Building Open Finance: From Policy to Infrastructure

Building Open Finance: From Policy to Infrastructure - CFTE Policy Working Paper

Introduction to the article

In a new paper on Building Open Finance: From Policy to Infrastructure, leading academic experts Douglas Arner, Ross P. Buckley, Christine Menglu Wang, and Dirk A. Zetzsche explore the global landscape of Open Finance, analysing how different jurisdictions are implementing Open Finance systems around the world. The paper highlights key international approaches such as those in the European Union, United Kingdom, Australia, Brazil, UAE, China, India, Singapore, Hong Kong, and the United States. The paper argues that globally there is a trend towards increasingly mandatory approaches, with best results when combined with supporting standards and infrastructure to enable data sharing. The authors argue that going forward, maximizing the value of data requires a new level of digital public infrastructure.

The objective of this paper is to provide insights that can be shared internationally, contributing to the global development of Open Finance systems increasing competition, innovation, and consumer empowerment in financial services​.

About the Key Contributors: 

Douglas Arner, Kerry Holdings Professor in Law at the University of Hong Kong

Douglas Arner is the Kerry Holdings Professor in Law and RGC Senior Research Fellow in Digital Finance and Sustainable Development at the University of Hong Kong, where he is also a Senior Fellow of the Asia Global Institute, Associate Director of the HKU-Standard Chartered Foundation FinTech Academy, a Member of the Management Committee of the Techno-Entrepreneurship Core, and Faculty Director of the Law, Innovation, Technology and Entrepreneurship Programme (LITE). He is a non-executive director of NASDAQ-listed early-stage biotechnology development firm Aptorum Group, a Research Affiliate of the Cambridge Centre for Alternative Finance, a Senior Fellow of the Program on International Financial Systems and of the University of Melbourne School of Law, a PRIME Finance Expert, and an Advisory Board Member of the European Banking Institute, SuperCharger Ventures, Global Impact FinTech Forum (GIFT), Policy 4.0, Alliance for Innovative Regulation, Digital Education Council, and Centre for Finance, Technology and Entrepreneurship (CFTE). 

Douglas has worked with governments, central banks, financial regulators and international organisations around the world on strategies to support financial sector development. He has served as an advisor with the World Bank, Asian Development Bank, UN, APEC, Alliance for Financial Inclusion, and European Bank for Reconstruction and Development. Douglas leads the largest FinTech online course on edX: Introduction to FinTech, with over 130,000 participants drawn from (almost) every country in the world. He has published twenty books and more than 200 articles, chapters and reports on finance, technology, regulation and development, including most recently FinTech: Finance, Technology, Regulation (Cambridge University Press 2024, with Ross Buckley and Dirk Zetzsche). 

Ross P. Buckley, Scientia Professor at UNSW

Ross P. Buckley is an Australian Research Council Laureate Fellow at UNSW Sydney, where he leads a $3.7 million, seven-year research project focused on regulating the data revolution. He serves as a member of the Payments System Board of the Reserve Bank of Australia, chairs the Digital Finance Advisory Panel, and is on the Consultative Panel of the Australian Securities and Investments Commission. Over his career, he has consulted with government departments in 14 nations, including the United States, and ranks among the top ten most frequently downloaded legal scholars of all time on the Social Science Research Network. Twice a Fulbright Scholar, he has held positions at Yale and Duke.

Christine Menglu Wang, Post-doctoral Fellow in the Department of Law, the University of Hong Kong

Menglu Wang is a Post-doctoral Fellow in Digital Finance and Sustainable Development at the University of Hong Kong. Her current research explores the digital transformation of finance and its regulation across various jurisdictions, with a focus on the potential of financial technology (FinTech) and regulatory technology (RegTech) to drive sustainable development.

Dirk A. Zetzsche, Professor in Financial Law ADA Chair in Financial Law (inclusive finance) at University of Luxembourg

Prof. Dr. Zetzsche, LL.M., is Professor of Financial Law at the University of Luxembourg where he holds the ADA Chair in Financial Law (inclusive finance) since March 2016 and leads the Faculty of Law, Economics and Finance’s House of Sustainable Governance & Markets. Professor Zetzsche also functions as one of the Directors of the Center for Business & Corporate Law at Heinrich Heine University Düsseldorf and is Visiting Professorial Fellow at UNSW Sydney (appointed 2021-2024). His current research focuses on inclusive and sustainable finance as well as financial and corporate law, in particular on payment and banking systems, collective investment schemes, institutional investments and FinTech/RegTech/CorpTech.

The history and development of Open Finance 

Open Finance has evolved from Open Banking and is characterised by the sharing of customer-permissioned data across a broader range of financial services providers, not just banks. This shift allows new entrants, like FinTechs and BigTechs, to develop innovative financial services. 

Open Finance promotes competition by breaking data silos and empowering consumers to share their financial data with third parties. When we look at different jurisdictions to implement open finance systems around the globe they are at various stages, different approaches and governance frameworks.

Different approaches and governance frameworks

  • Mandatory approach: EU, UK, Australia, Brazil, and UAE have adopted a mandatory framework where financial institutions are required to share customer data via APIs. This approach aims to enhance competition and innovation by facilitating secure data sharing between financial institutions and third-party service providers​
  • Collaborative approach: Singapore and Hong Kong are examples of jurisdictions using a collaborative approach, where financial institutions and regulators work together to establish standards and promote data sharing without legal mandates. The focus is on encouraging industry participation and developing API standards
  • Other approaches: China and India have broader data ecosystems being developed. These jurisdictions focus on the aggregation and sharing of data across different sectors, beyond just financial services, to promote innovation and competitiveness​

Open Finance governance faces significant challenges, including regulatory fragmentation, where multiple regulators involved in financial regulation, data protection, and competition policies may cause conflicts. Data localisation laws in certain jurisdictions restrict cross-border data transfers, potentially hindering the global efficiency of Open Finance systems. 

This paper aims to unlock the full economic potential of data and emphasises the importance of transitioning to Open Data with requirements to achieve such as harmonised regulations, data interoperability, and tackling challenges such as data sovereignty and localisation with the important highlights on digital identity and consent management systems as key infrastructure.

Building Open Finance: From Policy to Infrastructure - CFTE Policy Working Paper

About CFTE

Founded in 2017 in London, the Centre for Finance, Technology and Entrepreneurship (CFTE) is a global platform for education in FinTech and the future of financial services. More than 100,000 professionals from 100+ countries have participated in CFTE programmes to accelerate their careers in finance. CFTE’s objective is to equip professionals and students with the skills to thrive in the new world of digital finance. 

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