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+# The ecosystem imperative
+## Digital transformation of  financial services and moving  from Open Banking to Open Data
+
+
+-----
+
+# Contents
+
+#### Executive summary 3
+
+ Context and overview 5
+
+ Open Data ecosystem 8
+
+ Archetypes, main players, and responsibilities  11
+
+ Value 15
+
+ How might one measure success? 20
+
+ Success conditions and key capabilities 22
+
+ Potential implications for policymakers and market participants 28
+
+ Contacts 29
+
+ Endnotes 30
+
+
+-----
+
+# Executive summary
+
+The digital transformation of financial services is extending activities into broad ecosystems with new players and shifting
+roles. These ecosystems are co-evolving with dynamic value networks of diverse actors who create value through complex
+models of collaboration, competition, and innovation. Data policies have significant impacts on the roles, responsibilities,
+opportunities, and value chain position for different actors in these ecosystems.
+
+The impacts of these data policies evidence the importance of broadening the scope from Open Banking to Open Data not
+just Open Finance. This shift has the potential to realize many of the promises industry-specific data-sharing frameworks have
+fallen short of delivering to-date. This report from the Institute of International Finance (IIF) and Deloitte studies Open Data
+and shares thought-provoking insights on the following fronts:
+
+**• Roles and responsibilities: In an interactive Open Data ecosystem, roles are not fixed. Rather, they are dependent on the**
+specific flow of data for each operation. Key responsibilities are those focused on ensuring safe, transparent, and efficient
+data flow (e.g., secure authentication, model organization, data infrastructure, connectivity through application programming
+interfaces (APIs), etc.).
+
+**• Common objectives of an Open Data ecosystem: (i) Promoting innovation to increase consumer choice; (ii) creating**
+more secure methods of data sharing; (iii) improving consumer data privacy and portability; and (iv) fostering cross-sectoral
+collaboration and interoperability.
+
+**• Technological panorama and ecosystems: The emergence of Open Data is occurring alongside and interacting with**
+other critical forces—such as the increased adoption of cloud, AI, advanced analytics, and digital identity and it should be
+[evaluated in this context (see previous series, “Realizing the Digital Promise”[1]).](https://www.deloitte.com/global/en/Industries/financial-services/research/realizing-the-digital-promise-in-financial-services.html)
+
+**• Strategic role of consumer data: As sets of customer data become increasingly available, the edge they provide erodes**
+substantially. Therefore, differentiation generated by access to data may require players to curate, maintain, and analyze
+proprietary datasets (i.e., accessed via collaborations, through more intimate relationships with consumers, or via superior
+analytics).
+
+**• Value generated: Open Data carries opportunities and benefits for different stakeholders. For consumers, it can create**
+more choices and a better user experience, and in some markets it may also increase financial inclusion and literacy. For
+financial institutions (FIs) and other industries, Open Data can open the door to new business models, business lines and,
+consequently, to new partnerships. In the end, organizations that capture the value of new data flows will likely unlock new
+sources of income and more.
+
+
+-----
+
+**• Key factors for success in Open Data initiatives:**
+
+– Open Data ecosystems that deliver sufficient value to each type of participant and commensurate with the cost they
+incur to participate, are most likely to drive broad-based benefits.
+
+– Balanced and fair distribution of liability for what happens in the ecosystem (e.g., operational risks) amongst the
+stakeholders incentivizes participation.
+
+– The potential of Open Data can only be realized when data from different industries is shared. Deep cross-sectoral
+collaboration would likely ensure the free flow of data through interoperable channels that maximize the potential
+benefits and opportunities in the ecosystem. Thus, the availability of interoperable data and APIs that work crossindustry could help maximize value in the ecosystem.
+
+– To date, this cross-industry approach exists in earnest in a few countries. Most policies are limited to the sharing of either
+banking or financial data more broadly, still limited in focus to one-way provision of data out of the financial industry to
+other industries. A growing number of jurisdictions are beginning to propagate policies that could facilitate cross-industry
+sharing, though their voluntary nature could limit participation and calls into question consistency across sectors.
+
+– The existence of flexible and principles-based frameworks is a key factor for Open Data.
+
+– Achieving appropriate data quality (accuracy, completeness, reliability, relevance, and timeliness) cannot be disregarded.
+Additionally, how data is delivered can enhance the growth of Open Data ecosystems (e.g., with machine-readable
+formats).
+
+– Clear regulation can prevent unintended conflicts and barriers. Data localization requirements and legal fragmentation
+amongst different geographies can generate unintended consequences that hinder innovation or drive it into less
+productive pathways, create bigger constraints to data transfers or data mobility, and generate bigger costs and lost
+benefits for individuals and businesses.
+
+
+-----
+
+# Context and overview
+
+The digital transformation of financial services has extended activities into broad ecosystems, shifted traditional roles, and
+given rise to new players. As the historic lines between sectors and services continue to blur, new trends in platformization
+have emerged, with consumers seeking a diverse set of offerings from a limited number of actors. For example, embedded
+finance, the topic of Deloitte Global & IIF’s next report of this series—where the branded financial service provider sits behind
+the interface and transaction flow—is becoming the norm and a few major markets, such as China, have seen this manifest
+in a major way[2]. These dynamics are driving change in how different institutions come together, the roles they serve, and the
+relative positions they hold in pricing power and value extraction. The public and private sectors can benefit from a better
+understanding of the implications of these trends in the future of finance. Specifically, as evolutions in sectoral competitive
+dynamics, macroeconomic disruption, and the proliferation of emerging technologies are driving a renewed imperative to
+engage in ecosystem activities and assemble new capabilities/channels to interact better with consumers.
+
+IIF and Deloitte have joined together to explore the future of ecosystems on four fronts that are evidencing an uptick in
+development and maturity across the globe:
+
+**• Open Finance and Open Data**
+
+**• Embedded finance–customer relationships and value chain dynamics**
+
+**• Platformization–new models of financial service development and distribution**
+
+**• Policy-orchestrated ecosystems (e.g., digital banking licenses)**
+
+In this report, the first in a series Deloitte and IIF will publish throughout 2023, we focus on Open Finance and Open Data,
+and the importance of advancing the dialogue to achieve the latter rather than pausing mid-way at one-way information
+sharing out of the financial industry. This document builds on research from IIF, Deloitte, and insights from senior and C-suite
+executives. It explores how different data-sharing frameworks function as ecosystems with the potential to achieve goals for
+policymakers and market participants alike.
+
+The report is divided into seven sections. This first section frames the discussion and explains how data-sharing frameworks
+are intrinsically linked to ecosystems. It also shares a brief overview of Open Data as a concept and its background as well as
+how is it manifesting in today’s market. The second section outlines the Open Data ecosystem, its linkage to Open Banking,
+and Open Finance, and the centrality of consumers. Next, the document shares the drivers for strategic priorities in ecosystem
+engagement. This section ends with the benefits of Open Data. The third section lays out archetype models, the main players
+involved, and different roles and responsibilities. The fourth section is a study of the value that Open Data can create for
+consumers and FIs, the common objectives and impacts for participating institutions, and value capture by the various players
+involved. The fifth section outlines various metrics by which success metrics can be measured tangibly and quantitatively.
+The study concludes with a sixth section that provides analysis of the internal and external conditions for success and key
+capabilities of various players, and a final section that provides recommendations for policymakers and market participants.
+
+Throughout the report, three sidebars complement the analysis with background on: ecosystems; digital identity; and lessons
+from leading jurisdictions.
+
+
+-----
+
+##### What is Open Data?
+
+Open Banking, Open Finance and Open Data do not have legal definitions in most jurisdictions; however, the Organization
+for Economic Co-operation and Development (OECD) has recently described Open Data and Open Finance as extensions
+of their definition for Open Banking: Open Banking is “generally well understood as the practice of sharing banking data via
+standardized and secure interfaces at the request of clients”[3]; therefore, if Open Finance can be understood as the practice
+of sharing banking and other financial data (i.e., insurance, investment, etc.), then Open Data goes further to encompass
+non-financial information (i.e., social media, mobility, energy, utilities, etc.) at the request of clients through standardized and
+secure interfaces (see Figure 1). The Bank for International Settlements (BIS) has used the term Data-Sharing Initiatives instead
+of Open Data and has described them as combining data from diverse sources to help improve the “performance and value of
+services, enabling better decision making, delivering better products and empowering data ownership by citizens”.[4]
+
+Today, the average global internet user generates about 150GB of data per day through their browsing, interaction with
+different sectors, and transacting behavior.[5] Much of this data is captured and stored by the limited number of organizations
+the consumer interacts with directly (for the purposes of this report, we will call these organizations Data Custodians). Often,
+consumers don’t have access to this data or ‘digital footprint’ and have little control over how they may do so. Open Data seeks
+to make the most valuable of these datasets available to consumers, giving them the ability to control how those data are used
+and with whom they are shared.
+
+Open Data can be viewed as an ecosystem that brings together Data Custodians, who capture, process, and store consumer
+information on their behalf, with a broader scope of third-party users of those data—all in service of improving data portability
+and consumer outcomes including greater choice, better user experiences, and lower cost services.
