Das ist Fintech & Beyond von UI, Financial Services Deutschland. Der Podcast für alle, die am Fintechs-Dat-Up-Ökosystem und der Digitalisierung der Finanzdienstleistungsbranche in Deutschland und Europa interessiert sind. Welcome to a new episode of UI-Fintech & Beyond. Mein Name ist Peter Fricker, und heute geht's um einen Topic, dass es keine langere Regulatere Konzept gibt, aber die Entwicklung der finanzielle Industrie des Skollens. Ein paar Tage ago, wir mussten die Digital-Final-Konferenz 2026, wo UI-Hoster-Hip-Profil-Panel-Titlet, Implementing Open Finance in der EU, was kann man von anderen E-Kosystemen lernen? Es ist eine der die Situation für Europa für die Zukunft. Wie kann die EU-Bilden und Open Finance-Franwork, das globaler Kompetitive, ein Land mit europäischen Values, und auch ökonomisch und operationally viable? Wir haben die Situation im Städchen und die Fahrbieter von den Technischen. Wir haben die Fundamentale gesprochen. Was genauer ist wieder, um zu verwendet? Was ist das für die Fintechs-Fan? Konsumers, SMEs oder Innovators? Wo will die Reprodukt- und Service-Value kommen? Und was kann Europa lernen von E-Kosystemen? E-Kosystemen, das Jahr ist er�ert, wie Brazil, die UK oder Singapore. Zu unpecke ich diese Fragen, wir haben 5 Ausdaining-Vorhäuser, die Regulation, Banking, Insurance und Global Open Finance-Experien. Aliskadel, Europan-Kommission, Verena-Ritter-Dörring, Taylor-Wessing, Daniel Nistrovsky, Pradesco-Presil, Joros Hansen, Barcher-Bank, Stephen Foss, Neid-Digital Insurance und all moderated by my e-Wi-Kolleg, Christopher Schmitz. Ein mager-Theme, throughout the panel, war die Tension zwischen Innovation und Controllability. Data will move. The real question is, whether it will move in a secure, ethical, and well-governed way. End-of-year runs to stay competitive in an AI-driven financial economy, it needs high-quality standardized and accessible data as a foundation. Otherwise, Europe's ambition to lead and trust with the AI becomes far more difficult to realize. We also discussed what institutions can already do today, the no-regret moves, that pay off regardless of how feeder it works. API-First-Architecture, Gov. and AI-ready data, ecosystem partnerships, and early involvement in scheme design. And we look honestly at where the industry needs clearer guidance, more stability, and more room for experimentation. In this episode, you'll hear the full panel, a nuanced, constructive and forward-looking discussion, about how open finance can become a reality in Europe, and what it takes to turn regulation into a real value for customers in the industry. Let's get started. Here's the recording of our panel from the Frankfurt Digital Finance Conference. [Music] Okay, everybody. Wow, wow. That was loud. It's an important topic. So speaking out loud is super important. So I'm going to do this. Thanks everybody for coming to this panel. We think we have a very unique and distinguished composition of people here on the panel that can speak to this very important topic about open finance. One thing in the beginning, we will record the panel, and it will also be published on our UI-ThinTech-MPO on podcasts. So if you want to share it with anyone, feel free to go to the podcast sections of Apple and Google and so on. You will find the UI-ThinTech-MPO on that thing, with the episode of today. So starting with the topic. When we talk about open finance, we're not talking about something that is very remote or regulatory concept. It's something that is in our daily lives today. We talked about the development that is already reshaping financial markets around the globe. Other regions have moved fast. Singapore, Brazil, India, Australia, all those markets have already embarked on the journey and even completed parts of it. And these ecosystem show that when financial data can move securely and with consent, new ecosystems can emerge. New services can thrive and consumers as well as SMEs will benefit. The exchange of financial data from my point of view has become a global must-have. It's not a nice-to-have or an option. And this creates a very simple question for Europe. And we're coming to the word that nobody likes or many people don't like in the industry right now in a minute. Do we want to compete on equal footing in the new data-driven financial economy or do we risk following behind as EU? At the same time, we also are witnessing a generational shift. Younger consumers are already demonstrating a far greater willingness to share their data when the value exchange is clear. And when they receive personal insights, financial coaching, or simply more intuitive digital experiences. Great examples. We also have in the German market, if you know about finance school, who has been one of the local players here in Frankfurt, they have a significant number of clients today, three million, which is actually quite interesting, because they have done it without even a regulation being in place. For them, for the younger generation, the idea of data flowing across trust and providers is not disruptive. They're trusting the Amazon's and the Google's even today, sometimes more than their own financial banks. So they are also surprised when financial services are not as seamless as they are used to from other experiences. So we have to do something about that to make it more seamless and for them a part of their digital lives. Now, if you put on top of all of this AI and agentex systems, we're coming to the question, what is actually being done to make AI work? So AI will thrive on high quality, well-governed data. Without accessible, standardized financial information, Europe's ambition to lead, specifically in trustworthiness and ethical AI, becomes much harder. At the same time, this is precisely why an ethical control and