How much should we let a financial institution know about us and who has the right to decide what they can see? This is the question that sits at the heart of open finance. As financial products and services spread out from the banking world and into insurance, investments, mortgages and wealth management, so the sharing of data will become more and more necessary to create a seamless customer journey. But this broader sharing of data also brings increased levels of responsibility banks and other providers have to make sure their customers know, trust and retain control over their financial data.
Consent-Based Data Sharing vs. Open-Ended Access
For years, financial data access often followed an ‘accept all’ approach. After customers consented, the institution and third-party providers could also hold their data widely and outside of the original aim. This open access opens up the possibility of blanket permissions, background scraping and scope creep. And it means that enterprises have a hard time proving that all the data requests were justified.
Consent-based data sharing enables boundaries. Access can be given for a particular purpose, for an agreed limited time period with the explicit agreement of the customer. By limiting the data shared, the application of data minimization, limiting permissions to particular services and allowing users to revoke access removes unnecessary exposure.
These varieties of access also have implications for compliance. Open-ended access raises concern about accountability, privacy and misuse of information. Consent models give a more straightforward audit trail for banks, which can identify who accessed the data, what they accessed and under what scope. Deutsche Bank makes use of OAuth2 scopes and API key management to offer a granular level of control, sharing current account balances and modest history, but not necessarily the ability to set up wire transfer payments.
The Evolution from Open Banking to Open Finance
Open banking transformed the flow of data between the customer and their financial provider. Although open banking provided a way to access customer’s current account and simplify day-to-day banking, for example on payments, account aggregation and cash flow management, customers aren’t only defined by the here and now. Their financial circumstances are affected by their long-term savings, mortgages, pensions, insurance and other liabilities.
Open finance extends data sharing across this wider portfolio. With customer approval, financial providers can pool together information from different companies into a complete picture of a customer’s financial situation to help them understand them, provide intelligent financial advice and enable tailored services and automated wealth management. For example, an advisory platform can review how much savings and investments a customer has built up and the debts they owe.
But creating that ecosystem is a technical challenge. Financial providers typically integrate with APIs in a way that can be slow and hard to scale. Ninth Wave tackled the challenge using Compass, an onboarding assistant that analyses and maps APIs using AI. The company claims that the tool can cut down the time it takes to automate these processes by 95%. That could help enterprises connect financial data sources at scale and deliver open finance products without human intervention.
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Transforming Customer Experiences Through Trusted Data
No one likes to have to enter their financial information repeatedly. However, too often customers are asked to upload documents again, undergo further identity verifications or pass through lengthy and duplicated approval processes at the outset of each financial interaction. Using open finance, providers could plug into other providers with the customer’s permission to gain access to checked information to speed up the process.
The bigger potential is around personalization. As firms get a more holistic view of a customer’s financial status, they can be more confident in their decision-making. A lender, for instance, could look at a customer’s income, their current debt and repayment history to come up with more appropriate credit conditions. A wealth platform could factor in investment and savings data to offer a more forward-looking piece of budgeting advice, and insurers could create more tailored protection solutions.
But access alone does not establish trust. Customers require a view of which organizations can access their information, what they can use it for and when their permissions expire. Transparent permission dashboards deliver this transparency and a simple method for customers to revoke access. Gradually, this transparency will build customer confidence.
Bank of New York Mellon demonstrated a 20% faster AI-assisted onboarding on its governed AI platform. This metric didn’t directly measure open finance adoption, but it is a good example of how governed technology can help streamline financial services workflows. With transparency into their data, businesses can use customer experience as a real differentiator.
Navigating the 2026 Regulatory Landscape
Open finance regulation is developing in all the key markets, but in unison. Financial data sharing has to be further opened up to be more safe, accountable, and open. For businesses, it’s a matter of not just keeping up with the regulations already in place, but also those still yet to come.
In the European Union, the PSD3 and the Payment Services Regulation proposals are intended to facilitate the uptake of new payment services and improve consumer protections. Meanwhile, the separate Financial Data Access framework focuses on extending secure data sharing beyond payment accounts. These developments should not be confused with a blanket elimination of screen scraping. In the UK, the Data (Use and Access) Act 2025 gives the government powers to establish smart data schemes, while its Smart Data 2035 strategy sets out a wider roadmap for trusted data sharing across sectors.
The US presents a more unsettled picture. The CFPB’s Section 1033 personal financial data rights rule remains subject to legal and regulatory uncertainty. A court stayed the rule’s compliance date in October 2025, and the CFPB opened the rule for reconsideration. At the state level, the New York legislature introduced the proposed Financial Data Rights Act, Assembly Bill A10640A, which has explicit consent, revocation rights and civil penalties of up to $10,000 per violation. The bill remains in committee.
That’s the message to be sent to business. No matter if in the guise of legislation or standards, compliance can’t be achieved through legislation alone. The requirements are much broader and more granular than that.
Architecting for Trust Through Enterprise Best Practices
Core with consent in open finance architecture to build a trusted open finance environment, CTOs and product owners need to ensure consent is a building block in your architecture. Starting off open, mature APIs like FDX or similar regional specifications will support integrations to safely share financial data via open finance.
Second, tightly limit the access lifetime. Any time-limited access token should be revoked when customer permission ends. Consent screens should be clear and simple and explicitly list what data will be shared, rather than checkboxes. Customers should also be able to easily revoke permissions.
Protection must persist when data flows into your enterprise systems to handle large amounts of financial data flowing into your enterprise systems, AWS describes an 11-step data protection deployment for enterprise financial data that covers sensitive-data detection and redaction, dynamic masking, data encryption, access management and retention controls. Another option is federated connectors that enable applications to access live financial data without copying or moving the data. Existing permissions, licensing restrictions and governance controls can be preserved.
Collectively, that together can allow companies to limit data overexposure and can begin to construct an architecture ready to scale alongside open finance.
Conclusion
Customer data is a borrowed power in an open finance environment. Organizations that leverage consent as a catalyst for growth will be able to cultivate deeper customer relationships, provide better targeted financial products and gain unshakeable trust. And that trust rests on what goes on beneath the surface. Permissions, repositories and data processes should be transparent, controlled and responsible at each transaction. Start by auditing your current data access infrastructure, then look for permissions that go beyond their intended scope and close the holes before regulators or customers do.