FIDA: Reaction to Council discussions on the gradual approach to schemes, compensation, alignment with the GDPR and definition of raw data

Schemes: A two-phased approach

DIGITALEUROPE welcomes the recent discussions in the Council regarding scheme governance and the introduction of a phased approach on the scope of the financial data sharing scheme(s), as this will benefit scheme participants and will ensure a successful implementation.

First, it is important to clarify that the FIDA regulation should provide an overarching governance framework in the form of minimum horizontal principles, that are the same across all schemes. This will help ensure consistency, setting the rules of the game whilst granting flexibility for the market to develop industry and scheme standards (in a subsequent phased approach). It will also help avoid a patchwork of different rules and modalities.

This would also help build interoperability across financial sub-sectors and would enable the delivery of seamless experiences, encouraging and reinforcing consumer adoption, and thus benefit delivery.

Secondly, scheme participants would benefit from a gradual approach on the different data categories that evolves based on two principles: market demand/usefulness and availability/FIDA-readiness of the financial datasets.

Successful schemes would require a two-phased approach:

● Phase 1 (24 – 36 – 48 months depending on the data set): Definition and set up of scheme(s) (building on the FIDA horizontal scheme principles). In this phase, the market should collaborate to specify common technical standards where they do not already exist (i.e. API, data, security, UX standards).

● Phase 2 (18 months): Implementation of all schemes, focusing on high-demand use cases. The 18-month timeline will begin from the end-date of the timeslot for different data-sets.