clearly regulated framework is so important. And we will see, we just discussed a very interesting use case from Spain, a couple of seconds ago, a month, the panelists, and we will clearly showcase that regulation is something we need. We might not need feeder in the way it is today, but we might and we definitely need some regulation about data sharing. So Europe has right now the unique chance to define a model that protects the citizens' rights while enabling competitive AI driven services. A model that combines innovation with ethics and speed with responsibility. But we need a well-designed and orderly framework for doing that. A framework that encourages participation instead of overwhelming institutions for complexity. One that reduces unnecessary costs to harmonize standards and predictable stable rules of the game. And one that creates space for experimentation, maybe in a sandbox. Because moving from pilots to real, scalable implementations is where the true economic value will lie. So how can we implement open finance in a way that learns a global example? That's why we compiled this distinguished panel. And at the same time, we need to create something that is truly European and follows European standards and ethical guidance. So how do we do that? And for this, we have a very distinguished round of panelists here. Let me start with the lady to my left. I'm super proud and really, really hyped that we have managed to get the EU commission into this room. Alice Gudell, she is a policy officer in European commission part of Commissioner Merkel's cabinet responsible for and now come three words that the industry does like Dora, Meeker, and Fida. So she will talk about the vision that the European commission has then. We have Verena Retardurring. She's partner at Taylor Westing in Germany. She is a long-term regulatory lawyer. She has seen many of the regulations come and pass and put into operations. Then we are also exceptionally proud that we have Daniel Lestrovsky. So Daniel is head of open finance regulation at Bradesco in Brazil. He actually took the long journey to come here. So to talk about the experiences in the market in Brazil. And we have Joris Hansen. He's the founder and head of API at Deutsche Bank. Also someone that has been driving the discussion on data sharing with together with TechQuat here here in Frankfurt through the different events that he've already orchestrated very actively. And finally, we also have Stephen Foss from near digital insurance. He's the CEO and founder. And of course, he has a very distinctive view on the insurance industry, probably challenging the existing incumbent infrastructures. So let's start with the panel right away. So first of all, Alice, what is Fida trying to really unlock from the Commission's perspective? What outcomes is Fida meant to unlock and who's going to benefit first? Thank you. Do you hear me? Yes.
a very good question. I think when we started drafting the digital finance strategy in 2020, the objective of having a framework for open finance was to have better financial products for consumers. So this was always the goal. It's still true today, but there are underlying objectives as well. And one of them is also to open competition in the financial sector. If we want more innovation, if we want better products, we need also to have a more competitive financial sector. And this angle is more important than ever. Competitiveness is really in all the speeches at the moment. So we have to also be aligned and consistent with what we put in our speeches. So for us, really, the competition angle is really important. And then other objectives related to FIDA, for example, the modernization of IT infrastructures. This will have to happen in any case, whether we have FIDA or not, but we thought maybe FIDA would actually encourage and help maybe give the push to modernize the backend infrastructures. And then it's also a continuation of PSD2. I mean, when we had open banking in mind, the objective was to then go to a big scope once it's implemented. And it's also very much aligned with the objectives we have in the savings and investments union. I don't know if you're familiar with it, but basically one of the very important angles is financial literacy. And if consumers have access to better consumer interfaces and more options and comparison tools and switching tools, that's also a way for them to be more financially literate. So these are the, let's say, the main objectives. I answered in many different ways, but the core answer is really having better products for consumers. Very good. Thank you, Alice, for stating that. Marina, after more than two and a half years of discussion, I remember the day when it was published on the 28th June of 2023, when we had the first draft, I really kind of stumbled across it in a newsletter and I opened the regulation and read it and I called my team and said, "We need to do something about this. This is going to change the world." Right? Now, looking at it two and a half years later, where are we from the latest-ledive process? And what do you have to say for how it's probably going ahead? Yeah, I hope it is going ahead, basically. I think we have some, still some remaining roadblocks. I hope will be solved in a dialogue in the next half year. I don't know. I think one point the market is complaining about is the time length for implementation. So maybe the usual 12 to 18 months is not enough here. And also maybe we need a step-by-step approach for getting data into FIDA. So historical data, maybe not 10 years ago. We need all the context of the past 20 years. Maybe we can start with two years, three years and then go year by year. I think this is something that is being discussed but could probably also be resolved. And then we have