EBF CONSULTATION RESPONSE
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EBF Response to the European Commission’s call for evidence on Open Finance

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BRUSSELS, 2^nd August 2022  – The European Banking Federation (EBF) has responded to the European Commission’s Call for Evidence on an “Open Finance Framework – enabling data sharing and third party access in the financial sector.” Key points that the EBF highlights include:

• Open Finance must be considered as part of the data economy as a whole and there must be a careful reflection of what policy option to pursue which, on the one hand, empowers and delivers new opportunities for customers and, on the other, stimulates innovation in the financial sector and data economy as whole.
• The approach to Open Finance should set out a framework or a scheme with provisions on how data could be share (including consumer protection, liability, compensation, technical obstacles) to facilitate voluntary data sharing, based on market needs. This would help to see for which use cases there is customer demand – for which there is the most added value – while supporting innovation in the market.
• Trust must be the foundation of any data sharing framework as the customer is at the centre. Consent management tools can play a role and can be provided by any party (data holder, third party or intermediary).
• Technical obstacles such as common secure access and transfer mechanisms and standards must be addressed. Efforts should be market driven and build on existing developments. Any Framework should remain technology neutral to allow for novel solutions to emerge.
• A fair distribution of value is key. Incentives should be provided for all market actors, which will also result in better outcomes for end users.

The response to the Call for Evidence on Open Finance should be seen as a complement to the EBF response to the European Commission’s Targeted Questionnaire on Open Finance.

For more information please contact:

Alexandra Maniati
Senior Director of Innovation & Cybersecurity, a.maniati@ebf.eu

Liga Semane
Policy Adviser – Innovation & Data, l.semane@ebf.eu

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About the EBF:
The European Banking Federation is the voice of the European banking sector, bringing together 32 national banking associations in Europe that together represent a significant majority of all banking assets in Europe, with 3,500 banks – large and small, wholesale and retail, local and international – while employing approximately two million people. EBF members represent banks that make available loans to the European economy in excess of €20 trillion and that reliably handle more than 400 million payment transactions per day. Launched in 1960, the EBF is committed to a single market for financial services in the European Union and to supporting policies that foster economic growth.