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TRACFIN 2021 Operations & Analysis Report


TRACFIN 2021 Operations & Analysis Report

Open banking has emerged strongly in the past few years
as a system to give customers the right to share with
parties they trust the information that banks have about
them in a secure manner and also as a way to open up
processes and services in banking. The main objectives
pursued by regulatory frameworks that define open banking are generally encouraging innovation and fostering
competition, resulting in new products and services at
competitive prices to the benefit of consumers.
With that in mind, and with the United Kingdom as a
first mover, different regulatory approaches have been
developed. Some of them are regulatory driven, while
in other cases, with a hands-off approach, they have
been led by industry. In between, we also find collaborative models in which both the public sector and private-party players are instrumental to the definition and
adoption of open banking.
Regulatory approaches also differ in the scope of data that
is to be shared, the definition of the financial institutions
that have to publish their application programming interfaces and share data, the mandatory or voluntary nature
of the framework, the definition of the type of license that

third-party providers need to operate, and the definition
or not of concrete standards, among other things.
While there is no single right approach, there are common challenges that countries considering regulation
certainly need to bear in mind in terms of the definition
and interoperability of technical standards, security, governance, and consent and authentication mechanisms.
With different strategies and intensity, some banks are
starting to be active in the development and opening of
their application programming interface frameworks. On
the other hand, different business models and players
have emerged to connect banks with fintech companies
through a middleware of application programming interfaces, especially in Europe, the United States, and some
Asian countries.
Although open-banking regulatory frameworks have
been operating for less than two years at most, early lessons can be drawn from the first movers and the debates
that are taking place between regulators and market


• 1

1. Introduction and Background

The Financial Inclusion Global Initiative (FIGI) is implemented in partnership by the World Bank Group, Committee on Payments and Market Infrastructure, and
International Telecommunications Union and is funded
by the Bill and Melinda Gates Foundation to support and
accelerate the implementation of country-led reforms to
meet national financial-inclusion targets and, ultimately,
the global Universal Financial Access 2020 goal.
FIGI funds national implementations in three countries
(China, Egypt, and Mexico) and supports working groups
to tackle three sets of outstanding challenges for reaching
universal financial access: (1) electronic payment acceptance, (2) digital ID for financial services, and (3) security.
FIGI also hosts three annual symposia on relevant topics
to gather national authorities, the private sector, and the
public and to share emerging insights from the working
groups and country programs.
The Mexico FIGI Program aims to expand access to transaction accounts and broader financial services by more
empowered users. This objective will be achieved by (i)
enhancing the design of payment and financial products,
including through the innovation of technology and business models to meet the needs of underserved individuals and micro, small, and medium-sized enterprises, (ii)
fostering the sustainable expansion of physical access
2 •


points, in parallel with leveraging technology for remote
access, and (iii) empowering users through increased
transparency and the use of transactional and other relevant data. The Mexico FIGI Program includes six different
components: (i) access points, (ii) digital ID, (iii) fintech
regulation, (iv) financial consumer protection, (v) financial literacy, and (vi) large-volume payments.
Article 76 of the Fintech Law determines that financial
institutions, money transmitters, credit information companies, clearing houses, regulated fintech companies, and
companies authorized to operate with new models will
be required to establish application programming interfaces (APIs) that allow interconnectivity between these
institutions. The Fintech Law also requires the development of secondary regulations by the National Banking
and Security Commission (Comisión Nacional Bancaria
y de Valores, CNBV) for banks and financial institutions,
including the new Financial Technology Institutions, and
by Banco de México for payment systems, central counterparties, and credit-reporting systems. The Fintech Law
states that entities required to create APIs shall share
three types of data: (i) open financials, which are nonconfidential data including information on services offered
and access points; (ii) aggregate data, which are those
related to the statistical information of its operations; and
(iii) transactional data, which are those related to the use

of financial products and services by a consumer. The
General Dispositions issued by the National Banking and
Security Commission and Banco de México establish the
common technical standards that ensure the interoperability of APIs, including their design, development, and
maintenance standards. The secondary regulations also
establish the security mechanisms to access, send, and
obtain data and information and outline the information considered critical for the good functioning of the
applications requiring access to APIs. Finally, the General
Dispositions outline the process to obtain consumers’

consent to access their transactional data. As per the Fintech Law, to permit transactional data to be shared and
accessed, the consumer shall grant authorization, and the
data shall be used only for the uses expressly authorized
by the consumer. The consumer can also withdraw this
authorization at any time.
In this context, Mexican authorities are interested in understanding the approaches pursued in other markets and
fintech ecosystems to inform and develop their own policies and regulation effectively.


• 3

2. Context for Open Banking

The increasing interaction and use of bank-held customer-permissioned data by third parties has led different
countries to take regulatory actions on different aspects
of open banking.1 Data sharing has taken place though
different techniques, such as screen scraping and reverse
engineering, as standard market practices. However, regulations are generally encouraging the use of APIs, considering the use a more secure and reliable practice.
Some jurisdictions have taken a prescriptive approach,
requiring banks to share customer-permissioned data
and requiring third parties that want to access such
data to register with particular regulatory or supervisory
authorities. Other jurisdictions have taken a facilitative
approach, issuing guidance and recommended standards and releasing open API standards and technical
specifications. Remaining jurisdictions follow a market-driven approach, having no explicit rules or guidance
that requires or prohibits banks from sharing customerpermissioned data with third parties.

4 •


The frameworks created vary across countries in terms
of stage of development, approach, and scope. Indeed,
most regulations are in the early stages of development,
and many were issued or came into effect in 2018 or later.
It is therefore still very early to draw substantial lessons.
In any case, the countries that are developing their regulatory frameworks are looking at learnings from the early
Finally, while some topics have not been incorporated
into any regulation yet and hence are beyond the scope of
the technical note, they are on the agenda for discussion
in many countries. The role of bigtech firms in the data
economy, the extension of data sharing to other sectors
of the economy (referred to as “smart data”), or potential
efforts toward international interoperability are examples
of issues that will very likely have the attention of regulators in the near future.

3. Objective of the Technical Note,
Scope, and Methodology

Mexico issued its Fintech Law in 2018 with the purpose of
regulating financial services provided by financial technology institutions that are offered or performed by innovative means. This law is based on the principles of financial
inclusion and innovation, the promotion of competition,
consumer protection, the preservation of financial stability, the prevention of illegal operations, and technological neutrality. A general approach to the open-banking
framework in Mexico is contained in the article 76 of the
Fintech Law.
To give context to the Mexican authorities as they
develop their secondary regulation around consumer
data-driven open banking, this technical note reviews
open-banking regulations and practices in those countries that are more advanced in that respect. To understand the different elements to consider when developing
a regulation, the following aspects of API infrastructure
are analyzed: governance, technical requirements, security measures, outsourcing models, interoperability, and
access to third parties. Also, a review of the players providing API infrastructure has been included. Aspects
referring to consumer rights around the use of their
data and regulations affecting the use of their data have

also been considered. Additionally, those initiatives that
include authentication of consumers have been taken
into account. Finally, incentives to adopt APIs have been
reviewed. A comparison of how different countries have
approached these elements, as well as lessons learned
from early implementation, could serve as a guide for
future regulatory efforts.
Countries analyzed for this technical note include Australia, Brazil, Canada, the European Union, Hong Kong,
India, Japan, Mexico, New Zealand, Singapore, the United
Kingdom, and the United States.
Part of the analysis in this note is based on a desk
review of (a) relevant regulations in the abovementioned
countries; (b) materials on open banking by the World
Bank and other international financial institutions; (c) literature on open banking by international market analysts
and other reliable sources; and (d) reports and consultations made public by different countries.
The desk review was complemented with information gathered through in-person and phone interviews
with authorities, market participants, lawyers, and other
experts from the countries included in the scope of this
technical note.