this discussions on gatekeepers. Also with every market participant here, I'm having this discussion. Yes, I think it is basically an artificial discussion because the gatekeepers have the data or will get the data by consent anyway. And we have mechanisms in place like in the digital markets act or in the data act already which we can apply here and we already have in the drafts. Now also some more scrutiny for the regulators for those. So for those gatekeepers. But so those are roadblocks. I think can we hopefully solve in a dialogue? Yeah. And I think what we're doing today can be one part of the discussion because I think the communication in the past at 24 months has not been let's say collegial but rather throwing stones at each other from both sides. So interesting thing is looking at at yours at the next candidate for answering a question. We are talking about value at four clients in the end. What are the products or the services that you foresee which will really profit from data exchange? Just to give some context. I guess it was a little bit later than you in February 23. In my case was June the first time I read about feeder. I realized okay this is nothing we can do and solve as a bank ourselves. So we kicked off a series of events with the tech party. I see Florian over there. We called feeder roundtables to start to address the questions. What does feeder mean for us as an industry and what are potential products? Three topics or three products came up that I would like to mention. The first one is probably not too surprising as 360 degree for the customer. Like an additional multi banking because then you have obviously not just banking but also insurance data. And you mentioned it in the introduction if you combine that with artificial intelligence. You have the possibility of real individualization for customers. You can make contextual offers for different relevance. So that's one product, potential product. The other one that was also a very interesting discussion around SMEs. We did not end up with a blockbuster product like multi banking but we had very small and particular product ideas coming up in around table around planning of liquidity stuff like that. You know that you could help SMEs throughout the life cycle of their entrepreneurial life or throughout the different occasions. And the third one, unfortunately, Julian is not here. He invented this word couch friendly processes. Because when we do a financial use financial services nowadays like applying for loan, we have together a lot of information. We do this in the evening or like I don't know we have plenty of documents lying around and this could possibly become easier with open finance because more data would be available. More data could be reused. I could could automatically share or have already shared the information. So I could use it in a different context. And this could increase speed for customers, make processes easier and at the end of the day generate new possibilities for products. So those are the three products. Very good. Sounds great. And specifically for the younger generation again as I mentioned in my introduction, the younger generation these days they don't have one account. They probably have five accounts and three different offers from the obrokers and then probably source their financial services via chat GPT. So a different story and that needs to be served somehow. Stephen from your background from the insurance and it's real, no, you start it out with an incumbent and then found that your own more innovative solution. What is your view on to this? Well, very much in line with everybody here I think and also with the lawyer which is seldom that I'm in agreement with a lawyer but apparently we need, we need regulation because what you just mentioned is the whole world and I'm speaking of the 45 years and younger. They are already sharing data. The problem is that they're sharing data in the wild west and that can't be in the sense of protecting the customer. So you said the lazy couch products, we call it the convenient products. This generation wants convenience. They are aware of the of the worth of their data. They know that this is something important. They don't share their data easily. They want to share and they want to benefit from it. And the research shows that they are willing to give it out if there is a clear benefit. And this is why we believe we have to invest in the infrastructure and by the way these costs that we are discussing, oh it's too expensive to create the infrastructure, you have to create the infrastructure anyways. The only issue that we do see in Verena was right is maybe the time frame that we are giving. Maybe 18 months is too short for some of the corporations but it's not a question if you have to do it it's just when because you will have to do it because customers and the next generation and we are all ready to all. Everybody that's here on the panel, sorry but we are all we are all too old for this but the coming generations they will demand it. That holds true for most of you as well by the way. Yeah no great. I think the interesting notion here is that you mentioned it what would happen if we don't have a regulation, right. I think that's if you take for a moment that stands and you take a look at what it would mean there's no regulation for data sharing, there's no ethical environment, there's no link to the UDATA Act and whatever we have in Europe as safeguards. It would basically mean that the U.S. companies that everyone wants to obviously see that they are big enemy, they would have access to the data just through interaction right. I think there's a great example that you brought in our discussion, Silla maybe you just mentioned it at this point. Yeah I can mention most of the in the room I might be aware that we have two new companies now actually are actively on the open AI platform.
