Building a future-proof open finance ecosystem: The FIDA trilogues

Executive summary 

DIGITALEUROPE welcomes the proposed financial data access (FIDA) framework as a key enabler of financial data sharing in the EU. To ensure its success, FIDA must be implemented gradually, allow flexibility in use cases, and align with existing regulations to foster innovation, competition and economic growth. 

In the upcoming trilogue negotiations, we urge policymakers to adopt the following recommendations to build a future-proof open finance ecosystem: 

• Implementation and use cases: FIDA should follow a phased implementation approach, allowing up to 48 months for industry adaptation. Stakeholders should be actively involved through Technical Working Groups to define high-demand data categories. To ensure efficiency, only datasets with clear market demand should be prioritised, with an impact assessment guiding implementation. 

• Scope and definitions: FIDA must not restrict data processing to financial services. Instead, it should enable cross-sector data reuse for improved product offerings. The definition of ‘customer’ should explicitly include retail clients, SMEs and mid-cap companies. Data users should not automatically become data holders, and historical data retention should align with the two-year standard in the Payment Services Directive 2 (PSD2) instead of 10 years. Mandated data sharing must be limited to raw data, excluding inferred or processed data. 

• Data access, sharing and compensation: FIDA should allow continued bilateral data-sharing agreements until fully consolidated schemes are established. It should promote EU-level, not national-level, schemes to avoid market fragmentation. Platforms facilitating financial product access should not be required to participate in FIDA schemes. Compensation should be flexible, fair and margin-based, aligning with the Data Act.

• Supervision and permission dashboards: Financial institutions should be supervised at the EU level, whilst other entities should remain under national oversight. National competent authorities (NCAs) must cooperate for harmonised enforcement. Permission dashboards should align with Payment Services Regulation (PSR) dashboards, allowing consolidated management across schemes, centralised permission bundling and outsourcing to technical service providers. 

• Regulatory alignment and data transfers: FIDA must remain consistent with the General Data Protection Regulation (GDPR), the Data Act and the Digital Operational Resilience Act (DORA). It should explicitly allow all legal grounds under the GDPR and not impose stricter intra-group data-sharing rules. Restrictions on third-party data transfers should be removed to ensure coherence with existing protections.