+
+##### How is it manifesting–Background and emerging models
+
+In the context of financial services, moving toward an Open Data ecosystem began largely with a focus on retail banking data—
+providing consumers with the ability to share data about their banking transactions and other activity with third parties. This
+is commonly referred to as Open Banking and can be thought of as a sector-specific, siloed implementation of the objectives
+sought by Open Data, and one of the first implementations to gain widespread traction. The reasons behind the emergence of
+Open Banking and Open Data are numerous, including:
+
+**• Increased competitive activity in the data aggregation space for retail banking information, leading to a significant amount of**
+consumer banking data being accessed through unsecure methods (e.g., ‘screen-scraping’) and prompting a push to reduce
+system-wide risks;
+
+**• Growth in policy efforts aimed at increasing competition, particularly in the United Kingdom and Europe; and**
+
+**• The need to satisfy increased demands for a ‘consumer data right’ that improves data privacy and accessibility–with high-**
+value, high-impact use cases.
+
+As data aggregation methods become more sophisticated and Open Banking platforms have begun proliferating globally, we
+have increasingly witnessed a push to expand the scope of data sharing to a broader set of financial products and services
+(e.g., wealth management, insurance, and commercial banking)–a term known as Open Finance. For example, in the United
+States, large data aggregators have expanded their product set to include investment and liability (credit) data.[6,7] In the United
+Kingdom, the government’s Pension Dashboards Program will consolidate often-disparate pension data in one place for
+retirees.[8] In other jurisdictions such as South Korea, the upcoming MyData platform will also allow consumers to consolidate
+and share insurance data with third parties.[9]
+
+
+-----
+
+Simultaneously, other sectors of the economy are feeling similar pressures (competitive, consumer, and regulatory) to provide
+consumers with more ownership over their data. Many social media companies offer members an option to download a copy
+of their information (e.g., posts, messages, and uploaded media). In Australia, the Consumer Data Right, which was stood up by
+the federal government in 2019 as a means of providing Australians with the ability to share data with accredited third parties,
+began with a focus on banking data, but as of November 2022, also allows consumers to share data held by energy providers
+(e.g., electricity, and gas), and is steadily moving to cover additional sectors, such as telecommunications.[10]
+
+While Australia may be one of the clearest examples in the market thus far, the push to provide consumers with more
+portability and control over the information they generate when transacting with key service providers beyond the financial
+services industry is gaining momentum in other jurisdictions. One example is Colombia, where a new law included provisions
+that drive the public and private sectors to share consumers’ information at their request aiming for “greater competition and
+innovation for financial inclusion”.[11] To-date, however, a cross-industry approach exists in earnest in few countries. While a
+growing number of jurisdictions are beginning to propagate policies that would facilitate cross-industry sharing, their voluntary
+nature could limit participation and calls into question consistency across sectors.
+
+
+-----
+
+# Open Data ecosystem
+
+Data-sharing frameworks have been at the forefront of the interactions between FIs and authorities for years. In the words of
+one multilateral agency leader, these data-sharing frameworks are “an accelerator of doing partnerships in a different way.”
+
+Since the United Kingdom implemented Open Banking in 2018,[13] the world has seen a growing number of jurisdictions
+studying and implementing their own data-sharing frameworks with important nuances. Some jurisdictions (e.g., India,
+South Korea) have opted for market-driven approaches, while others (e.g., Hong Kong, Australia) have pushed mandatory
+frameworks, and a few have selected a voluntary approach with authorities playing a key role in promoting the active
+participation of players in the ecosystem. Compensation, reciprocity, data quality, and availability have been at the heart of
+discussions, especially in cases where opening access to information was mandatory and business cases didn’t—or haven’t—
+flourished naturally. Standardization and governance have also been points of discussion. The scope of the information
+subject to these frameworks has expanded in recent years, with players advancing efforts to implement true Open Data
+schemes, which will be important to unlock some of the promises unrealized by Open Banking.
+
+Figure 1. Landscape and state of play[12]
+
+
+**Components of**
+**data exchange**
+**layers**
+
+**APIs**
+
+**Data sharing**
+**infrastructure**
+
+**Technical standards**
+
+
+**Governance**
+
+**Accreditation**
+
+**Liabilities**
+
+**Oversight**
+
+**Privacy and consent**
+
+**Data protection**
+
+
+-----
+
+But what is driving the strategic imperative toward ecosystems in general, and Open Data in particular?
+
+Figure 2. What is driving the strategic imperative?[14]
+
+**Predicting the future is becoming more difficult**
+We continue to live in an increasingly VUCA world, which favors adaptive, adoptive and resilient firms, who will need
+capabilities to watch for signals, diversify the workforce, and pursue new strategic options
+
+**Traditional industry lines are blurring**
+As embedded finance, open data, and other flashpoints of industry convergence proliferate, they will re-distribute
+where financial services are delivered, so FIs will need to play both offense and defense on disruption.
+
+**Technology is now both table stakes and a differentiator**
+Technology continues to be the foundation for transformation across society, industry and people. If organizations
+are not building it, they will need to buy it or partner for it to assemble the right stack.
+
+##### Emerging hypotheses
+
+When looking at the key strategic decisions to be made by ecosystem participants, the following hypotheses are of particular
+interest:
+
+**• Ecosystems are built on symbiotic relationships and generate value in standard ways;**
+
+**• Data sharing is (and will continue to be) critical to ecosystems, but client consent and permission are priorities;**
+
+**• Interoperability will likely be key to increasing the value capture in ecosystems;**
+
+**• Broadening the set of data used by FIs and non-FIs could realize significant benefits for consumers, authorities, and the**
+private sector; and
+
+**• Cyber-security and operational resilience will likely play a key role in building trust in Open Data ecosystems.**
+
+##### Benefits of Open Data
+
+FIs—and primarily, the consumers they serve—can benefit substantially from a broadening of data-sharing frameworks.
+The products and services provided by FIs to retail consumers often serve as a means of facilitating some activity in the
+real economy, such as making everyday purchases (payments), financing a house (banking), securing an asset against loss
+(insurance), or saving for retirement (wealth management). FIs help consumers execute decisions that they make in the ‘real
+world’ by facilitating transactions, underwriting risks, transferring value across time, and extending credit.
+
+Today, FIs have a limited view into the underlying economic activity generated by these services, and the underlying needs,
+wants, and decision-making processes, of their consumers. What FIs know today often comes from inferences made on
+imperfect data (e.g., inferring spending patterns based on payments data), information picked up during hard-to-scale
+conversations (e.g., when a consumer meets a mortgage advisor), forms/documents that consumers are asked to fill when
+applying for a product/service, or one-off data-sharing cooperations with third parties (e.g., a mortgage lender working with an
+online home-buying portal).
+
+To quote an example, the Joint Regulatory Oversight Committee[15] (JROC) studied, along with 100+ industry actors, the state of
+Open Banking in the United Kingdom and what the path forward should look like. When addressing the current state of Open
+Banking, the JROC found that key objectives posed by the authorities when designing the Open Banking framework haven’t
+been fully achieved. Additionally, the committee stated that “the evidence received suggested there may be a number of gaps
+between the current and a more optimal future state of the Open Banking ecosystem.”[16]
+
+
+-----
+
+In particular, when addressing what was needed to achieve more competition–set up as one of the key objectives laid out by
+the United Kingdom and most of the authorities that have worked on Open Banking and Open Finance frameworks–, the JROC
+highlighted the importance of accessing new data sets; and concluded that limiting the data-sharing frameworks to banking
+data is one of the main barriers to achieving the objectives posed by authorities years ago. To bridge this gap, the JROC
+proposes to prioritize, among other elements, the integration of Open Banking and Open Finance with non-financial data.[17]
+The ability to leverage these ‘adjacent’ datasets (e.g., energy, real property, telecommunications, social media, etc.) through an
+Open Data framework could provide both traditional FIs and new entrants the capabilities to:
+
+**• Deliver more tailored advice to help consumers improve their financial decision-making (e.g., leveraging property and energy**
+data to help them trade off the all-in cost of home ownership against their cashflows);
+
+**• Automate routine transactions to save consumers time (e.g., automatically move money into a checking account to cover a**
+utility bill);
+
+**• Improve risk modeling to deliver better pricing to consumers (e.g., leveraging driving data to create better risk profiles–and**
+thus more precise pricing–for consumers looking for car insurance); or
+
+**• Better tailor products and offerings to customer preferences (e.g., using social media data to construct an investment**
+portfolio aligned with the consumer’s values).
+
+These are just some examples of how FIs can leverage Open Data to better serve consumers, which we will explore more in
+the Value section.