• 5

4. Challenges and Opportunities of
Open Banking

A new wave of disruption has been progressively introduced in the retail banking industry in the past few
years. Open banking can securely provide other financial institutions and third-party providers (TPPs) with
seamless access to customer data through APIs and
enable banks and non-banks to provide integrated
modular services sourced from different specialist firms.
This consent-based access to data and the potential
communication that it allows open great opportunities
for innovation to banks, fintech companies, and other
players. This access to data is not exempt of risks; to
reap the full benefits of open banking, they must be
accounted for.
From the standpoint of banks, they have traditionally
been in control of the data about their customers, and
within a closed architecture, this allows them to make use
of that data and gives them the initiative on the design
and development of products. Opening to third parties
requires API developments that enable other players to
have access to their customers’ data and to play a role
in the production and delivery of financial and auxiliary
services, moving banks to some extent from their comfort zone and opening up to competition. The need to
develop and maintain an API infrastructure, the time and
cost involved, the potential loss of revenue, more complex distribution of liabilities between banks and third
parties, and cybersecurity are among the challenges
6 •


that banks are facing. At the same time, implementation
of open finance allows banks to develop new business
models with potential new revenue streams and, to the
extent banks also connect with other banks or players,
have deeper insight into their customers.
As far as fintech companies are concerned, open banking creates an environment that encourages the development of the ecosystem. Access to consumer data and
collaborative business models with banks enable great
opportunities for innovation. Building the necessary security and compliance elements that an adequate treatment
of customers data require is an important challenge for
fintech companies.
Consumers, for their part, are probably the biggest
winners from a move toward open banking. While some
concerns may arise about privacy and data security,
access to a wider range of services, improved user
experience, lower prices that increased competition
entails, and the potential for wider financial inclusion
are important gains. Those gains could be enhanced
with “dynamic efficiency” as the process around data
exchange consolidate.
Concerning regulators, they can find in APIs a more
stable framework of data sharing, with enhanced security. Also, the development of solutions could potentially
contribute to more efficient surveillance and compliance
of banks. Open banking could play a role in the areas of

regtech and suptech, capturing information directly from
financial institutions through APIs and, hence, significantly automating the supervision. At the same time, this
could allow financial institutions to meet their compliance
obligations in a more efficient manner. One interesting
example in this direction is AuRep, an innovative regulatory reporting system that has been implemented by the
Austrian central bank and the country´s banks to capture
data directly from financial institutions.

Regulators are also facing important challenges in an
open-banking framework, such as the need to have new
technical capabilities to analyze APIs, the need to resolve
conflicts between banks and fintech companies, and
coordination among regulators.
Finally, all the players involved on the potential extension are challenged by data sharing to other sectors of
the economy and the role that bigtechs might be playing
in the data economy.

TABLE 1: Challenges and Opportunities of Open Banking




Fintech Companies



New business models
New revenue streams

Enables ecosystem

Wider range/choice of

More stable exchange of

Deep customer insight

New business models

Enhanced security

More user-centric solutions

Collaborative business
models with banks

Improved user

Need to develop API infrastructure
(cost and time)
Competition and revenue loss
New distribution of liability
Business model risk
Customer disintermediation

Lower prices

Scale faster

Financial inclusion




Data security

Potential for suptech
Need to have technical
capabilities to analyze
Need to resolve conflicts
between banks and TPPs
Coordination among

Source: Author’s summary


• 7

5. Legal Framework of Open Banking
and APIs in Selected Countries

Open banking offers great opportunities for incumbents,
new service providers, and consumers. At the same time,
banks and financial institutions are big targets for criminals, and the loss or misuse of financial data can cause real
damage and distress to individuals. The risk of data loss,
privacy breaches, fraud, and other cybersecurity attacks
is real and increasing. Therefore, banks and financial service providers face new legal responsibilities to prevent
the unauthorized or unlawful processing of data and to
prevent loss, destruction, or damage. In such a context,
there might be a need to balance legal and regulatory
provisions related to information sharing and enabling
access by different institutions with legal provisions
related to data protection. Since rules are enacted by different authorities, potential conflicts of law might exist. In
addition, one of the objectives of enabling open banking
is to provide consumers more control over their account
information and the possibility to decide with whom they
would like to share such data. In such a context, consumer consent to allow third parties to access information
through APIs has become a key issue in the formulation
of the legal and regulatory framework of open banking.
Safeguarding competition, strengthening market contestability, and protecting the integrity of legal frameworks in the face of innovations from payment initiation
and account services/aggregation are the main reason
why the European legislator has decided to intervene and
8 •


why national authorities are implementing and enforcing these rules. On the one hand, large financial institutions (or groups thereof) held too much control over the
industry and the array of payment and other services that
users could combine with their core banking services. On
the other hand, big techs are entering the financial market and are outside of the regulatory perimeter. Avoiding
regulatory arbitrage has become a key priority for financial-sector regulatory authorities.
Data sharing is one of the key aspects of open banking,
and safeguarding such data is also important. In this context, the adoption of measures to secure not only data but
also networks, software, applications, hardware, and facilities is a relevant element of the design of open finance
ecosystems. This security includes not only banks and
institutions accessing data through APIs but also institutions that provide outsourcing services to banks and
other institutions accessing their data, including providers
of cloud-computing services.
Sharing data through the screen-scraping technique—
where a TPP or financial data aggregation service accesses
bank accounts on the consumer’s behalf using their credentials—raised consumers’ as well as lawmakers’ and
banks’ concerns, as there was no possibility to limit the
time or scope of data accessed by the third party. Open
banking therefore requires a new approach to authentication and access to permissioned data.

The adequate assignment of accountability for financial losses in the event of erroneous data sharing is also
a relevant legal aspect that is typically covered under
contractual arrangements that might not be enforced in
a rapid manner.
Finally, one additional important point is the adoption
of alternative dispute-resolution mechanisms, established
either by banks or by the third parties through processes
and procedures and contractual arrangements between
banks and third parties.
Although early precedents are also in other constituencies, the United Kingdom was the first country to regulate
open banking; the Open Banking Standards went live in
January 2018. Since then, the number of countries defining their open-banking regulatory frameworks has been
The first attempt to create an open-banking framework
in the United Kingdom was the Midata Initiative, which
was launched in 2011 by the Department for Business,
Innovation and Skills with the objective to give consumers
greater access to their transaction data in a portable electronic format. Banks voluntarily supported the initiative
by providing downloadable account-transaction data in a
standardized file format. Customers needed to download
these files, save them to a disk, and then upload them.
Providers, in turn, would analyze the data and make recommendations based on them. Midata was rolled out in
2015 but emerged with serious problems, in particular a
very poor user experience. The project was not as satisfactory as had been envisaged and did not reach wide
adoption. However, it served well as a learning experience
for the framework to be designed later.

Envisaging the important benefits that open banking
could unlock, the Treasury and the Cabinet Office commissioned a report2 in 2014 to assess the opportunities
that a model of open banking with data on bank transactions shared with APIs could entail for banks in the United
Kingdom. The authors concluded that a greater access to
data would improve competition, and they made a strong
case for the use of common standards to enable interoperability between banks and providers.
As a next step toward establishing open banking in the
United Kingdom, the Treasury in 2015 created the Open
Banking Working Group, with representatives from the
banks, open-data groups, consumers, and TPPs, to determine the practical definition of data sharing. In 2016, the
working group published a framework for banking data
sharing and guidelines on how to implement it.3 The group
recommended standardized APIs to be shared.
In parallel to those developments in the United Kingdom, important pieces of regulation emerged at a European level affecting how open banking and data sharing
were unfolding in the United Kingdom—namely, the
revised Payment Services Directive (PSD2) and the General Data Protection Regulation (GDPR). These will be
analyzed later.
The Competition and Markets Authority (CMA) conducted an investigation of the retail banking market in
2017 that resulted in the issuance of a mandatory order4
concluding that competition was insuffient in the United
Kingdom, leading to high prices and insufficient incentives
to innovate, to the detriment of final consumers. Among
the remedies that merged from this result, the nine largest
banks (referred to as the CMA9)5 were obliged to make

FIGURE 1: Open-Banking Timeline
RBI Report Working
Group Fintech
Retail banking market
investigation order