on chat GPT that is intro 5 from US. That's a comparison platform where you can basically talk with chat GPT and get your kind sure. They're taking 194 million data sets and then doing comparison, which is more astounding for me. At the moment is actually the European example. We have a Spanish digital insurer called Tuyo. And they sell household insurance and building insurance via chat GPT. Apparently that gives me a lot of question marks because they are within the EU. If they're selling the product, they're giving advice. This would be IDD relevant, giving advice. How is this protected? How is the customer protected? They are exchanging data via chat GPT. You mentioned it. Data is personal data is going outside of the EU onto an US platform. Do we want that? Is that really what we want? And I have quite questions about this. I'm totally about open market. But at the other hand, we have to be transparent to our customers what's happening with their data and it should be in a regulated way. Yeah, I think Fida is also supposed to foster the single market. We have with Daniel, we have someone from Brazil, with a huge market, very single in its own, because it's one market. Coming from your background, and I know you've gone through a very, very harsh regime by your regulator, right? Because just to mention it, the central bank in Brazil published the standards in 2020, I think was 2020. And they gave the industry a year to comply. We're not talking about two, three, four years, like we do here in Europe, but one year, right? So coming from your background and your experience, how do you see that Brazil basically went through that journey? After five years, what are the product categories that you see have proved most possessive and was the impact on computational market segmentation? All right, okay. And so in Brazil, we have opened our countries where we start to build and open five years ago. And I couldn't agree more with the colleagues here, because we proved that that one year target was not enough. The central bank had to extend these. And we start with not so good version of the OpenFinds self, because they have to deal a lot with standardization among all the players and among all the products. It's pretty much the same, but not really the same. And you learn it by doing. So you have the version one, and then you come the version two, and the version three, and so on. And you have to rewrite the code, rewrite the APIs so many times. And I don't believe that's the better way to go to the market. You also, as a consider that OpenFinds have some assumptions. The first one is all the players I use in their own data at the maximum, I can guarantee it's not what happened. The second assumption, all players have knowledge of all the data and access to all the data. It's also not true. And the market is prepared to plug some user case in top of the infrastructure itself, because the OpenFinds in the sharing data is just an infrastructure. It's not just a product for itself. So for the client to have any kind of value, you have to know that data, extract that data, and compare that data, and then you'll offer something, or could be a multi-banking extract, or advice, or something like that. So we have to give the time to market to prepare this kind of user case in the news. And we are suffering for five years. And now we are having a more or less stabilized ecosystem that we're starting to get some value from the OpenFinds itself. So it's important to give time to market to prepare it yourself and put all the phases one by one, not all together, because not all the market type are preparing the same way. Account information. It's one set information. Card information is different when investment information. It's another one. Insurance is totally different. So we have OpenShore in Brazil. You can't see the traction that you have in OpenFinds there. They are different ecosystem, but we don't have the traction already. And so that's important to have a stunder that everybody agrees. It's not that easy, because multiple players with different needs and wants. And also give time to the market, put the infrastructure in place, and also create value from that infrastructure. That's OK. So five years is our own journey. Obviously, you've arrived at something that is successful. So just for people that don't know, the Brazilian ecosystem currently-- and I looked up the numbers for this number. Probably if it wasn't again in January-- currently, December figures is on a weekly basis. The ecosystem generates 5 billion API calls weekly, meaning on a yearly basis, 250 billion. 150 million consents have been provided from users to share their data. And I think you did some back-of-the-envelope calculations, probably 20 to 30 million clients actually using it. So obviously, there is a way to get there in a successful manner. Now, Alice, coming to you again, how do we ensure in Europe that the data scope and the breadth aligns with the market requirements? Is there potential ways of softening that approach? What are the next steps and outlook that the commission is looking at? Thank you. So just to give a bit of context on where the file stands. So we adopted the commission adopted a proposal in summer 2023. And since then, the co-legislators-- so the member states and the members of parliament-- are negotiating, basically, to come forward with a proposal that can be voted. So of course, the proposal we had on the table in the beginning evolves. And that's a good thing, because also, we arrived a bit early with our proposal. And of course, if we can take some feedback from our co-legislators, but also from the industry, that we will take for