+
+
+##### What we know about ecosystems
+
+Ecosystems are dynamic and co-evolving value webs of diverse actors who can create value through increasingly
+productive and sophisticated models of collaboration, competition, and oversight. They tend to have the following key
+chaacteristics:
+
+**• they have a common purpose**
+
+**• they span traditional industry boundaries, and**
+
+**• they are made up of multiple firms that each have a different but integral role to play.**
+
+Ecosystems are not necessarily a new concept in the context of financial services. Indeed, many of the products and
+services offered by FIs today serve as a means to achieving some ultimate end in the real economy: buying a home,
+protecting a valuable asset, or building a new manufacturing facility. Therefore, FIs are not strangers to collaborating
+vertically and/or horizontally across sectors to create value for their clients. We have observed ecosystems take three
+common forms in the context of financial services:
+
+Figure 3. Three types of ecosystems[18]
+
+**Offering ecosystems** **Platform ecosystems** **Knowledge ecosystems**
+
+
+**Bring together multiple players of**
+**different types and sizes in order to**
+**create scale and serve markets in ways**
+**that are beyond the capacity of any**
+**single organization**
+
+
+**Enable connections between previously**
+**disconnected or inefficiently connected**
+**buyers and sellers, or other types of**
+**counterparties (e.g., content producers**
+**and consumers)**
+
+
+**Formed in order to leverage the**
+**combined resources, expertise, and**
+**talent for the express purpose of**
+**generating new knowledge which is then**
+**shared by all**
+
+**FIs have formed local and global**
+**industry groups (e g** **the IIF) to share**
+
+
+**Property & casualty insurers have long** **Large payments networks standardize**
+**orchestrated ecosystems of brokers and** **connectivity to enable the transfer of**
+
+
+**Examples of existing ecosystems[19]**
+
+**Property & casualty insurers have long** **Large payments networks standardize** **FIs have formed local and global**
+
+
+-----
+
+# Archetypes, main players, and responsibilities
+
+##### Roles and responsibilities
+
+The Open Data ecosystem is comprised of three main players:
+
+**Data Custodians**
+Generate, store, and augment data on behalf of consumers based on their underlying
+activity (e.g., transactions, hobbies, or internet usage). In an Open Data model, Data
+Custodians are responsible for providing an agreed-upon set of third parties (data users)
+with access to consumer data on the explicit direction and authorization of the consumer.
+
+**Data users:**
+Receive data from Data Custodians and use them to provide valueadded services to consumers.
+
+**Consumers:**
+Perform activities that generate data stored with a Data Custodian, and consent explicitly
+to their data, stored with a Data Custodian, to be sent to a third-party data user.
+
+In a balanced Open Data ecosystem, these roles are not fixed–an organization could be a Data Custodian for a specific set of
+consumer information, and a Data User for other information, dependent on the specific flow of data. For example, an insurer
+may be a Data Custodian in the case where a consumer consents to sharing policy data with a rental car agency, while the
+insurer might be a data user in the case where a consumer consents to sharing health data from their medical provider with
+the insurer.
+
+The volume of firms producing data and becoming custodians continues to grow dramatically as fintechs, data aggregators,
+and other new entrants join the landscape alongside BigTech. Increased consumer use of digital interfaces and cloud
+computing have enabled this growth. Cloud service providers have extended the capability to generate and hold data at scale
+to firms that would not have had the platform to truly act as Data Custodians.
+
+There are other responsibilities that are key to a well-functioning Open Data ecosystem, generally focused on ensuring
+safe, transparent, and efficient data flow. Across jurisdictions, these roles are played by various types of entities, including
+regulators, self-regulatory organizations/industry bodies, common utilities, private organizations, Data Custodians, Data
+users, etc.
+
+
+**Data Custodians**
+Generate, store, and augment data on behalf of consumers based on their underlying
+activity (e.g., transactions, hobbies, or internet usage). In an Open Data model, Data
+Custodians are responsible for providing an agreed-upon set of third parties (data users)
+with access to consumer data on the explicit direction and authorization of the consumer.
+
+**Data users:**
+Receive data from Data Custodians and use them to provide value-
+added services to consumers.
+
+**Consumers:**
+Perform activities that generate data stored with a Data Custodian, and consent explicitly
+to their data, stored with a Data Custodian, to be sent to a third-party data user.
+
+
+-----
+
+These responsibilities include:
+
+**•** **Secure authentication and consent gathering: Ensuring that consumers who direct Data Custodians to share their data**
+with data users are who they claim to be (to prevent fraud and identity theft) and have given explicit and informed consent
+around how their data will be used by the data user.[21]
+
+**• Accreditation model organization: Developing and enforcing a common framework for determining who qualifies as a**
+Data User and who qualifies as a Data Custodian. Accreditation could be policy-driven (e.g., a regulatory/self-regulatory/utility
+body sets standards for who can be a Data User/Custodian and manages a whitelist of accredited parties) or market-driven
+(where individual Data Custodians, or a third-party aggregator, manage the ecosystem of data users with whom data is
+shared).
+
+**• Participation model organization: Developing and maintaining the standards for participation, including technical**
+connectivity (e.g., APIs), liability and recourse models, and reciprocity. Similar to the accreditation model organization, this
+could be policy-driven (e.g., a regulatory/self-regulatory/utility body sets standards for participation) or market-driven (where
+individual Data Custodians, or third-party aggregators, set standards for participation). Also, participation standards are
+crucial to ensuring interoperability amongst players.
+
+**• Policy development and enforcement: Development and maintenance of regulations that support safe and secure data**
+sharing, including data privacy, consent, portability, and consumer protection policies.
+
+**• Data infrastructure provision: Development and maintenance of technical infrastructure to support the free and secure**
+flow of data, including token service providers, API gateways, centralized data exchanges, etc.
+
+
+-----
+
+# Digital identity
+### The role digital ID could play in ecosystems
+
+##### Digital identity is a key enabler for digital ecosystems.
+
+Trust is one of the key foundations of almost every interaction in the modern world. Whether these interactions occur
+between people, businesses, or governments, trust plays a key role in permitting the exchange of ideas, products, and
+services across various actors.
+
+In particular, ‘digital trust’ is increasingly required to enable interested parties to prove their identity or credentials
+securely and easily, to those with a need to know, while not over-sharing data. In previous decades–and even today in
+many jurisdictions–this trust is attained by the presentation of physical identity documents (i.e., state-issued IDs for
+people, registration documents for companies, etc.). But progressively, digital identity is being attained, using identifiers
+or digital tokens that link the identity of a person or a corporation to a set of reference data stored by agencies in the
+public or private sector.[64]
+
+As a result, trust and identity provide the gateway to different sectors, including financial services. As the OECD stated in
+its draft recommendations on the governance of digital identity: “access to essential services across the public and
+private sectors and trust between individuals, businesses, and governments rely on being able to prove one’s identity.”[65]
+
+With extensive AML and KYC procedures commonplace in financial services, and with suitability tests and credit risk
+applications based on data, FIs are now used to handle (digital) identity to guarantee the integrity of their operations,
+deliver better consumer experiences, and offer security for their consumers. As the OECD has recognized recently
+“identity underpins the entire financial system, and poor identity infrastructure opens the path for bad actors exposing
+consumers and businesses to important risks.”[66]
+
+As referenced in previous IIF-Deloitte research, “digital identity is a crucial enabler for integration into the digital
+economy and consumers’ lives, to the areas where consumers want banking to take place.”[67]
+
+##### What is digital ID? And why is it useful?
+
+As there are various definitions of what comprises digital ID, and to seek consistency in our analysis, it is important to
+recall some of the elements and characteristics laid out by the IIF and the BIS in previous papers around the concept of
+digital ID. Digital ID can be described as a “means of identification of a user, issued by an authoritative source such as a
+registry, which may be composed of a set of credentials, with or without a unique identifier”[68] that provides electronic
+verification of their identity[69] and which could refer to a physical person or a corporation.[70]
+
+Using digital IDs has a range of positive impacts for FIs, authorities, and consumers, including (1) better risk mitigation
+due to increased reliability of the information provided by the consumer; (2) decreased operational costs due to
+automation of KYC and AML processes; (3) improved market integrity; and (4) enhanced financial inclusion from both
+access and usage perspectives.
+
+Apart from these benefits, it is possible that requiring the use of digital ID could put burdens on consumers, given
+potential technological and security considerations, which could demote its use. As has been previously found by
+Deloitte Global, “organizations should balance the need to authenticate customer identities with the need to deliver a
+positive customer experience.”[71]
+
+
+-----
+
+##### Digital ID essentials.
+
+Digital ID is a clear building block required by the digital economy, but the governmental and institutional
+foundation still varies across countries and regions. Below are some examples of different models:
+
+**• Led by the state:**
+
+**[Estonia: Around 97%, or ~1.3 million of Estonians have a state-issued digital identity called eID which constitutes the](https://e-estonia.com/solutions/e-identity/id-card/)**
+cornerstone of e-state (which sits on the xroad); a platform that connects citizens with the public (vote online, file tax
+claims, etc.) and private sectors (pay bills, travel, request financial services, shop, etc.) through their ID-card or mobileID, or the Smart-ID app.
+
+**[India: Aadhaar was established by the state and currently has an adoption rate of over 99% of the Indian population.](https://uidai.gov.in/en/)**
+This biometric digital identity platform enables interaction with the public and private sectors. Key use cases include
+direct transfers of benefits to bank accounts, e-KYC, and digital document storage.
+
+**• Led by the private sector:**
+As we will show with some examples, FIs have played a key role in these models where the private sector has
+empowered consumers through Digital ID. This might be explained by the fact that due to the nature of sensitive
+financial data, investments in security and privacy have been substantial in the industry, which leaves FIs at the
+forefront of these innovations.[72]
+
+**Sweden:** [BankID was the digital ID solution launched in 2003 by FIs and it is now recognized by the government. Over](https://www.bankid.com/en)
+90% of people between 20-40 years in Sweden, and approximately 80% of the whole population now use this solution,
+which enables authentication and signature for use with public and private-sector institutions. In December 2022
+BankID announced its involvement in the first phase of the EU digital identity wallet.