Mi Data


Hong Kong





Open Banking

PSD2 published

Payments NZ launch API
New Zealand

API Playbook




decision in

First Open API
Fintech Law

Farrell Report

PSP2 RTS deadline

PSD2 applies

Amendment to the
Banking Act Japan

EBA Working Group

Launch review
open banking


Central Bank

Review open

Source: Author’s summary based on public information


• 9

customer data from their current personal and business
accounts available to authorized third parties through
APIs. The CMA also established an implementation entity
to write the standards, build the supporting infrastructure, and coordinate and drive the implementation. The
design of open banking was delegated to an individual
(the Trustee), who would head up a body, the Open Banking Implementation Entity (OBIE), that would work with
stakeholders across the sector to deliver open banking
and at the same time have powers delegated to compel
banks to comply. Open banking went live in January 2018,
with the launch of the first account-information API. Once
the implementation phase is complete,6 the role of the
OBIE will transition into a monitoring role to ensure that
banks continue to meet their obligations.
Among the early learnings from the United Kingdom’s
experience, analyzed in a report commissioned by the
OBIE,7 the importance of enhancing the user experience,
the need to improve payment capabilities, the need also
to improve consent protection for customers, the possibility to expand open banking into open finance, and the
introduction of premium APIs that go beyond the mandatory ones could be highlighted.
While the United Kingdom’s experience has opened
the way and been taken into account by other countries,
different models and regulatory approaches to open
banking have emerged.
In Europe, PSD28 came into force on January 12, 2016,
and for most of the provisions, member states had until
January 13, 2018, to implement them into national laws.
The most impactful parts of PSD2 related to open banking are the introduction of new payment-initiation and
account-information services operated by TPPs that are
granted access to bank data though APIs, and the provisions on strong customer authentication (SCA) for online
payments. The PSD2 security measures related to TPP
account access and to SCA were further detailed in the
European Banking Authority Regulatory Technical Standards (RTS),9 which were foreseen to enter into force on
September 14, 2019. Finally, due to the complexity in the
implementation, the European Banking Authority (EBA)
has allowed national authorities to postpone for a year
the introduction of the RTS for online payments.
At a European level, no common APIs standard have
been adopted. Different set of standards have been proposed by bodies representing coalitions of European
banks (for example, STET10 and the Berlin Group11).
In January 2019, the EBA established a working group
on APIs under PSD2. The working group is tasked with
facilitating industry preparedness for the Regulatory
Standard on Strong Customer Authentication and Common and Secure Communication and to support the
development of high-performing and customer-focused
APIs under PSD2.

10 •


Europe´s GDPR12 marked a significant milestone in
data protection and had a global impact. GDPR is the primary law regulating how all companies protect the personal data of citizens of the European Union. It provides
several new rights relating to personal data for citizens of
the European Union, including a right to access, a right to
be forgotten, a right to restrict processing, a right to data
portability, and a right to revoke consent. GDPR requires
explicit consent and that customers are made fully aware
of how their personal data will be used and by whom.
Finally, GDPR also imposes legal duties on organizations
to protect customer data and to ensure its accuracy and
The European Data Protection Board is working on
guidelines on the relationship and compatibility between
relevant provisions of GDPR and PSD2. The first version
of this guidelines is expected for the first quarter of 2020.
In Japan, the Amendment to the Banking Act in 2017,13
which came into force in June 2018, introduced a registration system for TPPs and set the framework for collaboration between banks and TPPs, including both
payment-initiation and account-information service providers. The amendment encourages banks to open up
their APIs. Financial institutions have the discretion to opt
in to open banking but must comply with specific rules
if they do. Banks must endeavor to establish a system
for carrying out interconnection through APIs within two
years from the enforcement of the amended Banking Act.
In 2018, banks had already presented their plans to realize open APIs. The fact that TPPs need an authorization,
and especially that they are required to sign an individual
agreement with each of the banks to which they want to
connect, are making the process burdensome and adoption slow.
The Monetary Authority of Singapore (MAS) has been
very active promoting open banking with a comprehensive, nonmandatory regulation and governance framework. The MAS has led by example by opening its own
data for APIs and establishing scalable data practices
and a payments infrastructure that underpins innovation
in the area. Singapore has taken a collaborative stance
with the industry. In 2016, with the Association of Banks
in Singapore, it published an API playbook14 that encourages banks to participate in open banking. The playbook
presents a high-level guideline for API design aimed at
stakeholders intending to use APIs, including providers,
consumers, fintech companies, and the developer community. It includes a description of the full sequence of
steps toward a complete strategy to open banking: prioritize and select APIs, implantation guidelines, data standard, security standards, and governance mechanisms.
Four categories of APIs are included: product, servicing,
marketing, reporting and payments. Finally, the MAS has
also established an API register, to list open APIs available

in the Singaporean financial industry. In total, the playbook sets out a comprehensive framework, listing more
than 400 recommended APIs and over 5,600 processes
for their development.
At a regional level, the MAS, with the Association of
Southeast Asian Nations (ASEAN) Bankers Association
and the International Finance Corporation, has participated in the creation of ASEAN Financial Innovation
Network (AFIN), established in 2018 as a not-for-profit
market institution. AFIN´s objective is to create a scalable,
market-driven, open architecture platform that can help
expand access to responsible financial services innovation in the digital economy to smaller banks and markets
across Asia. AFIN operates the API Exchange (APIX)15
platform, the world’s first cross-border, open-architecture
API marketplace and sandbox platform for collaboration
between fintech companies and financial institutions.
The marketplace expedites discovery and collaborative
undertakings between fintech companies and financial
As a result, several banks have launched their own
initiatives and API platforms in Singapore (DBS, OCBC
Bank, Citi, and Standard Chartered, among others), making Singapore one of the most dynamic markets in the
development of an API ecosystem.
Australia has approached open banking from the wider
perspective of consumer data rights.
In 2017, the Treasury Department commissioned the
Review into Open Banking in Australia, chaired by Scott
Farrell,16 to recommend the most appropriate model for
open banking in Australia. Since then, the government
has decided to legislate a Consumer Data Right (CDR)17
to empower customers to choose to share their data with
trusted recipients only for the purposes that they have
authorized. The right will be implemented initially in the
banking (open banking), energy, and telecommunications sectors and then rolled out economy wide on a sector-by-sector basis.
On May 9, 2018, the Australian government agreed to
the recommendations of the review, both for the framework of the overarching CDR and for the application of
the right to open banking, with a phased implementation from July 2019. The government decided to phase in
open banking with all major banks making data available
on credit and debit cards and deposit and transaction
accounts by July 1, 2019, and mortgages by February 1,
2020. Data on all products recommended by the review
will be available by July 1, 2020. All remaining banks will
be required to implement open banking with a 12-month
delay on timelines compared to the major banks.
The Australian Competition and Consumer Commission has a supervisory role in the process and has been
empowered to adjust timeframes if necessary. In September 2019, the commission released draft guidelines on the

CDR accreditation process and supplementary guidelines
on the insurance and information-security requirements
of accreditation.
Also following a public consultation, the Hong Kong
Monetary Authority (HKMA) published its Open API
Framework for the Hong Kong Banking Sector18 in July
2018, laying out its approach to open banking. The formulation of the Open API Framework is one of the seven
initiatives announced by the HKMA in September 2017
to prepare Hong Kong to move into a new era of smart
The framework takes a risk-based principle and a
four-phase approach to implement various Open API
functions (product information, customer acquisition,
account information, and transactions) and recommends
prevailing international technical and security standards
to ensure fast and safe adoption. It also lays out detailed
expectations on how banks should onboard and maintain
relationship with TPPs in a manner that ensures consumer
Hong Kong has defined a collaborative approach where
the HKMA will monitor progress of Open API implementation and further consider the need for new regulatory
measures. However, it has permitted flexibility to banks
in implementing Open API as part of their strategies. It
has allowed the industry to set its own standards without making them mandatory. Having reviewed implementation challenges after a year, the HKMA signaled its
intent to play a more proactive role in the definition of
standards and security for the higher-risk phases 3 and 4
of API implementation for account information and debit
Concerning the US market, the regulator has taken a
hands-off approach, issuing nonbinding guidelines and
letting open-banking practices be industry driven. We can
find a general driver for open banking in Section 1033 of
the Dodd-Frank Act,19 which states that US citizens can
allow access to their financial data. Also, the Consumer
Financial Protection Bureau issued a document in 2017
containing consumer nonbinding principles for data-sharing protection20 that encourage the use of APIs for data
More recently, in July 2018, the US Treasury issued a
report21 containing general recommendations on the use
of consumer financial data and encouraging regulators to
take the necessary steps to avoid regulatory uncertainty
and create a context for secure and efficient access to
With a widely established practice of screen scraping,
the United States’ bank payments association, the National
Automated Clearing House Association, launched in 2017
a group to work on API standardization, mainly in three
areas: fraud and risk reduction, data sharing, and payment
access.22 Also, in late 2018 the Financial Data Exchange23


