AFME calls for EU Open Finance proposal to be fit for purpose

AFME has responded to the EC’s consultation on the EU Open Finance legislative proposal (eventid=21815). AFME expresses support for the EU’s goal of establishing a consumer-centric data-sharing ecosystem but underscores the necessity for key changes in the framework to fully realize its benefits. Emphasizing the centrality of trust, AFME calls for a secure data-sharing infrastructure and stringent safeguards, particularly for the newly proposed category of data users, FISPs, to prevent potential weaknesses in the financial system.
AFME recommends that BigTech companies should not be authorized as FISPs until effective data sharing, as outlined in the Digital Markets Act, is successfully implemented. The organization underscores the importance of reasonable compensation to encourage investments in secure data-sharing infrastructure. They propose a cost cap for small and micro data users, while mid-sized and larger companies should be required to pay a reasonable and market-led compensation to data holders.
In terms of Open Finance scope, AFME suggests limiting its application to individuals and SMEs. They stress that data-sharing policies, including Open Finance, should not discourage banks from investing in data-driven customer services. Additionally, AFME recommends excluding proprietary and inferred data from the scope due to potential infringements on trade secrets and intellectual property.
While supporting data sharing without undue delay, AFME advises against real-time data sharing, considering it disproportionately burdensome without commensurate benefits. For the implementation of the proposed schemes, AFME advocates for a 36-month period, followed by an additional 12 months for the rest of the FiDA proposal. They propose a phased approach prioritizing use cases with significant benefits and limited development requirements to facilitate a balanced and pragmatic decision-making process regarding the governance of data-sharing schemes.