+
+**[Canada: Verified.Me (recently renamed “Interac”) is a solution designed to allow consumers from leading FIs to verify](https://www.interac.ca/en/about/)**
+and securely identify themselves for accessing a range of interactions with the government, banks, investments, health
+providers and consumer retailers.
+
+**European Union: The EU is developing a new digital identity regulation eID that will entail a revision of the 2014 EU**
+Regulation on Digital Identity. The new eID will allow citizens to identify and authenticate themselves online using
+the “European digital identity wallet”, allowing users to have full control over their data, to store and use personal
+identification information and electronic certificates that can be used to access goods and public and private services
+(checking in at the airport, renting a car, opening a bank account, or logging in to their account on large online
+platforms). The regulation is expected to be in force approximately by the third or fourth quarter of 2024, and the way
+digital identity, payments, and a possible digital euro will interact is yet to be known.
+
+**[United Kingdom: The United Kingdom is currently working on its guidance on “enabling the use of digital identities,”](https://www.gov.uk/guidance/digital-identity#full-publication-update-history)**
+which includes standards and a governance structure to promote the private’s sector participation in offering digital ID
+[solutions. To move toward this objective, the government introduced the Data Protection and Digital Information (no. 2)](https://www.gov.uk/guidance/digital-identity#full-publication-update-history)
+[Bill in March 2023.](https://www.gov.uk/guidance/digital-identity#full-publication-update-history)
+
+
+-----
+
+# Value
+
+##### Common objectives of an Open Data ecosystem
+
+As we have explored already in this report, the global trend toward Open Data is a result of converging competitive, consumer,
+technological, and policy shifts. Across the many jurisdictions where these ecosystems have been established or are
+emerging, the relative importance of each of these shifts in ecosystem design and governance varies. Because of this, the
+‘intent’ behind the push toward Open Data varies from region to region. For example, Europe has taken a centralized, policyled approach. Data sharing in financial services is governed by the Payment Services Directive II (PSD2) legislation, which
+has been in force since 2016, with the stated aim of leveling the competitive playing field, improving systemic security and
+consumer protection, and driving better cross-continent integration. On the other hand, in the United States, the efforts of the
+Financial Data Exchange (FDX), an industry-led consortium to develop data-sharing standards, stem from the need to increase
+interoperability amongst Data Custodians, users, and aggregators in a fragmented, market-led model.[22]
+
+Despite these nuances, there are a few common objectives that Open Data regimes set out to achieve:
+
+**• Promoting innovation and competition to increase consumer choice: In some jurisdictions, the emergence of Open**
+Data has been accelerated by government inquiries into various sectors of the economy which allege stagnating product and
+service innovation and inadequate competitive activity. For example, in the United Kingdom, Open Banking was introduced
+because of a 2016 Competition & Markets Authority (CMA) investigation into retail banking which alleged that the sector was
+uncompetitive and that barriers to entry for new players were too high.[23] In Australia, the decision to extend the Consumer
+Data Right to the energy sector was driven in part by an inquiry into electricity affordability conducted by the country’s
+competition bureau, the ACCC.[24] In other jurisdictions, latent consumer demand for more innovative products and services
+has allowed new entrants that take advantage of data sharing to flourish. In the United States, for example, nearly 60% of all
+banking logins are made by third parties on behalf of the consumer[25], data aggregators like Plaid (200M+ consumers) have
+achieved unicorn status while others like Finicity have been acquired by major incumbents[26], and the fintech venture funding
+has raised rearlyUS$100 billion in 2021 and 2022.[27]
+
+**•** **Creating more standardized and secure methods of data sharing: Historically, data sharing between Data Custodians**
+and users was facilitated via so-called “screen-scraping” or “credential sharing” methods. Consumers would share their login
+details with an end data user or aggregator, who would log into the Data Custodian’s website or app on their behalf and
+collect data or transact in the name of the customer. However, “screen-scraping” has a number of challenges associated
+with it. Firstly, it’s insecure; requiring consumers to share sensitive information (e.g., passwords) with a third party, creating
+vectors for credential theft and fraud. Secondly, it’s inefficient; because the data is not accessed directly (and is simply
+‘scraped’ from a webpage), Data Users must keep a schema of where critical information is located on the webpage of every
+Data Custodian they access. Every time a webpage is updated, the Data User has to update the scheme. Finally, it’s resource
+intensive; using automation, data users can access a Data Custodian’s website many more times than a human can, which
+can overload servers and cause disruption. As a result, most Open Data regimes are implementing secure APIs standards
+to facilitate data sharing, creating direct data links between data users (often large aggregators) and Data Custodians, and
+building on the lessons learned from the Open Banking frameworks that have been in place for the last years. With APIs,
+data is accessed directly without the need for credential sharing, improving security. At the same time, standardized APIs
+make it easy for Data Users to access data in a uniform way, no matter which Custodian they are accessing them from. As a
+lead specialist of a multilateral organization puts it “the needle that has put this together (accelerated movement) is APIs. You
+should build your capacities around APIs, opening your own APIs and consuming others’ APIs.”
+
+
+-----
+
+**• Improving consumer data privacy and portability rights: The emergence of Open Data has driven**
+a substantial regulatory push to modernize data privacy and portability laws. Open Data ecosystems only function
+when consumers have control over their data and can easily direct them to trusted third parties of their choosing,
+and they trust that the information is only accessed by the specific parties, and for the specific use cases, they
+consent to. The hallmarks of modern data legislation, including Singapore’s Personal Data Protection Act (PDPA)
+and the California Privacy Rights Act (CPRA) include requirements for explicit and informed consent, an enshrined
+right to data portability (regardless of sector-specific implementations), strict rules around third-party data sharing,
+and data minimization principles (i.e., limiting the collection of data by data users to only those necessary to satisfy
+the use case(s) that consumers have consented to).
+
+**• Fostering cross-sectoral collaboration and interoperability: Open Data is also a powerful tool for combating**
+structural barriers to information sharing across sectors of the economy, and between public and private
+institutions. For example, Estonia’s national data exchange infrastructure, the X-Road, connects FIs, national and
+municipal governments, healthcare providers, educational institutions, individuals, and other entities via a single,
+standard data-sharing platform. On it, Estonians are able to seamlessly and securely
+share health records or educational credentials between parties in an automated manner. In total, the system
+processes 1.5billion transactions per year (in a nation of approx. 1.3 million) and is estimated to save nearly 1500
+years of working time, every year.[28]
+
+##### Strategic impacts of Open Data on the financial services sector
+
+While Open Data is an exciting source of opportunity and growth for financial services,[29] it is certainly playing a role
+in shifting some of the dominant competitive structures and operating models in the sector. While all players will
+play by these new ‘rules of the road,’ the impacts will be felt particularly by incumbent FIs, who will have to adapt
+quickly to the pace of change to realize the benefits of accessing new pools of information from different sectors to
+provide consumers with better and more efficient products.
+
+It’s important to note that the emergence of Open Data is not singlehandedly ‘responsible’ for these shifts–though
+it plays an important contributory role. Rather, it is occurring alongside and interacting with other critical forces
+such as the increased adoption of emerging technologies (e.g., cloud, AI, and advanced analytics), the rapid
+digitization of products and processes, financial infrastructure modularization, policy modernization, and sectoral
+convergence.
+
+One key shift is the role Open Data is playing alongside new ‘as-a-service’ infrastructure models (e.g., Banking
+as a Service–BaaS) in lowering the barriers to entry into financial services. With ‘as-a-service’ access to all the
+necessary ‘building blocks’ of a FI (e.g., operating license, balance sheet, product shelf) and the ability to tap
+into rich sources of consumers’ financial and non-financial data, new entrants are reducing the time to stand up
+compelling offerings from years to weeks. Among other things, this is intensifying competition for new consumers
+and commoditizing core product lines.
+
+A second shift concerns the strategic role of consumer data. Historically, these data have served as a highly
+defensible source of differentiation. For FIs, transactions, product holding, and other financial data gave a
+consumer’s primary FI advantage in making compelling offers, rewarding loyalty, and predicting moments of need
+for new products and services. Likewise, device, usage, and location data afforded telecommunications providers
+many of these same privileges. However, as these ‘basic’ sets of customer data become increasingly democratized,
+the usefulness of this moat erodes substantially. Therefore, differentiating through data will require players to
+curate, maintain, and analyze proprietary datasets–for example, accessed via exclusive partnerships with other
+service providers, through more intimate relationships with consumers, or via superior analytics.
+
+
+-----
+
+Finally, Open Data will likely help drive the reallocation of traditional sources of profitability. For example, ‘anchor’
+products (like a checking account) could become less lucrative as democratized access to data makes it easier
+for consumers to switch FIs and be multi-banked without much friction. Also, using extensive customer data to
+better automate money movement (e.g., from higher-yield to lower-yield products, and from checking to investing
+accounts) will likely make deposits less sticky, increasing the cost of funds. Finally, the commoditization of core
+product lines mentioned in the first shift is increasing returns to both scale and deep specialization simultaneously.