• 11

was launched with the goal of unifying the leading financial institutions in the United States, together with fintech
and others, around a common API standard and technical
framework for data sharing across the industry.
In New Zealand, the development of open-banking
standards is also being led by the payment association,
PaymentsNZ. It launched an API workstream as a central
part of its Payments Direction strategic initiative since
2017; the main driver for that initiative is encouraging innovation in the payment sector in the country. In March 2018,
the first pilot of APIs for payment initiation and account
information was launched. This pilot is now closed, and
the first versions of payment-initiation and account-information APIs are available in the newly created API Centre.
In June 2019, PaymentsNZ released a set of standards on
account information and payment initiation.24
India entered into open banking in the area of payments. The National Payments Corporation of India, an
umbrella organization for operating retail payments and
settlement systems in India, as an initiative of the Reserve
Bank of India (RBI) and Indian Banks’ Association under
the provisions of the Payment and Settlement Systems
Act, launched the Unified Payments Interface in 2016. The
interface facilitates interbank transactions through an API
framework together with a digital identity solution. It is
partly built within the unique identification platform in
India (Aadhaar).
The history of API infrastructure dates back to 2009,
when India launched the Unique Identification Authority
and created the Unique Identification Numbers (UIDs),
named as Aadhaar. The first API was launched in 2010,
and several APIs were progressively added within the platform India Stack: Payment Bridge and Aadhaar Enabled
Payment System, eKYC, eSign, and DigiLockers. In 2019,
India Stack has collected 1.06 billion Aadhaar numbers,
linked 339 million bank accounts, and done 150 million
electronic know-your-customer actions.25
The RBI has remained active, encouraging the adoption
of open banking. In 2017, the RBI published a report of
the Working Group on Fintech and Digital Banking,26 providing recommendations for an environment for developing fintech innovations and testing of APIs. Also, the RBI
established directions for a Non-Banking Financial Company-Account Aggregator,27 describing a framework for
the registration and operation of an account aggregator
in India.
More recently, Canada embarked on a journey toward
open banking with the announcement in the 2018 budget
of the government’s intent to undertake a review of the
merits of open banking.28 To guide the review, the minister of finance appointed an advisory committee on open
banking. The following three core financial-sector policy
objectives were clearly stated to be guiding the review:
efficiency, utility, and stability. The consultation sought

12 •


to understand how stakeholders perceived the potential
benefits of open banking and, also, how Canadians felt
that risks related to consumer protection, privacy, cybersecurity, and financial stability should be managed.
While the government completes the review, different
stakeholders are contributing to the debate. In June 2019,
the Standing Senate Committee on Banking Trade and
Commerce issued a report with recommendations on how
the deployment of open banking should take place in Canada.29 The recommendations include (i) the designation of
the Financial Consumer Agency of Canada as the interim
oversight body for screen scraping and open-banking
activities, with a mandate to conduct research and public education and to respond to complaints; (ii) the provision of immediate funding to consumer-protection
groups to help them conduct and publicize research on
the benefits and risks of screen scraping and open-banking activities; and (iii) to facilitate the development of a
principles-based, industry-led open-banking framework.
Over the longer term, it is also recommended modernizing the Personal Information Protection and Electronic
Documents Act, to align it with global privacy standards
and to designate the privacy commissioner of Canada
and the Canadian commissioner of competition as the
co-regulatory and enforcement authorities for open-data
In Mexico, the Fintech Law30 came into force in March
2018. This the first law in the world to regulate in a comprehensive manner all the aspects affecting digital innovation in the financial sector, new business models, and
new players, including the creation of a sandbox. The
main guiding principles of this regulation are financial
inclusion and innovation, which differ from the focus on
competition stated by some other regulations mentioned
in this section. Open banking is mandated in article 76,
describing the institutions that must publish their APIs
and the type of data to which they need to give access.
The details of these elements of the strategy, together
with the other dispositions of the Fintech Law, are being
developed by the Mexican authorities.
Finally, Brazil has also declared its intent to regulate
open banking. In a communiqué published in April 2019,31
the Central Bank of Brazil disclosed the fundamental
requirements for the implementation of open banking
in Brazil. Specifically, the communiqué provides for the
scope of the Brazilian open-banking model, the definition of the customer personal and transactional data
to be shared, and its phased implementation approach,
expected to be completed for the second half of 2020.
Self-regulation initiatives are expected, and the Central
Bank of Brazil may coordinate these initial self-regulatory
efforts. In December 2019, as a first step to start the regulatory process, the central bank submitted the drafts for
public consultation.

TABLE 2: Regulatory Approaches to Open Banking
Regulatory-Driven Model

Collaborative Model

Industry-Led Model

United Kingdom
European Union

Hong Kong

United States
New Zealand

Source: Author’s summary


• 13

6. Analysis of Selected Topics


• Customer-provided data: Information provided directly
by customers to their banks. Customer ownership is
most obvious in this type of data.

Data exchange between financial institutions and service
providers has become increasingly common, as it promises to facilitate industry-wide innovation and increased
business agility and competition while allowing consumers further choices. However, the types of data to be
exchanged, the mandatory versus voluntary nature of the
exchange, and the types of participants in the exchange
might vary from one context to another.

• Transactional data: Data generated as a result of a
direct interaction with the financial institutions. This
data is usually available in internet or mobile banking
statements. Products included can go from the most
basic current account to a wide range.

6.1.1 Types of Data
The scope of open banking varies with the kind of data
and functions made available via APIs. Some frameworks
apply only to specific types of data, such as payment processing data, and provide third parties with both “read”
and “write” access to data and payment initiation, while
other frameworks provide “read-only” rights for data
aggregation purposes. Concerning type of data shared,
the following five categories could be considered:
• Product and service data: Non-confidential data provided by financial institutions—for example, data about
their products or services offered or offices and ATM

14 •


• Customer insights: Data that results from an effort
made to gain insights about a customer. Credit scoring or know-your-customer data would be examples of
this type of data.
• Aggregate data sets: Non-individualized data that
results when the bank uses multiple customer´s data
to produce collective or average data across a group
or subset of customers.
6.1.2 Types of Participants

Participants in the open-banking ecosystem are both
banks and financial institutions, and third parties accessing the data. Among the latter, payment initiators and
account information aggregators have emerged as the
two main actors.

TABLE 3: Types of Data Exchanged in Selected Countries




Hong Kong


Current account


Credit scoring

about ATMS
and offices

New Zealand






Source: Author’s summary based on public information and interviews with authorities and market participants

Concerning the institutions that are subject to opening
their data, different approaches are observed, depending on how wide the definition of financial institutions
affected by open banking is.
Developing an API framework, the definition of processes, compliance requirements, and staff training or
hiring impose some initial costs that have been considered in some instances to include only players of a certain size. This is the case, for example, of Open Banking
in the United Kingdom, where initially opening mandated
largest banks to give access to current personal and business accounts customer´s data to authorized third parties
through APIs (the CMA9).
Brazil has announced a progressive approach, where, at
first, only the institutions that are part of prudential conglomerates will be obliged to participate. Subsequently,
this obligation may be extended to other institutions,
at the discretion of the Central Bank of Brazil. The final
scope of the model envisaged for Brazil should include
financial institutions, payment institutions, and other institutions licensed by the Central Bank of Brazil.
In most countries, banks are the addressee of regulations or guidelines about open banking. This is the case
in the European Union, Hong Kong, Japan, New Zealand,
Singapore, and the United States. In some of those cases,
such as in Hong Kong, New Zealand, or the United States,
only major banks are affected, at least at an initial stage.
Finally, in some instances, a broader set of institutions
are subject to the opening of their APIs.
In the case of India, the concept of financial information
provider includes the bank, banking company, non-banking financial company, asset-management company,
depository, depository participant, insurance company,
insurance repository, pension fund, and any other entity
that the RBI may identify.
In Mexico, the Fintech Law has included as obliged to
establish standardized APIs financial institutions, money