sure. So at this stage, because the text is still negotiations, we continue to take feedback. And we continue to dig and to try to understand the difference between what's actually happening on the market and what's happening at political level. Because it's true that in negotiations with-- we are with politicians all the time. So sometimes, our discussions can maybe depart a bit from what's actually happening on the grounds. This is why we participate in these types of events. This is why we meet with market participants. And it's not just either fintechs or incumbents. There's also a big group in the middle. And the objective for us is really to speak to everyone, to understand where we are receiving constructive feedback. And that's what can integrate in the proposal. And the question of scope-- of data scope, there was a question on the entities in scope. But the real one now, I understand, is more on the data side. And here, we're trying to collect as much as possible to see where the truth lies, basically. And actually, we've been really impressed by the number of people that have come to us with really constructive proposals and suggestions to bring to Fida. And so, yeah, just to say that on the scope, there's still a lot of room to adapt. If the scope is considered as too ambitious, too large, at least to start with, then we can think about either reducing the scope as a whole or eventually having this phased approach where we would decide specific data to start with. And as long as it doesn't stop the common objective to really accelerate. And that's a bit to try to figure out right now. Is this phased approach really a necessity on the ground because we need time to adapt the infrastructures, to modernize, et cetera? That's one thing. But we shouldn't delay too much either to start implementing open finance. Great. Thank you very much. Coming to this question of Fida and AI, oh, data sharing and AI. Is data sharing a comprehensive sort of data sharing, we say, with Fida? Is that a prerequisite for a successful AI use case? Or could incumbents work on their own? Data is that enough to draw that 360 picture that you basically brought forward yours. And giving that question to you, first of all. So when this question is also-- I mean, like I used to say they are the perfect match for Fida and AI from the perspective that they would be based on the same infrastructure. So the perspective I'm just thinking about is AI needs data, needs structured data, needs reliable data. And so would open finance, Fida, whatever data you would explore.
And this goes back to, okay, what's the underlying architecture? So do you follow the API first principle of exposing every Services in API? Yeah, I think that would be the necessary decision because This would allow you or give you a lot of flexibility also in terms of Developing internal products because you have this grown IT system with many Different systems just thinking about an architecture diagram. This is really messed up and so APIs would help you to build services like With Lego bricks, you know, compositing out of different services. And if you have this infrastructure which would speed up your Internal product development, AI development, agent development, then I guess it's just a small step to expose this data to the outside. Very good. Very enough from a legal regulatory view. Is there anything where there's intersections between FIDA and AI infrastructure? Yeah, first of all, I couldn't agree more. I think database innovation goes hand in hand with AI based innovation. So and but we are still in the regulated space so we also need to put on top the AI regulation and Dora as well because we have regulated entities sharing the data and using the data. So it's I think the framework is there. It might not be as easy as just putting it into chat. But it might also be more secure. Another question and that this goes to Daniel because you've been through this. Is talent eliminating factor in a sense of do we need to work on talent or the other question you could also pose the other way around if we don't offer something like a data sharing environment. Is the talent interested at all to join us in the EU to work on this? I don't I don't believe that this questions all about just for open finance because talent and architecture is a it's a factor for everything. And when thinking open finance is more wide way. You see that you have a kind of lots of other data serves that are open as well. So open finance or FIDA is just one more source that complement all the data that we're using. And for that you have to have the constant constant of the client itself. So if you have a good structure that you can use your own data and other search of data for sure you are going to uplift with the data from FIDA or open finance itself. But you have to concern that you have a cost that costs is convinced you're client as somebody here that you are going to give him back a benefit because the client is very conscious. They are providing something and looking for something back and that's really important. So in learning from five years what I learned that you have to construct your base before and then you plug in the open finance data and then you can have the lift in client facing our services not so well. So that's we are learning but I don't consider open finance or FIDA a bucket for itself. Very good. Now I think while we are very bullish in the sense of that at least we from a why that we think we need open finance regulation. I think we should not ignore that there are key concerns in the industry and there are good reasons for it. One is the legacy infrastructure, significant cost for transformation, the risk of losing your client while on the other hand there might be the opportunity to re-win