+
+##### Value generated by Open Data
+
+Open Data presents tremendous opportunities to unlock value for consumers, incumbent FIs and new entrants
+(collectively, financial services providers), regulators, and other service providers. It has the potential to significantly
+lower the barriers to conducting financial transactions, drive meaningful financial innovation, and improve
+the safety and security of the financial system. When discussing the value generated by open ecosystems, an
+executive and a thought leader of a major payments company stated that “having connections to everybody else
+vastly increases the value of whatever it is that you build.”
+
+##### Consumers can benefit from participation in an Open Data ecosystem in the following common ways:
+
+ Augmented product and service choices
+
+Open Data makes it easier for innovative new players to quickly develop and market new products and services,
+shaping consumer expectations and raising the competitive standard. At the same time, access to key financial
+and non-financial data allows FIs to better tailor products, advice, and recommendations to the specific needs of
+individual consumers. For example, a life insurer could use health and activity tracking data to help consumers
+save on premiums by rewarding healthy behaviors. At the same time, more standardized information sharing
+allows financial products and services to be embedded more seamlessly into non-traditional channels (e.g.,
+embedding a one-click mortgage refinancing in a home buying aggregator, such as Domain in Australia), and nonfinancial products to be embedded more seamlessly into financial channels (e.g., DBS Bank’s Home Marketplace,
+which allows the bank’s clients to set up consultations with trusted contractors and use an in-built calculator to
+retrieve their holdings with DBS to ascertain the housing loan they can afford, among other services.).[31] Ultimately,
+this allows consumers to access key services in the channel of their choice and puts financial products right in the
+flow of decision-making. Finally, the potential for automated money movement that focuses on achieving the best
+outcomes based on an understanding of a consumer’s entire financial picture (e.g., moving deposits around when
+higher-interest offers become available, optimizing short-term savings/long-term investment mix, etc.) can have
+positive impacts on their overall wealth.
+
+##### Better consumer experiences
+
+Giving consumers the ability to seamlessly and digitally share their information can reduce a significant amount
+of transaction friction, both within and outside of financial services. One-click information sharing with a lender,
+for instance, could save consumers’ time often spent filling out forms manually. In the world of Open Data,
+information such as employment status, income, and asset/liability holdings can be analyzed, verified, and
+pre-filled automatically. Or, for example, providing trusted income, identity, and proof-of-insurance data to a
+property manager can make it easier for tenants to access housing. While “new-to-bank” consumers will realize a
+significant portion of the benefits, FIs can also leverage Open Data to better serve their existing clients. FIs can use
+knowledge about consumer behaviors/preferences to better provide servicing and support. For example, data
+from telecom providers can help banks build a picture of when their consumer is active on different devices during
+the day, helping them optimize support delivery. At the same time, access to a consumer’s complete financial
+picture can help organizations better determine the potential lifetime value of a consumer, and tailor more
+personalized and precise advice.
+
+
+-----
+
+##### Increased financial inclusion and literacy
+
+As alluded to, greater access to information about a consumer would allow FIs to conduct more fine-grained risk
+analysis, using a wider array of information sources than previously available. Data–especially pertaining to identity
+and credit–has long been a barrier to inclusion: a report by the World Bank found that over 100 million people
+in sub-Saharan Africa who are unbanked also have no formal means of identification.[32] Leveraging financial and
+non-financial data to build a trusted and verifiable profile of an individual can help FIs serve more consumers
+while satisfying strict Know-Your-Customer (KYC) requirements. At the same time, it can increase rates of product
+ownership by using alternative sources of data to thicken credit files (e.g., using telecom bill payments) thereby
+increasing loan eligibility, or building more accurate risk profiles (e.g., using social media data to understand
+consumer activity), thereby potentially lowering premiums. When consumers get access to accounts and products,
+FIs can then use these channels as powerful tools to help consumers build healthy spending, saving, and
+protection habits, by providing helpful recommendations, access to articles/tools (e.g., retirement calculators), and
+rewarding sensible financial behavior.
+
+##### FIs can benefit from participation in Open Data ecosystems in the following common ways:
+
+ New business model development
+
+Cross-sectoral data access can help FIs develop entirely new business models to diversify revenue mix, access
+new consumer segments and channels, and differentiate themselves from competitors. As we explored
+previously, alongside other key developments such as the proliferation of “as a service” frameworks, Open Data
+gives FIs the tools to stand up these new business models much quicker than previously possible. For example,
+Commerzbank is leveraging internet of things (IoT) sensor data from the warehouses of its manufacturing clients
+to initiate payments and trigger automatic provision of financing as goods move through the supply chain.[33] In
+the investment space, custom indexing solutions could one day leverage Open Data to make tailored portfolio
+recommendations that balance a consumer’s risk tolerance, financial goals, and beliefs.
+
+##### Improved efficiency and cost reduction across the organization
+
+There are myriad ways that increased access to data can help FIs improve efficiencies and reduce costs across the
+organization. Firstly, it can help conduct more targeted and precise acquisition, reducing cost-per-acquisition in the
+sales funnel. For example, Deloitte’s Acquisition.AI solution, which leverages data from dozens of sources to drive
+more sophisticated segmentation and targeting, helped one large Canadian-bank increase the conversion rate of
+low-engagement clients to primary relationship clients by over 50%.[34] Secondly, it can help better match cost-toserve against consumer lifetime value. Better knowledge of a customer’s financial status and preferences can help
+FIs engage in right-sized interactions and help scale delivery. Thirdly, as alluded to above, instant access to a large
+pool of consumer financial and activity data can help lenders make quicker, straight-through credit adjudication
+decisions, by reducing the time spent manually collecting information. It could also one day drive predictive
+lending (e.g., a business lender could leverage store traffic and point-of-sale data to automatically pre-qualify a
+small retailer for working capital financing during periods of high customer demand). Finally, in combination with
+simultaneous advances in digital identity, building more robust profiles about consumers and their behaviors can
+help FIs root out identity and transaction fraud.
+
+
+-----
+
+##### Deeper relationship-building
+
+As data and product shelves commoditize, and as-a-service capabilities make it easier for anyone to access
+best-in-breed financial infrastructure, the return on investment (ROI) on building intimate, relevant, and frequent
+customer relationships grows substantially. Intelligent analysis of a consumer’s finances, lifestyle, goals, and
+activities builds a strong foundation for FIs to advise clients on more complex matters by delivering more timely,
+relevant, useful, and impactful interactions. This creates a flywheel effect–the better the relationship, the more
+consumers may be willing to opt-in to share additional, proprietary information that cannot be accessed through
+Open Data alone (e.g., nuanced details about their personal ambitions), and the better the advice and servicing,
+and thus the overall relationship, will become. In a sense, Open Data serves as a springboard to building deeper
+client relationships.
+
+##### Data service providers benefit from participation in an Open Data ecosystem in the following common way:
+
+ Building new infrastructure business models
+
+As we will explore in more detail in the following sections, interoperability is a critical necessary condition for a
+well-functioning Open Data ecosystem. Facilitating interoperability requires the development and maintenance of
+data-sharing infrastructure. There is an opportunity for individual FIs (e.g., payments networks), industry consortia,
+or data service providers to provide revenue-generating services on behalf of the market, to support the safe,
+secure, and efficient flow of data. Some of these business models could include the provision of:
+
+**• Data gateway, exchange, and intermediation services (e.g., the National Payments Corporation of India’s United**
+Payments Interface or UPI)
+
+**• User accreditation and tokenization services (e.g., Token.io in Europe)**
+
+**• Centralized utilities for fraud management and identity (e.g., Interac/SecureKey in Canada)**
+
+**• Authentication and consent management services (e.g., PingID globally and SoyYo in Colombia)**
+
+
+-----
+
+# How might one measure success?
+
+Open Data can drive quantifiable benefits across multiple levels of the economy. At the national or regional level
+(dependent on the breadth of the particular regime) unlocking data can drive economic growth and increase
+national and domestic competitiveness. At the institutional level, it can enhance revenue growth, cost savings, and
+consumer satisfaction scores. Finally, at the individual consumer level, it can help save time and increase wealth.
+
+##### National/Regional level
+
+Open Data can be a strong contributor to positive economic growth. A 2018 study by the European Centre for
+International Political Economy found that stricter data policy regimes, which restrict domestic and cross-border
+data flows, could have a significant negative impact on productivity and economic performance.[35] As well, a 2021
+study that Open Data ecosystems could boost economic growth by 1-5% by 2030, with developing nations having
+the highest growth potential.[36] But growth is not the only positive benefit from Open Data; it can also improve
+overall systemic competitiveness of institutions. This includes both improvements to the global competitiveness
+of domestic institutions (e.g., consider Klarna, a Swedish company, which has grown to over 34 million users in the
+United States since launching in 2018)[37] as well as increases to domestic sectoral competitiveness. On the latter
+point, a 2021 study by researchers from Columbia, Stanford, and the University of British Columbia found that
+the emergence of Open Banking policies leads to statistically significant increases in venture capital funding for
+fintechs, hinting that Open Data frameworks could exponentially exploit this trend. Finally, Open Data can help
+increase rates of financial inclusion and financial literacy within economies. In India, the introduction of the Aadhar
+digital identity scheme, which is linked to the broader Indian Open Data ecosystem, increased financial account
+ownership from 35% in 2011 to 80% in 2017.[38]
+
+##### Institutional level
+
+Organizations that capture the benefits of new data flows could unlock new sources of income. One obvious
+way to measure success is profitability–either through enhanced revenue growth, cost savings due to improved
+operational efficiency/employee productivity gains/reduced fraud, or a combination of the two. For example, Bud,
+a leading UK-based provider of data aggregation products, has helped lenders reduce default rates by 40-75%
+vs. market estimates.[39] But not all of the potential positive impacts are as immediately tangible as profitability.