transmitters, credit information companies, clearinghouses, financial technology institutions, and companies
authorized to operate under new models.
In some cases, the opening of APIs for the financial
institutions described in the regulations is established as
mandatory, while in other cases, countries have drafted
the regulation more in the shape of nonbinding guidelines
or other prescriptions that make them voluntary.
Concerning the parties who can have access to the
data, ensuring that only entities that adhere to the appropriate security and privacy standards and have the customer´s authorization becomes key to guaranteeing a
secure open-banking framework. With that in mind, some
constituencies have established licensing or authorization
requirements for TPPs. That is the case of Australia, the
European Union, India, Japan, Mexico, New Zealand, and
the United Kingdom. In the case of Japan, regulation has
gone a step further, also requiring an individual bilateral
agreement between the TPP and the bank. Finally, Hong
Kong gives banks the freedom to choose which TPP to
collaborate with using bilateral agreements.
In the case of Europe, to increase transparency, the EBA
established a central register that contains information
about payment and electronic money institutions authorized or registered within the European Union.32 TPPs,
both account information service providers and payment
initiation service providers, are required to have an electronic ID to prove that they are a licensed player. This ID is
then read by the bank before granting their access.
In Singapore, the authorities have established a Financial Industry API Register, updated semiannually, which
tracks APIs by functional category as they are launched.
These open APIs provided by financial institutions have
been broadly classified as either transactional (that is,
containing sensitive client data, user/partner authentication required) or informational (that is, containing nonsensitive data, no/minimal authentication required).


• 15

TABLE 4: Types of Participants and Nature of the Framework

In the case of the United Kingdom, to
manage API standards in a way that enables
a transparent and open governance frameUK
work that supports accessibility, usability,
Mandatory for MA9
and innovation, an independent body was
created. Recognizing that the CMA could not
specify the technical standards in the primary
regulation, the design of open banking was
delegated to the “Trustee” who would head
Hong Kong
up a body, the OBIE, that would work with
Banks and other sectors
stakeholders across the industry to deliver
open banking. Funding for the OBIE comes
New Zealand
from the largest banks (the CMA9), while
Financial information provider
the CMA, the Financial Conduct Authority,
and Her Majesty´s Treasury provide goverBrazil
Financial institutions
nance oversight. The OBIE is the custodian
of the Open Banking Standards for APIs and
Financial institutions and others
owns and maintains the Directory of Open
Source: Author’s summary based on public information and interviews with authorities and
Banking Participants (also referred to as the
market participants
Open Banking Directory), which provides
a “whitelist” of participants able to operate in the open
Finally, one particular principle that the CDR has introbanking ecosystem. Once the implementation phase is
duced in Australia is reciprocity. All accredited recipients
completed, the role of the OBIE will transition into a mon(fintech companies and other) must transfer data at their
itoring role to ensure that service levels and obligations
customers’ request in a format equivalent to how they
are met.
received it.
Considering the API architecture and framework within
a bank or financial institution, there is the need on their
part to define an internal governance that includes the
following phases: ideation of APIs; prototyping and production; publishing; consumption (including partner
6.2.1 Governance
onboarding, security, and so on); and retirement (notifiOne important aspect around open banking is how to
cation of changes and migration). Singapore has been the
operationalize the open-banking framework, including
country that has issued the most detailed description of
the potential creation of governance entities, and their
guidelines about this API life-cycle governance. Also, in
roles, responsibilities, and activities. To ensure an adethe case of Singapore, recommendations around the API
quate governance of the open-banking framework, cerrisk governance have been detailed.
tain aspects need to be defined, such as the appropriate
In the case of Hong Kong, which leaves the strategy of
mechanisms to determine engagement of participants to
adoption of open API to banks, the HKMA mandates that
ensure that obligations are met, or how issues that matethose that chose to move forward should ensure that a
rialize between participants are resolved.
commensurate level of protections and suitable TPP govAuthorities involved in open banking can include the
ernance arrangements are in place with appropriate, clear
banking supervisor, an API or technical standards comcontracts to define responsibility, liability, control, and
petition authority, the consumer-protection authority, the
customer protections. A detailed description of the predata privacy authority, and an alternative dispute mechferred governance framework, based on bilateral arrangeanism.
ments with a common baseline, for the different phases
In some cases, such as in the European Union, Hong
of API adoption is described by the HKMA in their Open
Kong, India, and Singapore, the bank supervisor is the
API framework.33 Processes range from simple TPP regisone in charge of overseeing the open-banking frametration process with basic consumer-protection measures
work. In other cases, such as Australia, it is the competito onboarding checks, ongoing monitoring, and bilateral
tion authority that is responsible for the implementation
contractual relationships.
of the open-banking framework to increase competition
Also, once open APIs have been implemented by
in the banking sector and to foster innovation.
banks, the HKMA contemplates the creation of a body
to review the relevance of the architecture, security, and
in Selected Countries

16 •


data standards on an ongoing basis. The body may also
take on other industry-wide tasks, such as coordination
and consumer education, where needed. In the longer
term, if harmonization of open API functions is desired by
the industry, the body can also take on this task to work
with the industry to achieve interoperability.
In the case of Australia, to govern the data standards,
the Australian Competition and Consumer Commission
has established the creation of a data standards chair and
an advisory committee.
There are instances where industry-led workstreams
are defining the governance of APIs. This is the case of
payment associations in the United States (National Automated Clearing House Association) and New Zealand
Concerning liability frameworks, many countries have
existing or planned laws for regulations addressing customer liability with respect to data access by third parties. For example, PSD2 requires authorized third parties
to have professional indemnity insurance, or a comparable guarantee, against specified liabilities, such as unauthorized transactions or non-execution and defective or
late execution of payment transactions. In other cases,
customer liability may be addressed by national personal
data-protection laws, general banking laws covering customer protection against fraudulent transactions, consumer-protection laws, and civil, commercial, and criminal
codes. In some countries, customer liability is included in
the bilateral contracts or agreements between the bank
and TPP.
Finally, several countries have existing or planned complaint-handling or alternative dispute-resolution mechanisms that cover open-banking issues.
Among jurisdictions with existing or planned complaint-handling or alternative dispute-resolution mechanisms, in the European Union, PSD2 requires payment
service providers, including authorized third parties, to
put in place adequate and effective complaint-resolution
procedures. In Hong Kong, terms addressing the complaint-handling mechanisms are expected to be included
in contracts with third parties, as customers should not be
responsible for any direct loss suffered as a result of unauthorized transactions conducted unless the customer acts

fraudulently or with gross negligence. In Japan, the Association for Electronic Payment Services, a private body, is
responsible for handling customer complaints related to
open banking. In Singapore, the Personal Data Protection
Commission facilitates the complaint between the customer and the provider. India has an ombudsman scheme
for digital transactions.
For jurisdictions that do not have regulatory guidance
requiring complaint- or dispute-handling mechanisms,
customers often initially take their complaints and disputes to their bank.

6.2.2 Technical Requirements
While regulation in some countries has defined standardized technical standards, in other cases, a flexible
approach has been adopted. In some instances, the industry has been the one establishing nonbinding standards.
In the case of Australia, Mexico, and the United Kingdom,34 the standards have been mandated by regulation.
Both Australia and the United Kingdom have introduced
guidelines on standards even in customer experience.
Hong Kong, based on international practice and the feedback during the consultation exercise, recommended
internationally accepted architecture and security standards. In Singapore, a joint effort between the MAS and
the Association of Banks resulted in the publication of an
API playbook containing detailed recommended standards for APIs. In New Zealand and the United States, it
has been the industry that has led the publication of nonbinding standards. In India, the RBI envisages developing
API standards with the technical support of the Reserve
Information Technology.
Concerning Europe, while PSD2 has not defined prescriptions on technical standards, some market initiatives
have emerged (such as the German Group, STET, and the
Polish API). Secondary regulation in the European Union
has defined regulatory technical standards for SCA and
common and secure open standards of communication
In Brazil, the expectation is that the participating
industries will agree themselves on technology standards,
operational procedures, safety standards and certificates,
and the implementation of interfaces. However, to ensure

TABLE 5: Technical Standardization in Selected Countries







Hong Kong



No standards, partial
industry adoption

Collaboration MAS/
Banking association

No standards



New Zealand








Expectation of industry


Source: Author’s summary based on public information and interviews with authorities and market participants


• 17

compliance with the regulation, as well as the achievement of the proposed objectives for the model, the
Central Bank of Brazil may coordinate the initial self-regulatory efforts, approve decisions and revisions, and exercise the veto power, imposing restrictions or regulating
nonagreed aspects.
In Mexico, the Fintech Law dictates that the Supervisory Commission and the central bank could determine
the technical standards for the interoperability of APIs,
their governance, security, and consent mechanisms.

