institutions that hold that data, the operational question is uncomfortable but urgent: could you locate, structure and serve that data today with sufficient quality if an authorized third party requested it? The data inventory is work you can already do.
The FISP (financial information service provider) is the role the FIDA proposal creates to access customers’ financial data with their permission: an authorized and supervised status, similar in its logic to the open banking AISP but with a much broader data scope.
If your fintech already operates as an AISP, you are halfway there culturally: permission governance, security and dealings with supervisors. The other half (the scope of FISP status) depends on the final text.
On three levels:
You will find the current framework explained on our PSD2 and open banking pages.
They are FIDA’s organizational building block: structures in which data holders and data users agree on standards, responsibilities and compensation for access, within the framework set by the regulation.
In practice, this means open finance will not be just about technology: there will be scheme contracts, fees and governance to negotiate. Institutions that come to that table with a defined data strategy will negotiate; the rest will sign whatever is put in front of them.
Three things that are worthwhile whatever the final text:
And a fourth, cross-cutting front: the technological resilience that DORA already requires of your systems and providers.
Build on what is already legal: access to payment accounts via AISP or payment initiation via PISP lets you launch a product today and build regulatory experience that will count with the supervisor tomorrow.
In parallel, design your target product with the FIDA scope in mind and follow the negotiations with sound judgment. This is the approach we apply in fintech regulation: launch with today’s license, ready for tomorrow’s.
You cannot comply with a rule that does not exist yet, but you can reach it with an advantage. This is the plan we propose to institutions and fintechs: no-regret decisions first, conditional bets later.
Are you a data holder, an aspiring data user, or both? We map your data, your use cases and your competitors, and define what FIDA would mean for your bottom line: a threat of disintermediation or a product opportunity.
Data inventory and quality, permission governance, security and data protection compliance, and, if you need to use data now, the current open banking licenses. All of this is worthwhile whatever is finally adopted.
Monitoring of the trilogues with alerts on relevant changes, design of the target product within the FIDA scope and a FISP authorization plan ready to activate once the text and its deadlines stabilize.
If you want us to run this plan with you, start with our fintech regulation service, or activate the current layer now with the AISP and PISP licenses.
The FIDA debate mixes new acronyms with open banking roles. This glossary gives you the map to read the proposal (and your competitors) without getting lost.
Proposed regulation on financial data access presented in June 2023. Under negotiation: it does not create obligations yet.
The extension of open banking to the rest of the customer’s financial life: savings, investments, insurance and pensions, always at the customer’s request.
Access to payment accounts under PSD2 through AISPs and PISPs. It is the law today and the practical training ground for open finance.
Authorized status created by the FIDA proposal to access customers’ financial data with their permission.
A structure in which data holders and data users agree on standards, responsibilities and compensation within the FIDA framework.
FIDA proposes that access to data be organized with compensation within the schemes, in contrast to the open banking model.
A bank, insurer, asset manager or pension provider that holds customer data and would have to make it available under FIDA.
PSD2 role that reads payment account information with consent. The functional predecessor of the future FISP.
Negotiations between the Commission, Parliament and Council to finalize the regulation. Until they end, all content is provisional.
A defined position on open finance: role (data holder, data user, FISP), prioritized use cases and a business impact analysis.
Positioning paper approved by senior management, competitive analysis and a map of use cases with their regulatory fit.
Savings, investment, insurance and pension data located, classified and with measured quality, ready to be exposed if the rules require it.
Data catalog by source system, quality metrics and a dated plan to remediate gaps.
Traceable management of customer consents and revocations, aligned with data protection by design.
Design of the permissions register, legal basis analysis by use case and documented impact assessments.
Current authorizations (AISP/PISP) for the use cases that are already possible, and a FISP authorization plan conditional on the final text.
Licenses held or applications in progress, fit analysis by service and a versioned FISP activation plan.
Systematic monitoring of the FIDA trilogues and of the payments framework review, with the impact translated into decisions.
Periodic monitoring reports, a change log for the file and minutes of the decisions taken as a result.
Five mistakes we see again and again in management committees and product plans. All of them can be fixed if spotted in time.
FIDA will not arrive in a vacuum: it will land on top of a payments framework under review, existing fintech licenses and the technological resilience requirements already in force. These pages complete the board you will have to play on.
The EU payments framework is being reviewed in parallel with FIDA: two files best read as a single move.
How the PISP service works in practice: the star use case of open banking, already generating revenue.
Which authorization each business model handling customer data and money needs: the full map of license types.
Exposing and consuming data requires resilient systems: DORA has applied since January 2025 and reaches your ICT providers.
Building products on financial data? See also open banking and the AISP and PISP roles. And if your project is just starting, our fintech regulation team helps you choose your license and architecture with an eye on FIDA.
Tell us about your model (bank, insurer, asset manager or fintech) and we will explain how FIDA would affect you and what moves to make while it is being negotiated.
Open finance is the next frontier for financial data in Europe: letting customers authorize third parties to access not only their payment accounts but also their savings, investments, insurance and pensions. Its legal instrument is FIDA, the proposed regulation on financial data access presented by the European Commission in June 2023 and currently under negotiation in trilogues. To put it bluntly: there is no final text and there are no binding application dates, and anyone planning around specific timelines is speculating. What there is, though, is a clear direction on which work can (and should) already begin.
FIDA rests on three pillars. First, a customer right to have their financial data (beyond payments) made accessible to third parties at their request. Second, a role authorized for that access: the FISP, an authorized and supervised financial information service provider. Third, data-sharing schemes, in which data holders and data users agree on standards, responsibilities and compensation for access. This last pillar is the most disruptive for business: data stops being a regulatory cost and acquires its own contracts, fees and governance.
Today’s open banking, built on PSD2, opened up payment accounts through the AISP (information) and PISP (initiation) roles. FIDA multiplies the scope to cover investments, insurance and pensions; replaces the access logic with schemes with compensation; and creates a new status, the FISP, for data users. In parallel, the review of the payments framework (PSD3) is moving forward: two files that institutions would do well to read as a single move by the EU legislator on financial data.
For banks, insurers, asset managers and pension providers, the no-regret work is threefold: data inventory and quality (knowing what you have, where it is and in what condition), permission governance (how you will record consents and revocations in a traceable way) and a strategic decision (being only a data holder with sharing obligations or also a user of other firms’ data to compete). On top of this comes the technology baseline that is already required today: the operational resilience rules of DORA, applicable since January 2025, which will fully cover any data-sharing infrastructure.
The paradox of open finance is that the best preparation for FIDA is to operate well under the current framework. A fintech that today aggregates accounts as an AISP or initiates payments as a PISP builds up what the future FISP status will presumably value: experience in permission management, security, dealings with the supervisor and a proven product. That is our approach in fintech regulation: launch with today’s licenses, design the target product for tomorrow’s scope and actively monitor the trilogues so the FISP plan can be activated as soon as the text and its deadlines stabilize.
Key legislation, linked to the official text:
Legislation and links reviewed in .