your client in the digital space coming from. So addressing these kind of key concerns first and Stephen maybe you probably have to switch on now your income and memory. I do. And think about how was it when you were working at income and companies and what would help them most during the implementation knowing what the catalog of activities is going forward. Well first of all also we have to be fair to the incumbents because they have over years grown IT infrastructure which is not pluck and play which is not legal bricks which are basically silos. So we have one system for this and one for the other and the big challenge is what we have not talked about but it's part of the FIDA main theme it is also about real time processing of data. And apparently real time is something that an incumbent has some challenges with and what you need to focus on and I think we are talking here sometimes FIDA as a burden to the industry. No, it's an opportunity to the industry. It can be a catalyst so that certain IT investments are being made I said earlier they have to be made anyway so take FIDA maybe as a focus point and say okay this is where we need to go it will come someday and so we need to concentrate now on streamlining our systems making the necessary investments and become attractive to our customers because at some point and that's the danger. At some point we will lose our competitive edge within the EU if we don't go forward with this and I think there's a big risk not today not tomorrow but in a couple of years if we are behind and Brazil is sending on my left side is already five years ahead. Just giving global markets this could be a threat to our industry and as an incumbent I want to live another hundred years so this is maybe something we should all focus on not not not to criticize the incumbent just to say where they are coming from from a lot of heritage but also from a lot of legacy. I think looking at also some of the clients we've been working with in this space there is a considerable amount of investment required I think there's no doubt about that and this should be recognized somehow right and there needs to be obviously some guidance also from the top to make it less burden some I think Danny you clearly spoke about the different variations of your standard until it finally was that for sure was costly. So a very similar statement also from Australia where there was a commission report who basically stated that the moving standards basically made it so expensive to get where they are today so looking at Brazil. I mean is there anything you could give us as a as a as a tip to really lower the cost of implementation for the industry. It's what the market is asking for and just give one the time the market needed to make the standard right. I'm not I'm sure that it's not but right in the first version it's almost impossible but we in Brazil have a really really short time to discuss the first and also for the second if you could discuss the second instead of. One standard for longer time probably we have a better standard and a better implementation at first with little less much more less correction and so on so it's something that you guys have to think about how much time you are going to give to discuss the standard and then to implement the standards of but it's important to have a standard self. If you just regulate and go everybody do what he's not working as well. So we have it to standardize the market itself to all the players communicating the same language. I just if I can just because this is exactly the point we need to be have a common agreement on a on a base standard and as Verena said we can evolve the standard over time as technology progresses we can also progress the standard but we need to find one common point to start off and then have a common exploration of what you did over the past five years and I don't think that we can fully avoid parallelism. So some costs will have to take because we'll things change over time but if we can agree within the EU on one common set of standards and I understand that according to industry the standard might differ a little bit we also have to take knowledge of that because you said the insurance standard is maybe different to the to the banking standard and the other financial services but still they are they are common ground and I think that the biggest step we have to take now going forward is to accept the common ground to start off. That's important. That sounds like the commission needs to put a little bit more standards into the ground and I'm not talking about detailed standards. I think that's something that the industry actually needs to create themselves and need to define themselves but kind of the minimum requirements to start off right. I think there is some stage to approach you now but what can you do about this to make it more palpable? So it's one of the big debates of the moment when the proposal was adopted two and a half years ago we had many months of expert groups and round tables and workshops to understand the standards.