6.2.3 Security Measures
Different potential operational and cybersecurity issues
have been identified related to the use of APIs, including data breaches, misuse, falsification, denial-of-service
attacks, and un-encrypted login. Mechanisms used by
some banks to mitigate these risks include stricter access
privileges, authorized end-to-end encryption, authentication mechanisms, and vulnerability testing, among others.
Robust security foundations are crucial to realizing
the benefits of data transfer that open banking promises
without compromising the soundness of the system. A
right balance needs to be struck to ensure that security
standards do not act as a barrier to entry for new players.
This general principle has resulted in different degrees of
regulation, from mandatory standards to recommended
guidelines on security measures.
In the United Kingdom, the OBIE has released highly
detailed and prescriptive technical security standards36 in
the areas of customer authentication, API specification,
encryption, management of data, and controls.
The European Union has also mandated specific requirements in PSD2 with regards to payments in aspects such
as managing operational risks, including system performance monitoring, contingency measures for unplanned
unavailability or a system breakdown, incident management, and reporting. The European Regulation 2018/389
develops the requirements to be complied with by payment providers to apply the procedure of SCA, protect the
confidentiality and the integrity of the payments service
user´s personalized security credentials, and establish
common and secure open standards for communication
between the different parties involved in open banking.
In Singapore, the API playbook contains detailed guidelines on information security standards in domains such as
authentication, encryption, authorization, hosting security, secure coding, vulnerability assessment, and robust
fail-over mechanisms. MAS recommendations clarify that
the level of security standards for each API depends on
the business criticality of the data being exchanged, permissible access levels, including role-based access, and
availability requirements across the identified information
security domains.

18 •


Banks in Australia are also subject to prudential standards and guidance on data security issued by the Australian Prudential Regulation Authority37 and to the Privacy
Act’s requirement to secure personal information. Those
standards set out the authority’s expectations for regulated financial institutions to consider and address risks
such as fraud due to theft of data, business disruption due
to data corruption or unavailability, delivery failure due to
inaccurate data, breach of regulatory obligations resulting from unauthorized disclosure, and controls to ensure
adequate data quality and data security, particularly in
arrangements involving third parties.
In India, the main characteristics, and the definition,
of security elements of APIs will be defined in guidelines
that are being drafted. The main features are likely to be
technology agnostic, reliable, scalable, simple, minimalist and evolutionary in nature, customer-centric, driven
by consent, and asynchronous by design. The specifications would promote interoperability and layered innovation and transparency and accountability through
data, including data privacy and security concerns. The
account aggregator will be data blind, and the data will
move in encrypted form, so that account aggregators
cannot store data on their servers.
Finally, in Hong Kong, the Open API Framework recommends the architecture and security standards. The
HKMA will also define a more detailed set of standards
in 2020 for Phase III and IV open APIs to facilitate secure
and efficient implementation across the industry. While
certain technical standards have been prescribed, they
cannot be considered as the only standards that cover all
security requirements. Banks should always refer to sound
industry practices and relevant regulatory and internal
requirements and apply holistic controls on information
and cybersecurity based on a risk- and principle-based
approach to protect banks’ systems as well as bank and
consumer data.

6.2.4 A
 PIs Developed In-House by Banks or
Outsourced APIs Providers
On a practical matter, banks have followed different
approaches to open banking, resulting in different levels
of openness for their APIs. Depending on their API strategy and internal capacities, banks either have decided to
develop and publish their own APIs or have connected to
external platforms.
While each model has its merits and challenges, standardized APIs (either regulatory or industry driven) tend
to create a more balanced competitive context than
closed APIs, which give a higher level of power and control to large banks and fewer opportunities to compete to
smaller banks. And they also impose more costs on fintech companies wanting to partner with several financial

We can find examples of banks having launched their
open APIs framework in different countries. Some of the
banks leading globally the development and publishing
of their APIs are DBS in Singapore—with the largest API
developer portal, with more than 155 APIs available—
OCBC, Unionbank in Philippines, Citi, and BBVA. The two
main origins of front-runner banks are either advanced
Asian countries—namely, Singapore—or banks in the
European Union adhering to PSD2. (More than 250 banks
operating in the European Union have launched developer portals and APIs.) According to market analysis, 65
percent of banks’ implementation in Europe adheres to
the Berlin Group standards.
On the other hand, a large number of banks deploy
their offering through so-called API hubs, which provide
a single interface to access all banks using their solution.
The following two models of API hubs are in the market:
1. Compliance model: This model incorporates a layer to
bank APIs that guarantees compliance with the regulation, hence mitigating compliance risk. They have been
developed specially in Europe to ensure compliance
with PSD2. Examples are Redsys (Spain), CBI (Italy),
Stet (France), and Nets (Nordic countries).
2. Technical TPPs or aggregators: They develop their own
APIs, which enable interconnection between banks and
fintech companies. Examples are BEC, Luxhub, SIBS,
Eurobits, and Figo (Europe); Plaid and Yodlee (United
States); or Saltedge (Europe and United States).
Some of these platforms work as marketplaces, allowing
the connection between banks and fintech companies
through APIs, and have appeared on the market with
a regional approach and, in some cases, with public or
multilateral support. The AFIN APIX platform,38 working
in the countries of the Association of Southeast Asian
Nations and with some partnerships outside the region,
such as Abu Dhabi Global Markets, is one example of a
multicountry marketplace platform. Another example is
Finconecta,39 operating with the platform 4wrd, which
provides an API framework for connecting banks with
fintech companies in some African countries, the Middle
East, Europe, and Latin America, in partnership with the
Inter-American Development Bank in that region.
Several banks, especially in the European Union, have
also started to act themselves as third parties; many
large banks now offer account-aggregation services (for
instance, Railsbank, Solaris, and BBVA). This trend is likely
to consolidate in other markets introducing open-banking
Concerning the business models around APIs and the
possibility of charging third parties for the use of APIs,
jurisdictions that regulate the obligation of APIs to be

published generally do not allow banks to charge for them.
For those APIs that are not mandatory, the so-called premium APIs, regulations generally leave freedom for banks
to decide on a business model for charging. So far, there
are not many instances where banks are charging for APIs.

6.2.5 Interoperability
Interoperability could be defined as the ability of a system or a product to work with other systems or products
without increased cost or effort. In the context of open
banking, interoperability entails that legal and operational terms facilitate switching between banks. Regarding fintech companies and third parties, interoperability
provides banks with the reciprocal stability of being able
to change providers or work with several of them without increasing fixed costs. When standardization has not
been imposed or has not yet been completely implemented, interoperability becomes a key driver for ecosystem development, and especially for customer adoption.
It is also key for enabling a competitive environment that
encourages small and medium players to develop their
APIs on a level playing field with large banks.
Indeed, one of the recommendations of the Fintech
Bali Agenda40 is to reinforce competition and a commitment to open, free, and contestable markets to ensure a
level playing field and to promote innovation, consumer
choice, and access to high-quality financial services. The
successful and large-scale adoption of technology would
be facilitated by an enabling policy framework regardless of the market participant, underlying technology, or
method by which the service is provided. It encourages
policy makers to address the risks of market concentration and to foster standardization, interoperability, and
fair and transparent access to key infrastructures.
Also, different reviews of digital competition across
Europe, such as the Furman Review41 and the European
Commission’s digital competition report,42 concluded that
data and protocol interoperability could drive increased
competition in digital markets.
Hence, interoperability has been broadly incorporated
as an objective for countries to achieve while promoting
and encouraging the adoption of API standards. Industry
practice also becomes key to achieving interoperability.
In the case of the United Kingdom, interoperability
has been forced by regulation but also pushed by banks,
especially large ones. Authorities estimate that 80–90
percent of account providers currently operate under the
open-banking standards.
Hong Kong is also moving toward interoperability.
Since the launch of the first phase of open banking in
January 2019, the APIs launched by banks have largely
followed the recommended technical standards in the
Open-API Framework.


