From Open Banking to Open Finance: What FiDA Would Change — and Why It Keeps Slipping

Update, 11 October 2026: The trilogue negotiations on FiDA are at a standstill. After two rounds in 2025 the Council indicated that it intends to amend its negotiating position but has not yet formally adopted a new one; since September 2026 the European Parliament has listed the file as blocked in the Council. It is open when the negotiations will resume.

Open banking gave Europe regulated access to payment-account data and then stopped at the property line. Everything that actually describes a person's financial life — savings, securities, insurance, pensions — stayed behind closed doors. The Financial Data Access framework, FiDA, is the EU's attempt to open the rest of the house. It is also a case study in how hard that is.

Proposed by the European Commission in June 2023 alongside the PSD3/PSR package, FiDA would establish rights and obligations for sharing customer financial data well beyond payment accounts: savings, credit, investments, crypto-assets, non-life insurance (excluding sickness and health insurance), and supplementary pensions. Around that data perimeter it constructs an institutional design — regulated financial information service providers (FISPs), mandatory participation in financial data sharing schemes that standardise interfaces and, crucially, compensation, plus permission dashboards giving customers visibility and revocation control.

The compensation point deserves emphasis, because it is FiDA's answer to open banking's original sin. PSD2 forced banks to build interfaces for free, which produced grudging compliance and minimal quality. FiDA's scheme logic allows data holders to be paid — turning the interface from a regulatory tax into a potential product line, and changing the political economy of who wants the framework to work.

Why the Timeline Keeps Moving

FiDA's legislative journey has been unusually turbulent. Parliament reached its position in April 2024; the Council followed in December 2024; and then the file collided with the deregulatory mood of the new Commission cycle — at one point appearing on lists of candidates for withdrawal before being kept alive amid loud industry and member-state disagreement about scope, cost, and sequencing. The honest status summary for 2026: two trilogue rounds in 2025 and a standstill since, scope and cost contested — and, if the file is concluded, application realistically toward the end of the decade after long transition periods.

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FiDA's fate matters less than FiDA's direction. Every serious financial firm in Europe is now planning for a world where customer data portability is the default — the only open question is the calendar.

The DACH Reading

For the DACH market, FiDA lands on fertile and difficult ground at once. Germany has one of Europe's deepest retail savings and insurance markets — precisely the data pools FiDA would unlock — and a financial sector that has already absorbed the cost lessons of PSD2. Insurers and asset managers, largely spectators of open banking, would become data holders with build obligations for the first time. Meanwhile fintechs with aggregation, advisory, or embedded-finance models gain a regulated access path that today exists only through fragile screen-scraping or bilateral deals.

Switzerland, once again, follows its own trajectory: no FiDA equivalent by statute, but a Federal Council push for voluntary open finance under threat of regulation and industry initiatives around a common infrastructure. Convergence in substance, divergence in method — the DACH constant.

The Scheme Question: PSD2's Lesson Applied

The deepest design choice in FiDA is that access runs through schemes — multilateral arrangements in which data holders and data users agree standards, liability, and compensation, under regulatory deadlines and with authorities empowered to intervene if the market fails to organise itself. This is a direct lesson from PSD2, where the absence of a scheme layer produced years of interface disputes, inconsistent API quality, and litigation-by-standardisation-committee. Schemes internalise those conflicts: the parties who bear the costs negotiate the rules, which is both the design's elegance and its risk — negotiation among unequal parties can also entrench the strong.

For DACH participants, the strategic consequence is that scheme formation is where influence gets exercised. Waiting for finished standards means accepting standards written by those who did not wait.

Insurers: The New Data Holders

The sector facing the steepest learning curve is insurance. Unlike banks, insurers never built regulated data interfaces at scale — and FiDA would put contract and coverage data from non-life insurance in scope for sharing at the customer's instruction; the proposal leaves out sickness, health and life insurance data, except for insurance-based investment products. The product implications cut both ways: brokers and comparison platforms gain the raw material for genuinely personal advice, while insurers gain — if they move deliberately — the same access to banking and investment data for underwriting and advisory propositions of their own. The DACH insurance market, dense and conservative, will be one of the most interesting laboratories for whether open finance produces convergence or entrenchment.

Positioning Without a Fixed Date

1. 01Inventory the customer data you hold against FiDA's categories — knowing your exposure precedes any build decision.
2. 02Treat consent and permission management as a platform capability now; it serves GDPR, PSD2, and every future data framework simultaneously.
3. 03If you would be a data user, design the products that justify access — schemes will price casual curiosity out of the market.
4. 04If you would be a data holder, model interface costs and compensation scenarios early enough to shape scheme negotiations.
5. 05Watch the scheme-formation phase closely: the governance of these schemes will decide who actually profits from open finance.

FISPs: A New Licence Category

FiDA would also create a new regulated actor: the financial information service provider, authorised specifically to access customer data under the framework — the conceptual heir of the PSD2 account information service provider, generalised across finance. For data-driven fintechs, this is the institutional door into the framework: an authorisation with passporting, supervisory duties, and — critically — a seat at the scheme tables where access conditions get negotiated. Firms whose product roadmap depends on financial data breadth should track the FISP regime's final contours as closely as the data categories themselves, because the authorisation design will determine whether open finance is an infrastructure for many or a moat for a few.

Conclusion

FiDA is delayed, contested, and structurally inevitable. The combination is not a paradox — it describes most infrastructure regulation before it lands. Firms in the DACH market should use the political pause productively: build the data and consent capabilities the framework will assume, and position for schemes rather than scrambling after them. Aegiron Capital Group helps financial firms translate emerging EU data frameworks into DACH product and market-entry strategy; legal advice comes from the law firm you engage.