+Leveraging Open Data can also help improve customer satisfaction by providing institutions with the tools to
+develop more relevant and personalized experiences. For example, Plaid (a US-based Open Data provider) is
+currently working with Flexport (a global logistics organization) to improve access to supply chain financing. Plaid
+reports that Flexport clients who connect via Plaid are able to access annual interest rates that are 0.4% lower than
+their peers and have credit limits that are 32% higher.[40]
+
+
+-----
+
+##### Consumer level
+
+Finally, at the consumer level, we can measure benefits in at least two ways:
+
+A. the improvement that new and upgraded financial services have on the overall consumer balance sheet (e.g., in
+the form of greater wealth); and
+
+B. in the time and effort saved when interacting with institutions.
+
+We are already seeing examples of access to Open Data improving consumer financial outcomes. For example,
+data aggregator MX worked with one of the largest banks in the United States to implement a predictive cash
+flow tool that helped the bank’s consumers increase their wealth by 4%.[41] On time savings, a report by DIACC,
+the Digital Identity & Authentication Council of Canada, found that the average consumer spends approximately
+eight hours per year creating or updating identity information and inputting data to prove who they are in order to
+transact, by automatically filling forms and providing additional attributes to help verify and validate a consumer’s
+eligibility to transact (e.g., providing income verification), Open Data can help significantly on these efforts.
+
+
+-----
+
+# Success conditions and key capabilities
+
+##### Ecosystem-level success conditions
+
+Data is a key element to creating more valuable and personalized proposals for consumers, but also, for society in general. For
+the data economy and ecosystems to flourish, some conditions need to be met. Many of them are external conditions that
+have the potential to either enable firms to create new services and products based on data or, on the contrary, can suppose
+an undesirable hindrance.
+
+In general, a well-functioning Open Data ecosystem facilitates secure and efficient data sharing at the behest of the consumer
+and ensures that the value created is distributed proportionately across players. Also, thoughtful regulation provides
+the necessary flexibility together with a fair and balanced approach. Creating incentives for all the parties within the data
+ecosystem is critical for the success of such ecosystems; liabilities should be clear, and the costs shared in a proportionate
+and fair manner; and, as data is the raw material that Open Finance and Open Data need to fuel services proposition and
+competitiveness, data quality is a necessary condition for the sharing of information to truly thrive; cybersecurity questions
+and other technical conditions such as those referring to standardization and interoperability also play an important role. The
+head of partnerships for a major European bank describes it as “when thinking about interoperability, standards are key, and
+they put everyone in a more competitive dynamic.”
+
+At the ecosystem level, we believe that seven factors are necessary for success:
+
+##### Fair and proportionate exchange of value
+
+It’s critical for the momentum and growth of Open Data ecosystems that they deliver sufficient value to each type of
+participant, and commensurate with the cost they incur to participate.
+
+Firstly, the products and services developed by data users should deliver sufficient value back to consumers. Obtaining
+the right to access a consumer’s data requires explicit and informed consent, so consumers need to believe that they are
+benefiting from sharing these data, or else traction will be limited. Benefits could be monetary-based (i.e., helping them save
+or earn money, for example by finding a tax-efficient means of consolidating retirement income), efficiency-based (i.e., helping
+them save time), or experience-based (i.e., improving the way they interact with a product or service).
+
+Secondly, there should be sufficient value available to Data Custodians. If participation in an Open Data ecosystem is merely a
+mandatory compliance exercise for Data Custodians, the ecosystem is likely to stagnate as these players are not incentivized
+to share more than what is required. Value can take a few forms. One way to coordinate value exchange is direct monetary
+compensation (either on a for-profit or cost-recovery basis) between the data user and Data Custodian. Another way to
+coordinate value exchange is to ensure reciprocity, which requires data users to also contribute relevant information back
+into the ecosystem. This can help ensure that there is not a one-way flow of information from traditional sources of consumer
+data (e.g., large FIs, telcos, ITs) to new entrants, and that Data Custodians can also share in access to consumer data that they
+don’t have from other players in the ecosystem, in order to enhance existing propositions or develop new ones for their own
+consumers.
+
+Thirdly, the data being shared in the ecosystem should be sufficient for data users to develop new commercial propositions. If
+the data is limited (e.g., limited scope, siloed approach, data that is already publicly available), there will likely be little incentive
+for data users to connect and develop innovative new products and services for consumers.
+
+
+-----
+
+##### Deep cross-sectoral collaboration to ensure the free flow of data
+
+Open Data goes beyond specific sectors, it can not only positively impact banking and finance, but also health, energy,
+pharma, mobility, infrastructure, natural resources, and many other sectors, which allows consumers to have more control
+over more sets of information.
+
+The potential of Open Data can be leveraged when merging data from different industries. Some approaches tend to be
+sector-specific, bringing together private entities, the public sector, and consumers to create common data spaces for certain
+industries. However, a sectorial focus on data-sharing frameworks leads to a partial and limited implementation and a partial
+and limited harnessing of its benefits, while a holistic approach to data would help develop more customer-centric solutions. In
+these efforts, avoiding asymmetries and contradictory regulation across sectors could play a key role in benefiting consumers
+and promoting interoperability.
+
+##### A flexible, principles-based framework
+
+When analyzing the different trends in Open Data, some jurisdictions that have opted for a regulatory-driven approach,
+such as the EU[42], United Kingdom, Australia[43], Hong Kong [44], and Brazil; others, like the United States, India, South Korea, and
+Japan have opted for a market-driven approach; and another group, with countries like Singapore, have chosen a scheme
+that is primarily market-driven, but where authorities play a key role in incentivizing participation and orchestrating different
+initiatives to promote the success of the ecosystem.
+
+Rigid legal frameworks may lead to some adoption challenges, especially early on in the development cycle. For instance, the
+pioneer UK Open Banking initiative has brought many positive aspects and learnings, though take up has been slower than
+anticipated.[45] In this sense, according to a 2022 report from the trustee of the Open Banking Implementation Entity (OBIE)[46],
+less than 3 out of each 20 digitally active UK adults use Open Banking-enabled services. And a similar outcome has been seen
+at the EU level. In the words of the head of partnerships at a leading European bank: “authorities should push the process (on
+opening information) but not to take the whole process in their hands.”
+
+In the same line, a 2023 report from the European Commission (EC), DG FISMA, on the application and impact of Payment
+Services Directive 2 (PSD2)[47] estimated certain benefits brought by this regulation–such as a reduction in fraud–thanks to
+improved customer protection measures of €0.9 billion in 2020 and increased market access to third-party payment services
+providers (TPPs) of €1.6 billion in 2020. While in regards to other benefits (i.e., more competitive prices for services, new
+products based on PSD2-enabled APIs, and increased market access to credit institutions) it concludes that it is still early
+to have an estimation. The report also included a valuation of costs, amongst which the development of APIs for the credit
+institutions included in the report[48] amounted to €2.2 billion, and the strong customer authentication (SCA) implementation
+costs for credit institutions, TPPs and merchants are estimated at €5 billion. The assessment published by the EC concluded
+that:
+
+1. while PSD2 has laid the foundations for Open Banking/Open Finance in the EU, many of the expected benefits and
+potential has not yet been realized due to issues relating to: (i) data access, (ii) data sharing, (iii) consent and data
+protection, (iv) and fragmentation of API standards; and
+
+2. “the overwhelming majority of banks and banking associations consulted for the study suggested that the costs of the
+PSD2 largely outweigh the benefits to them. National authorities and TPPs established before PSD2 was introduced were
+more positive about the general impact, but they tended to agree with the overall negative assessment.”
+
+More flexible frameworks can help the industry explore and put in place initiatives that are beneficial for all the players in the
+ecosystem. While prescriptive ones (seen in the United Kingdom and Mexico) may lead to situations in which the industries
+cannot adapt at the pace of technological developments and cannot learn from controlled trial and error exercises (when
+needed, as in all innovative processes).
+
+
+-----
+
+These frameworks could be based on design and functioning principles in which effectiveness could be measured considering
+different variables, like the reach and benefits to consumers or the increase in innovation and better solutions; the
+proportionality among the cost to be incurred by the different stakeholders and the benefits they receive from participating in
+this ecosystem, etc.
+
+##### Common, cross-sector standards to maximize interoperability
+
+In order to interconnect data in an Open Data ecosystem, it is important to have data standards[49] and API standards.[50] The
+standardization approaches can be multiple, ranging from those which are more prescriptive, to those more market-driven
+and flexible.