• 19

India has interoperability as a clear aim as it moves in
advance of its draft API standards.
In Europe, the EBA has determined in the RTS that, to
ensure the interoperability of different technological communication solutions, the interface should use standards
of communication that are developed by international or
European standardization organizations. Thus, without
defining a concrete standard, it calls for the interoperability of the system.
In Singapore, collaboration with the banking association in the development of the API handbook has been
instrumental to promote the interoperability of the API
In some cases, such as in the United States and New
Zealand, efforts toward interoperability have been led by
industry associations.
Finally, Australia has understood interoperability in a
wider way, in the sense that what has been designed for
the banking sector will also be able to work in other sectors of the economy (for instance, in energy and telecommunications).

6.2.6 Access to Third Parties
Access by third parties to customer data has occurred
in the absence of APIs with the use of the widespread
practices of screen scrapping or reverse engineering, still
prevalent in several markets.
In screen scraping, the customer provides a third party
with his or her log-in credentials (for example, a username
and password) for the online banking platform. This third
party then uses the details to log in to the website of the
customer’s bank and extract data on behalf of the customer.
The practice of reverse engineering decompiles the
code of the mobile banking applications to figure out
which information is exchanged between the application and a bank’s servers (through the nonpublic API)
and subsequently build a “reverse-engineered” version of
the mobile application that is capable of directly exploiting the communication from and to the bank’s servers.
It requires a second enrollment of a mobile application
upon receipt of the customer’s authentication credentials
and the subsequent use of these credentials, or even the
creation of a proprietary set of authentication credentials (to the third party). This technique is often favored
by data aggregators over screen scraping because it is
much more scalable and robust, as its performance is not
influenced by changes that banks make to their customer
Interestingly, one of the latest countries to launch a
consultation process, Canada, is paying a lot of attention
to the analysis of the advantages and disadvantages of
open banking versus screen scraping, as part of their con-

20 •


sultation and the reaction to it on the part of the Standing
Senate Committee on Banking, Trade and Commerce.43
Some of the concerns associated with screen scraping
and reverse engineering have to do with security and customer protection, stability, and the lack of revoking rights
on the part of the customer. Hence, screen scraping and
reverse engineering are perceived as slower, less stable,
and less secure processes. Also, they allow less control
on the part of the bank over who accesses customer data
and which data are retrieved. Generally, banks prefer a
system of APIs where they are in full control of the data
accessed by TPPs. However, the cost and time needed
to build and maintain public APIs could represent a challenge, particularly for smaller banks.
On the other hand, while fintech companies are aware
of some of the drawbacks entailed with accessing data
through screen scraping and reverse engineering, they
generally also have concerns about limitations on access
only through APIs, which give permission only to certain
data, with more limited flexibility on the type and number of queries and, in some cases, with some lags on the
update to the latest information.
In some areas, these different approaches have led to
tension about whether the regulator should choose to
prohibit screen scraping once APIs are mandatory. Most
jurisdictions do not prohibit the practices of screen scraping and reverse engineering.
The case of the European Union is particularly illustrative of this heated debate. The RTS introduced the
concept of a “dedicated interface” (API). This enabled
account servicing payment service providers, those who
provide and maintain a payment account for a payer, to
develop their own APIs and impose them on TPPs.
Indeed, the latest version of the RTS saw a last-minute
change in December 2018 incorporating a contingency
mechanism to use screen scraping (also known as the
“fall-back mechanism”) in case the dedicated API interface is unavailable or not working properly. In that vein,
the EBA Guidelines from the Contingency Mechanism
under Article 33(6) of the RTS44 establish that, if the interface does not respond to five requests within 30 seconds,
it is considered unavailable, mandating banks to publish
metrics on their service levels.
Banks can benefit from an exemption if their dedicated
interface fulfills a number of conditions centered around
how robust, available, and well supported the solution is.
To gain the exemption, the dedicated interface also has
to meet certain design and testing standards and has to
have been widely used for at least three months. There
are a number of challenges with the exemption process,
especially given that these assessments include fairly
technical analysis of each interface. Several regulators
in the European Union are open about the fact that they

do not have the technical expertise required to perform
these assessments, so they are encouraging banks to use
standardized conformance tools available in the industry.
Many have also mandated self-assessments and audit
steps as part of the exemption process.
TPPs make several claims about the system established in Europe. They allege that it creates an imbalance.
Each account servicing payment service provider has, at
most, one API to implement—namely, its own. Whereas
TPPs must implement a large number of APIs, depending
on their current service and market coverage. Also, they
underline the challenge that TPPs have in testing these
APIs for bugs and other problems without compensation.
Finally, the APIs were opened up for testing on March 14,
2019. Initial evaluations from some of the largest TPPs
in Europe found that testing environments (sandboxes)
were available for only about half the account servicing
payment service providers.

Data openness is an essential element of open-banking
regimes. One key aspect to deal with is the protection
of customer rights. This has resulted in the need for an
explicit consent on the part of customer, which in some
cases is contained in other regulatory pieces that deal
horizontally with customer data rights that could introduce more strict measures to the open-banking framework.
In Europe, in accordance with data-protection rules
under both PSD2 and GDPR, account holders can exercise control over the transmission of their personal data.
Hence, no data processing can take place without the
explicit informed consent of the consumer.
Under PSD2, providers (that is, banks, account information service providers, payment initiation service providers,
and so on) can access and process only the data needed
for the provision of the services subscribed to or requested
by the consumer. PSD2 regulates the provision of new
payment services that require access to the payment service user´s data. For instance, this could mean initiating a
payment from the customer’s account or aggregating the
information about one or multiple payment accounts held
with one or more payment service providers for personal
finance management. When a consumer seeks to benefit
from these new payment services, she or he will have to
request such services from the relevant provider explicitly.
Payment service providers must inform their customers
about how their data will be processed.
Payment service providers will also have to comply
with other customers’ rights recognized in GPDR, such as

the right of access, the revocation of consent, or the right
to be forgotten. All payment service providers (banks,
payment institutions, or new providers) must comply with
the data-protection rules when they process personal
data for payment services.
Australia, under the principle of giving customers control of their data, has determined that customers should
be able to give specific instructions on what data is shared,
with whom that data is shared, and for what purpose it is
shared, as well as the duration the sharing arrangement.
The CDR requires banks to implement effective and efficient consent-management policies and processes and
establish dashboards. Banks must demonstrate clear governance around collecting and managing customer consent and authorizations before data is shared. Also, the
CDR contemplates that a consumer who has given consent to use particular CDR data may withdraw the consent at any time by communicating the withdrawal to the
accredited person in writing
In Singapore, open-banking practices also need to be
fully compliant with the regulation that protects the use
of individual personal data, the Personal Data Protection Act,45 where it is mandated that organizations must
obtain previous consent to collect, use, or disclose personal data, and where an individual has the right to withdraw this consent at any time.
The Open API Framework in Hong Kong expects banks
and TPPs to implement appropriate measures for addressing requirements related to customer data protection and
the protection of personal data, including applicable laws
and guidance on the protection of personal data. These
include the Personal Data (Privacy) Ordinance in Hong
Kong,46 as well as the regulations and codes promulgated
by the Privacy Commissioner for Personal Data under
the said ordinance. Specifically, this regulation requires
consent from the data subject and mandates that data
subjects must be informed whether supplying data is
obligatory or voluntary, the purpose of using their data,
and the classes of person to whom their data may be
transferred. A data subject can withdraw his/her consent
previously given.
In India, the consent architecture established in the RBI
Master Directions47 determines that no financial information of the customer shall be retrieved, shared, or transferred by the account aggregator without the explicit
consent of the customer. The consent of the customer
should be obtained in a standardized way and contain,
among other details, the identity of the customer and
optional contact information, the purpose of collecting such information, and the consent expiration date.
Account aggregators should also provide their customers
with a functionality to revoke consent.