and what to do on the schemes and how to make sure this is done in a way that it's coordinated. And we decided to move forward at the time with a very much market-led approach where basically we're a bit told to let the market do because they're better at it, which I fully agree with. So initially this was the mindset we had. So we let the market, the industry would be the ones sharing the data, using the data. So they know better how to do it and in which way they want to do it. In the meantime we've received very different type of feedback, including the fact that there's the risk of having too many schemes or that it's not standardized enough and that it will create fragmentation, which is not at all what we want to do with FIDA. On the contrary, we really want to have a very common approach, not something fragmented. So as I was saying earlier, we're not stubborn, we don't have to stick to our original proposal. And if we can find a bit of common ground, so a certain level of guidance to help the first scheme creators, but at the same time without intervening too much, maybe that's where the right balance is. But as I was saying, it's ongoing discussions and feedback that will probably lead us to the right balance. Just stating there is a very successful European scheme for financial services called ZEPA. It's been in place since 2003, there is one governing body which is run basically by the associations. Why don't we build a EPC for insurance, for asset management and for banking? That could be a top level kind of organization where everyone can feed in. All the associations will have a place around the seat around the table. So maybe that's one thing to think about going forward. Now one thing that has also come up in the course of identifying customer demand, as well as doing first kind of iterations of trials, let's put it that way, or pilots, is always the sandbox, right? So beyond these kind of standardizing questions that are surely relevant, is there anything where feeder could be made more easily, introduceable or more operationally viable by using a sandbox approach like we saw in the UK, for example? You're as well as your view. Well, I mean, when we started our API program that was back in 2015, before the actual PST2 regulation, and we are now offering premium APIs, we had this question, okay, what would the market expect? So we had different kind of formats to understand what what Fintech players need, what other companies would need for us to develop meaningful products. So we set up a sandbox actually, and that helped us a lot. So in the beginning, we did a lot of hackathon, so developers came to us, told us, okay, what about this data field or that? And without this, that doesn't make sense, and does not workable. So at least in the sandbox, we could quickly introduce this data field and see what the prototype looks like, and what the outcome is. So I perceived this as a super helpful, because other than that, it was quite standard, like a discussion, you know, and a theoretical level, but this helped us to move forward and prove to be very valuable to listen to the market. The other thought I just have is we had a very good presentation in one of the roundtables about another EU funded project called Fame. It's a technology project, sort of say, building an architecture for federated data marketplaces, and what it does and how I understand it is, does it, that it solves some of the technical questions a scheme would face, like managing the policies, the billing and stuff like this. And as far as I understand this approach, it's also possible to connect different sandbox even. So this could help fragmentation in a technology way, or ease the risk of fragmentation in a way, and also help, I guess, to adopt quickly, because when we talk about standards, it's just one side of the scheme, but all the operational details and stuff, and really the technology integration is a huge task, not to miss them. Absolutely. Are there also legal constraints around sandboxes? Yes, so we have, on the one hand, the regular toy sandbox, which would require legislative authorization, so it would require something in the feeder text to allow this, and also give some framework. And then we could test products, or we could test APIs, and also the market requests. But then we would really have to have a regulatory framework, also for the sandboxes, and usually all participants, also the regulators who are closely involved, usually also learn from it. But we can also have sandboxes out of this, so in an unregulated space, where just voluntary data sharing can be used for products, and so on. And I think this would maybe here in this context of open finance, give a push to the market, maybe to show the market what customers need, what customers are willing to share, also in a safe space to start with. Okay, great. Sounds like some more thinking for the commission, on whether there's a sandbox, and needs to be part of feed itself. Now looking at the process from an EU point of view, and also whether there's a roof on negotiation, maybe, Alice, what can we still adapt from abroad for the current EU process? Is something we can learn from Brazil, from other ecosystems? And will you feature that into the current draft? Why have you done it already, maybe? Absolutely. I mean, we're also realizing how much open finance is advancing abroad, but also at home. So it changes a lot the approach we have to our proposal. Now it's a question of having a legal framework in place for something that's already underway. So a couple of years ago it was very different. We were not so confident about how it was going to evolve. And then of course we have examples from abroad that open finance is happening in certain cases with the legislative framework and other cases without. And this is something we don't really want to move forward without a framework is not the right direction to take. So we want to have something from the start that is clear, that is pragmatic. That's why it's still evolving. And by the way, the fact that it's taking time is also related to the fact that it's just the beginning. And we were expecting that they would be pushed back on this, just like there was pushed back on open banking. And it doesn't mean that we have to step back. I mean, if there are ways that we can move forward still with adapting to what is useful for the industry great, we will take that into account. But we will continue pushing because we really want to send that message that we