+
+Regardless of the path to be chosen, cross-industry standards maximize the potential benefits and competitiveness of
+businesses that participate in the ecosystem. Though the implementation of those standards can entail a relevant cost, its
+benefits surpass its potential drawbacks. In that sense, building over the already built infrastructures and standards can serve
+to simplify processes, reduce costs and implementation times, and drive better interconnectivity and outcomes. For example,
+the financial sector has been a pioneer in opening part of its data to third parties, therefore, existing infrastructures and
+standards can be leveraged by authorities and corporations in other sectors that might consider adhering to certain standards
+for creating effective cross-sector data flows.
+
+The definition and commercialization of specific solutions and services based on the availability of interoperable data and APIs
+would allow the market to offer new solutions and services, and for the customer to benefit from them.
+
+##### Balanced and fair distribution of liability
+
+The question of who is liable for the use of data, the connectivity, and for damages that might be caused carries important
+weight. Whether an Open Data ecosystem is being driven by regulatory activity (e.g., a centralized data exchange framework
+like Australia’s Consumer Data Right (CDR), which is written into government policy and overseen by regulators) or market
+activity (e.g., in the United States, where data sharing is largely done through competitive data aggregators like Plaid and MX), it
+needs proper risk controls and liability governance.[51]
+
+These issues can be addressed in different manners. For example, through private agreements and market dynamics, and in
+some cases through certain regulations. An ideal scenario would make each provider responsible for the services they render
+and the use they give to data and infrastructures.
+
+For consumers, Data Custodians, and data users alike, it should be very clear how risk and liability flow in concordance with
+the flow of data, and who is liable when things go wrong (e.g., data breaches, fraud, data sent to the wrong party). When a clear
+and well-understood set of rules is not in place, participants’ trust decays, affecting the outcomes sought by the ecosystem.
+
+##### Robustness and quality of data
+
+Data is the raw material that nurtures the whole system, thus, the better the quality of data, the better the results. There are
+various attributes that come with data quality, such as accuracy, completeness, reliability, relevance, and timeliness, all of
+which are necessary for a successful data-sharing ecosystem.
+
+A relevant point on this front is whether not only humans can understand the data, but also machines. By creating more data
+that is served in a machine-readable format, more automation could be embedded in the systems, as the machines would be
+able to communicate and analyze data themselves, initiating new steps in the value chain.
+
+
+-----
+
+##### Coherent regulation
+
+The quality, but also the quantity of data is relevant for data business models. The existence of networks that capture data in
+an agile and automatic fashion (e.g., IoT), is crucial in order to scale the Open Data ecosystem.
+
+Some relevant questions regarding privacy should be taken into account (e.g., anonymity and pseudonymization of data).
+However, there are still many different regulatory approaches in regards to data privacy, and this fragmentation can make it
+more complex to implement cross-border and sometimes cross-sectoral solutions that serve clients and companies.
+
+When possible, the options to implement Open Data should be technologically neutral to adapt to the different solutions
+needed by consumers. Also, data sovereignty and data localization requirements, together with legal fragmentation amongst
+different geographies, can generate unintended consequences in terms of innovation, bigger constraints to data transfers or
+data mobility, as well as bigger costs.
+
+##### Organization-level required capabilities
+
+For both Data Custodians and data users, winners will likely share a common set of operational, technical, and strategic
+capabilities, including:
+
+##### Technology
+
+**• Modern and modular data architecture (e.g., based on APIs) to facilitate easy internal retrieval, sharing, and ingestion of data**
+from multiple sources.
+
+**• Advanced data processing and analytics capabilities to translate data received via the ecosystem into actionable insights,**
+either on its own or by linking it to existing data.
+
+##### Governance and risk management
+
+**• A sophisticated partnership management function responsible for creating trusted relationships with third parties by**
+aligning interests, flexibly managing SLAs, efficiently and fairly managing conflicts, and adhering to ecosystem rules and
+norms.
+
+**• Robust third-party risk management and cybersecurity protocols, in order to understand, monitor, and safeguard against**
+threats (e.g., API security).
+
+##### Organizational and process design
+
+**• An agile, customer-focused culture that allows the organization to react to new types of data being shared in the ecosystem,**
+and quickly incorporate them into product and service development.
+
+**• Flexible teaming mechanisms that cut across traditional product and service siloes; with access to data from various**
+sectors, a FI might be able to develop entirely new offerings that don’t fit into their traditional lines of business (e.g., a bank
+using open real estate data to offer a home-comparison service)–this requires a new approach to teaming that focuses on
+achieving key customer outcomes.
+
+##### Strategy
+
+**• A strong base of proprietary data generated via frequent and meaningful customer interactions and/or exclusive**
+collaborations
+
+– Given that Open Data serves to level the playing field across participants in terms of access to secure consumer data, a
+significant source of strategic differentiation will come from being able to keep the mindshare of consumers and generate
+proprietary data with particular insights.
+
+**• Permission to provide clients with insights and advice that goes beyond the organization’s traditional scope of services in a**
+way that will not be perceived as ‘overstepping boundaries’ by the customer.
+
+
+-----
+
+##### Lessons from leading jurisdictions
+
+The various points identified above are derived from research on jurisdictions that are leading discussions on
+data-sharing frameworks, some of which are listed below:
+
+**•** **Singapore, SGfindex[52]: The Singapore Financial Data Exchange (SGFinDex) was launched in 2020.[53] The Monetary**
+Authority of Singapore (MAS) and the Smart Nation and Digital Government Group (SNDGG) conceived the Open
+Finance initiative to empower consumers so that they can use their financial data smarter. This initiative was executed
+in four different phases covering different financial services and products, such as money management, investment,
+retirement, and protection (insurance). It is built on Singpass Singapore’s national digital identity, and it has been
+developed through public and private collaboration, including the Association of Banks in Singapore, as well as various
+major entities. The system has been designed to embed privacy and consent requirements.
+
+**• Hong Kong, Commercial Data Interchange: The Hong Kong Monetary Authority (HKMA) launched a financial data**
+structure known as Commercial Data Interchange in 2022[54] after a pilot that started in 2021. Twenty three banks
+with relevant SMEs business and ten data providers have joined the initiative upon its commencement. The project is
+based on consumers’ consent and API standardization and is built over a blockchain architecture to ensure data and
+consent traceability. All the participants in the ecosystem are identifiable. HKMA intends to explore new business use
+cases based on data by broadening the scope of the project and the type of data it comprises. It is still too soon to
+evaluate the success of this initiative, which is ambitious in its scope and has the potential to cover much more than
+Open Finance if it develops as expected. Though, as per the success cases so far, among others, the platform seems to
+simplify the complexity that many SMEs face in order to finance their operations.
+
+**• Data Act and Financial Data Access proposals, European Union: After the relevant experience gained with the**
+regulation on Open Banking (Payments Services Directive 2[55] or PSD2[56], now also under revision) the EU is currently
+working on the Data Act[57] initiative as well as in an open finance initiative (called Financial Data Access). It will allow
+users of connected devices to gain access to data generated by them and to share such data with third parties. The
+draft proposal includes compensation[58] mechanisms and other incentives for the manufacturers and those making
+data accessible.
+
+The Financial Data Access proposal foresees that data sharing will be done with the user’s consent, and that data
+holders (e.g., FIs) are entitled to reasonable compensation for sharing data, and such compensation shall be defined by
+the governance schemes to be put in place. The proposal’s scope covers credit, loans, savings, investments, cryptos,
+real estate, pensions, insurance (e.g., non-life) information, as well as certain data from creditworthiness assessments,
+and it affects not only banks, but also other institutions such as insurance companies, payment institutions, asset
+managers, etc.
+
+It foresees switching rights for the consumers, so they can switch between different cloud data-processing service
+providers. The Act also includes provisions for the public sector to access and use data held by the private sector in case
+of exceptional circumstances such as public emergencies (e.g., floods and wildfires); The act reflects a shift from Open
+Banking to Open Data, as it promotes the creation and functioning of interoperability standards for data to be used
+across different sectors.
+
+
+The Financial Data Access proposal foresees that data sharing will be done with the user’s consent, and that data
+holders (e.g., FIs) are entitled to reasonable compensation for sharing data, and such compensation shall be defined by
+the governance schemes to be put in place. The proposal’s scope covers credit, loans, savings, investments, cryptos,
+real estate, pensions, insurance (e.g., non-life) information, as well as certain data from creditworthiness assessments,
+and it affects not only banks, but also other institutions such as insurance companies, payment institutions, asset
+
+It foresees switching rights for the consumers, so they can switch between different cloud data-processing service
+providers. The Act also includes provisions for the public sector to access and use data held by the private sector in case
+of exceptional circumstances such as public emergencies (e.g., floods and wildfires); The act reflects a shift from Open
+Banking to Open Data, as it promotes the creation and functioning of interoperability standards for data to be used
+across different sectors.
+
+**• Australia, Consumer Data Right: In Australia, the Consumer Data Right (CDR)[59] empowers consumers to access and**
+share their data among accredited third parties. The CDR is operated by providers that have been previously accredited
+by the Australian Competition and Consumer Commission and it is overseen by the Australian government. Its
+approach is regulation based and it currently covers the financial and energy sectors, and it will foreseeably expand to a
+new different sector each year, the next one in the pipeline is the telecommunications sector.