• 21

Brazil has also declared that the sharing of a customer’s
personal and transactional data, as well as the execution
of payment services, should be subject to the customer’s
prior consent. Procedures to obtain such consent should
aim to promote a simple, efficient, and safe customer
Finally, Mexico requires in the Fintech Law that personal transactional data could be shared only with prior
explicit consent from the customer. Only data that has
been authorized may be used, and the owner of the data
(the customer) has the right to revoke consent.

The transmission of data, and especially remote electronic
payment transactions, are subject to a high risk of fraud.
Hence, some constituencies have deemed the introduction of additional requirements for SCA to be necessary.
Also, fraud methods are constantly changing; thus, the
requirements of SCA should allow for the innovation of
technical solutions addressing the emergence of new
threats to security.
In this vein, PSD2 introduces in Europe strict security
requirements for the initiation and processing of electronic payments. PSD2 and the development regulation
(the RTS) oblige payment service providers to apply SCA
when payment service users
• Access their payment accounts online, whether directly
or through an account information service provider;
• Initiate an electronic payment transaction, or
• Carry out any action through a remote channel that
may imply a risk of payment fraud or other abuses.
SCA is an authentication process that validates the identity of the user of a payment service or of the payment
transaction. More specifically, SCA indicates whether the
use of a payment instrument is authorized.
It requires payment service providers to provide two of
the following three items to verify identity:
• Something you know (a password, response to a security question, or PIN)
• Something you have (two-factor authentication via
mobile phone, hardware token, or smart card)
• Something you are (a fingerprint scan or facial recognition)
SCA isn’t applied to some transactions that are considered low risk, including balance checks, low-value transactions (less than €30 for a single transaction), and the
number or amount of transactions relative to the last time

22 •


SCA was performed. Also, for remote transaction between
€30 and €500, it is accepted not to use SCA if the levels
of fraud are proved to be under certain thresholds.
The requirements of SCA across the European Union
are aimed at reducing the risk of fraud for online payments and online banking and protect the confidentiality
of the user’s financial data, including personal data. However, given the complexity of adoption, the EBA has given
flexibility to national authorities to postpone the adoption
of RTS for non-present card transaction up to 15 months
from September 2019.
SCA in Europe could result in different user experience
levels depending on how the authentication flow is implemented by banks. TPPs are required to have an electronic
ID, which serves to certify that it is a licensed player. The
bank must not create obstacles to the process, but, in
the absence of a contract, once the bank has read the
electronic ID, it has the option to require the SCA to take
place on its website and then send the customer back to
the TPP.
Other countries, such as Hong Kong, have so far opted
to introduce only recommendation in their Open API
Framework about security-protection requirements and
technologies related to the authentication of customers.
It is expected that in 2020, the HKMA will also define a
more detailed set of standards, which may include more
security elements, including more sophisticated technology and authentication infrastructure.
In the case of Singapore, their API playbook has defined
the recommended authentication standards through
tokenized protocols (OAuth 2.0 and Open ID Connect).
In other cases, such as Australia, different authentication
methods are being tested as part of the implementation
of the regime.
Broadly speaking, there are two options for enabling
customer authentication: bank-specific (models such as
the one described above, where banks need to comply
with certain rules) or market-specific schemes (such as
eID solutions). We can find examples of eID solution in
some Nordic countries, in India (UID), and in New Zealand
(Digital Identy NZ).
In the case of India, Aadhaar Auth API allows banks
and other financial institutions to verify the identity of the
customer instantly, as required by RBI regulations.

Although regulators and market participants recognize
the importance of the financial industry taking a leading role in the adoption of open banking, countries are
adopting particular measures to kick-start the adoption
of a framework.

First, most regulations have taken place after a prior
open consultation process and intense dialogue with the
Second, in some cases, standards have been defined
in a collaborative manner with the banking industry. One
of the clearest examples of such a practice has been the
joint publication of API standards by the MAS and the
banking association in Singapore.
Having a single point of reference (known as a repository or dashboard) of all open APIs offered by banks is
also a measure that some countries, such as Hong Kong,
have taken to facilitate ease of access by TPPs. During
discussions, some banks suggested that it would be desirable for the Data Studio of the Hong Kong Science and
Technology Parks to take up this dashboard role. Hence,
the HKMA recommended that all open APIs should be
listed under the Data Studio. The listing of open APIs
under the Data Studio will not preclude banks from using

other repositories. The industry or individual banks are
free to list their open APIs in multiple repositories.
Additionally, other practices—such as partnering with
interested parties on the promotion of open banking,
organizing educational events and competitions on the
use of open APIs among the industry, or hosting seminars
and workshops for banks and technology companies to
share use-case ideas or experience gained elsewhere—are
ideas mentioned by different regulators as potential formulas to encourage the adoption of open banking.
An enabling environment in which regulators set standards of a technical or legal nature can provide a baseline
that reduces risks for banks and other users, encouraging
the use of APIs.
Finally, some market drivers—such as new business
models in e-commerce or other areas of digital business
that require real-time intercompany processes or realtime payments—are incentivizing the use of APIs.


• 23

7. C
 onclusions and Future Agenda of
Open Banking

As described in this document, open banking is to great
extent about ecosystem creation and the smart use of
data to deliver new products to customers and to encourage competition. There is no single model or solution to
achieve these objectives. The models analyzed in this note
differ in their approach and scope, in the strictness of the
standards or principles defined, and in the definition of
the responsible governing bodies, among other things.
Most regulations analyzed under this note came into
effect in 2018, so it might be too early to draw substantial
lessons, but the following trends are observed:

• TPPs claim that the APIs published by banks do not
have the quality they require and are not being used,
and de facto screen scraping is still prevalent. TPPs
claim that there is no real incentive for banks to publish
good, free, open APIs.

• In Europe, more TPPs than payment initiators have
been authorized as aggregators, signalling higher challenges in the business model and accessing process in
the case of the latter.

Early regulatory efforts have been concentrated on
defining standardized API frameworks, creating governance bodies and rules, enhancing security, developing infrastructure, and establishing authentication
methods. Among the next items on regulators’ agenda
in the area of open banking are issues such as the future
scope of open banking, competition with other industries, especially with big tech players, and international

• Some concrete technical definitions on PSD2 are acting as a bottleneck for the development of TPPs. For
instance, requiring the customer to provide consent
every 90 days results in a very high rate of dropoff.
Also, the fact that PSD2 does not accept variable recurrent payments impedes the inclusion of a wide assortment of use cases. Finally, PSD2 is not contemplating
the possibility of a refund on direct payments, giving
much less flexibility than traditional payment schemes.

24 •


• As a corollary to the former, some market players
argue that it would have been desirable to regulate
based more in principles and less in details that in the
end require interpretation, and hence are subject to

In that respect, market participants and regulators are
starting to talk about the evolution of the scope of open
banking toward open finance and smart data. Open
finance refers to the capacity of consumers to access their

data via a suite of finance products, including mortgages,
savings, insurance, pensions, and so on. On the other hand,
smart data suggests the idea of customers accessing their
data in nonfinancial services sectors, such as energy, water,
mobile, and data from bigtechs. Although the only country
to regulate the extension of open banking to other sectors
so far is Australia, discussions around it are taking place at
different levels in other areas. The idea of reciprocity when
giving access to data is a principle that banks are starting
to claim as a necessary step toward a level playing field.
The Smart Data Review in the United Kingdom and the
report of the Canadian Senate Committee on Open Banking also go in the direction of extending access to data to
other sectors beyond banking.
Concerning bigtechs, their increasing interest and positioning as financial service providers, especially through
banking-as-a-service models, has raised questions about

the impact of their access to data from financial institutions. Some banks are starting to claim the idea of reciprocity in the access to customer data to guarantee a level
playing field. On the other hand, regulatory authorities are
analyzing the implications for financial stability and consumer protection, and also the division of responsibilities
between bigtechs and their partnering banks.
Finally, one last element on the agenda of open banking that could contribute to the development of global
markets is international interoperability, still at very early
stages of discussion. The fact that there is no globally
adopted API standard, and that TPPs may need to use
different API standards to communicate with banks in
different jurisdictions, could lead to potential challenges,
such as inefficiencies for third parties or fragmentation of
the digital financial ecosystem.


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