don't want to like behind. I mean, Europe in terms of the fintech industry we've been really good for many years and leading on many aspects of fintech. And so there's no chance that we will let ourselves like behind especially on something like this. And it's also sometimes mentioned in the statements by different associations and individuals that digital sovereignty is a key concern with feeder. I would argue the other way around. We probably need a regulation to maintain digital sovereignty on the data that are owned by the EU citizens. We see the example from Spain, where just overnight by getting an offering, European data is now obviously worked in across the ocean beyond our regulation, beyond our legal framework. So, from your point of view, when we compare this to the other ecosystem, then US is one example where there's only bilateral regulations. What can we learn and what should the policy makers keep in mind? I think if you want to establish a system that provides financial or boost financial innovation, you need to be aware that you can only build this on digital trust because it's about customer data and consumer data. And digital trust, and I really believe this, can also be established by regulation. So everyone will understand this. And then it's not a restriction. It's actually enabling the innovation and the data sharing for the consumers. I think digital trust is really a great thing. It's a great impact here. And if we want to maintain our hands in the EU, authorized by the elections, the parliament, the different entities of European legislation, we should probably, we would better be off doing something about regulation than not doing it, something about regulation. So this has been very quick. We're coming to the end. Now, I would like to ask you a closing statement from each of you. 30 to 45 seconds, you go. Well, I think it's important to look on the product side. I think we talked a little bit about the products. Now we ended up talking about the customer, but this is where the whole journey starts. So I think having showcases of what would be possible with data, maybe through some sandbox
initiatives, I think that would be a game changer. Daniel. Okay. If you can summarize open finances, I'll give you a structure and I have to deal like this and I have to give time to construct your own top. And in the end of the game, how you serve certain client is what matters and they really and you can use or not open finance for that. So that's the key question. Are your company serving your client in the right way and can scale up the open finance data for itself or not? That's the main points. Great. Thank you. Excuse me. I just repeat myself. I see there's a big opportunity to improve our data infrastructure and I agree with Anna and with Alice, it has to be in a legislative framework in order to also have the entry level high enough so that we basically also protect our customers and not let them go over the pond because this is the value they add to our infrastructure. Well, I think open finance will be an innovation booster for the financial market which we need also for the customer journey and I think it should be seen as an investment in the future and not just an investment for the next two years. I couldn't agree more. Very quickly from my side, I would say that for open finance and feed them more specifically to work and to really have a big impact, we absolutely need data holders and data users to work together. So I know it's not always easy. I know there are differences of views of work practices, of products, business models, but this is a key condition. And the sooner we manage to collaborate between both sides of the data sharing, the quicker we will get new business models, new innovations, new products for our consumers and that's what's really the most important. Great, thank you very much. I'd like to add to the two parties, the third part, which is the regulator. So having this open dialogue I think is something that we definitely need, right? Alice has come here also to open that dialogue again. So if you or anyone from your companies from your environment have something to say, something to contribute to this probably less nice discussion that we had over the last 12 months, I think would be super helpful. I think the willingness to collaborate is something that is essential to make this work. And in the end we make it work for the clients. For you as clients of your banks, your insurance is your asset managers, but also for the people out there that are not in this room, who will probably profit from a much better situation being able to be much more digitally advised, much better products, much more choice, much more transparency on what they need to build a private pension scheme for themselves in the future. We all know that this is one of the key challenges and the key challenges of the changing generations. Let's try and do something about it by providing a data infrastructure that helps everyone to get much more professional and much more financially literate. Thanks very much for the contributions of the panel, super deep insights. We have five seconds left so we unfortunately don't have time to do any questions, but please feel free to address us after the panel. Thanks very much for being here. Thank you for listening to the special edition of UI FIDG and Beyond. A big thank you again to our panelists for their insights and to the Frank Vatigel Finance Conference for hosting such an important conversation. If you found today's episode valuable, feel free to share it with colleagues or anyone following the evolution of open files in Europe and beyond. And as always, if you have ideas for further topics or guests, reach out to us at
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