Position paper - Framework for Financial Data Access

In June 2023, the European Commission proposed a legislative package on a framework for financial data access. While we welcome the market-driven approach of the proposal, allowing the market itself to determine many key aspects for a secure and trusted data sharing ecosystem, a number of elements should be clarified. This includes some of the key definitions (eg ‘customer data’ and ‘customer’) as well as the categories of customer data in scope. Furthermore, in order to maintain trust in the broader data economy and data sharing ecosystem, it is important to ensure the implementation provisions reflect the important operational and security challenges the creation of data sharing schemes will face. Additionally, while the recognition of compensation as an important incentive for high level of quality and high functioning data sharing mechanisms is a positive development, a more proportionate approach should be adopted.

For permission dashboards to be a useful tool to build consumer trust, further clarity on the responsibilities of ‘data holders’ and ‘data users’ is needed. Moreover, for a data sharing ecosystem to flourish, there must be consistent and appropriate regulatory oversight, including for the new ‘Financial Information Service Provider’ category. Finally, the interplay of the proposed regulation on a framework for financial data access (FiDA) with other relevant EU legislations, such as the General Data Protection Regulation (GDPR), the Data Act, the Digital Markets Act and the Payment Services Regulation (PSR), should be clarified.