+
+
+-----
+
+The Australian CDR allows consumers to easily compare services and products from different providers and to switch
+amongst them. This solution is also based on consumers’ consent, and it allows them to manage their consent in an
+easy way through a dashboard. Their consent can be provided for a specific time frame, with certain limits. It is also
+based on APIs and the data format has been set up by the Australian Data Standards Body.[60] User’s identity is verified
+by a third provider using a One Time Password (OTP). The CDR is undergoing revision, and the new legal text may
+include new possibilities like payment initiation on behalf of consumers (similar to what is already in place in the United
+Kingdom and the EU) as well as the inclusion under the umbrella of Open Banking of other services such as non-bank
+lending, general insurance, superannuation, and merchant acquiring.
+
+**•** **United Kingdom, from Open Banking to Smart Data (Open Data): After becoming the first jurisdiction to implement**
+Open Banking frameworks, a recent report by the Joint Regulatory Oversight Committee[61] identified some gaps and
+bridges in the implementation of those frameworks; among the gaps identified are:
+
+1. insufficient ecosystem reliability-especially regarding APIs availability and performance;
+
+2. appropriate protections from fraudulent practices; and
+
+3. the narrow scope of the regulation. On the other hand, some of the bridges and priorities identified were: (A)
+detailed evidence collection to appropriately measure the ecosystem reliability; (B) use of data sharing to prevent
+fraud and exclusion; and (C) integration with Open Finance, smart data frameworks, and alignment with digital
+identity infrastructure.
+
+**• The UK government also introduced (March 2023) a new bill on Data Protection and Digital Information. The bill is**
+expected to (1) reduce burdens on businesses and researchers, and (2) boost the economy by £4.7 billion over the next
+decade. It also addresses cross-sectoral data sharing (known as Open Data, or Smart Data in the United Kingdom), and
+includes a chapter on digital identity verification services, which would enable public authorities to disclose information
+to registered organizations ‘providing trust-marked services for the purposes of identity or eligibility verification’.[62]
+
+**• Brazil, Open Finance: Brazil launched its Open Finance initiative in 2021[63] with the aim to allow the exchange of data**
+in the financial sector and increase competitiveness and new business models. Joining the Open Finance initiative is
+mandatory for banks, payments institutions, and other authorized entities under the supervision of the Central Bank
+of Brazil (BACEN) that represent a more relevant portion of the total assets or those with significant international
+activity, and voluntary for the rest of the entities. Privacy and client consent requirements have been embedded in the
+design and digital channel experience. Its scope is wider than a mere Open Banking initiative, it’s named Open Finance
+as it covers many kinds of financial data and products (e.g., domestic information, credit limits, banking transactions,
+pension funds, investment funds, insurance, etc.), and thus open insurance and open investment are embedded under
+the same umbrella. The Open Finance initiative is still evolving in country and under development as it encompasses
+different implementation phases.
+
+
+mandatory for banks, payments institutions, and other authorized entities under the supervision of the Central Bank
+of Brazil (BACEN) that represent a more relevant portion of the total assets or those with significant international
+activity, and voluntary for the rest of the entities. Privacy and client consent requirements have been embedded in the
+design and digital channel experience. Its scope is wider than a mere Open Banking initiative, it’s named Open Finance
+as it covers many kinds of financial data and products (e.g., domestic information, credit limits, banking transactions,
+pension funds, investment funds, insurance, etc.), and thus open insurance and open investment are embedded under
+the same umbrella. The Open Finance initiative is still evolving in country and under development as it encompasses
+different implementation phases.
+
+**•** **United States, Financial Data Exchange (FDE): The United States has had a predominantly market-driven approach to**
+Open Banking and Open Finance. This environment has allowed for consumer-led services and private initiatives such
+as Financial Data Exchange (FDX) to grow. FDX is a consortium that provides an open standard for exchanging financial
+data and performing financial transactions between FIs and applications and operates in the United States and Canada.
+Its members include FIs, data aggregators, fintechs, amongst others.
+
+
+-----
+
+# Potential implications for policymakers and market participants
+
+The public sector is an active ecosystem player in many jurisdictions (e.g., EU, United Kingdom, Australia, Singapore, and Hong
+Kong, amongst others). Policy decisions are shaping the data market, not only in finance but also in other industries. In this
+sense, and in order to ensure a competitive, fair and balanced market, the following is apparent:
+
+**• There is widespread support for an expansion of Open Banking beyond Open Finance and on to Open Data,**
+**effectively ‘broadening the scope’ of accessible data. The benefits promised by Open Banking haven’t been realized**
+for various reasons, not least of which is the restriction of one-way data sharing out of retail banking. The goals of improving
+competition, empowering consumers, and offering tailored products will struggle to be realized when limited only to financial
+products and financial data; rather, they require all aspects of a customer’s life, such as information related to utilities,
+mobility, taxes, digital identity, health, social media, travel, commerce retailers, etc. A unidirectional lop-sided approach to
+data sharing will not achieve the objectives put forward by policymakers.
+
+**•** **Regulatory fragmentation can lead to fewer benefits, as well as hindrances for the global innovations that**
+**are yet to come. Fragmentation can occur among jurisdictions, but it can also be inter-sectoral. A holistic cross-industry**
+approach to data-sharing frameworks is better suited than a single-sector approach to achieve policymakers’ objectives.
+Fragmentation appears in the form of differing obligations, governance rules, and standards such as sectorial voluntary
+participation in data-sharing frameworks.
+
+**• Principles-based frameworks with sufficient incentives benefit market adoption and consumer empowerment.**
+Principles-based rules provide the flexibility needed to develop workable business models and partnerships in dynamic
+ecosystems like Open Finance and Open Data. This can help to avoid unnecessary burdens on participants and facilitates
+the proliferation of private initiatives.
+
+**• An appropriate distribution of costs and benefits would incentivize all parties to participate, creating a**
+**better and more dynamic ecosystem going forward. Compensation structures and reciprocity have proven to be**
+key components in Open Banking and Open Finance frameworks as they promote data quality and availability, which
+subsequently enriches the exchange among participants of the ecosystem. These considerations are equally applicable to
+Open Data, where other sectors would also benefit from them.
+
+**• Fair and balanced liability frameworks that set clear rules to identify liabilities and settle disputes with**
+**certainty can help the data economy to grow. Legal certainty together with the existence of quick, trusted, and dynamic**
+dispute settlement systems, are growth drivers to be considered.
+
+**• Data quality (accuracy, completeness, reliability, relevance, and timeliness) is essential. Among the questions**
+that can be considered to improve data quality, we find data quality assessments, as well as the use of machine-readable
+formats to improve automatization and help eliminate manual tasks and thus, reduce operational risk. Data standardization
+facilitates data sharing and interoperability.
+
+**• Existing Open Banking and Open Finance frameworks should be considered when building Open Data**
+**standards, governance, responsibilities, and infrastructure. The financial industry has learned valuable lessons from**
+Open Banking and Open Finance efforts to-date. Developing entirely new rules for data sharing without consideration for
+those that already exist would likely incur costs for market participants, regulators, and supervisors of these ecosystems,
+while wasting relevant knowledge learned from experience.
+
+
+-----
+
+# Contacts
+
+**Neal Baumann**
+**Global Financial Services Industry Leader**
+Deloitte Global
+[nealbaumann@deloitte.com](mailto:nealbaumann%40deloitte.com?subject=)
+
+**Michael Tang**
+**Partner,**
+Deloitte Canada
+[mtang@deloitte.ca](mailto:mtang%40deloitte.ca?subject=)
+
+**Luca De Blasis**
+**Manager,**
+Deloitte Canada
+[ldeblasis@deloitte.ca](mailto:ldeblasis%40deloitte.ca?subject=)
+
+**Peiching Teo**
+**Senior Consultant**
+FSI Strategy, Deloitte Canada
+[pteo@deloitte.ca](mailto:pteo%40deloitte.ca?subject=)
+
+
+**Jessica Renier**
+**Managing Director,**
+Digital Finance, IIF
+[jrenier@iif.com](mailto:jrenier%40iif.com?subject=)
+
+**Conan French**
+**Director,**
+Digital Finance, IIF
+[cfrench@iif.com](mailto:cfrench%40iif.com?subject=)
+
+**Gloria Sánchez Soriano**
+**Sr. Advisor,**
+Digital Finance, IIF
+[gsanchezsoriano@iif.com](mailto:gsanchezsoriano%40iif.com?subject=)
+
+**Daniel Mendez Delgado**
+**Assc. Policy Advisor,**
+Digital Finance, IIF
+[dmendezdelgado@iif.com](mailto:dmendezdelgado%40iif.com?subject=)
+
+
+The Institute of International Finance (IIF) is the global association of the financial industry, with about 400 members
+from more than 60 countries. The IIF provides its members with innovative research, unparalleled global advocacy,
+and access to leading industry events that leverage its influential network. Its mission is to support the financial
+industry in the prudent management of risks; to develop sound industry practices; and to advocate for regulatory,
+financial and economic policies that are in the broad interests of its members and foster global financial stability and
+sustainable economic growth.
+
+
+-----
+
+# Endnotes
+
+1. Realizing the Digital Promise series encompasses several reports
+that are built on research and the insights the IIF and Deloitte
+have received from more than 200 senior and C-suite executives,
+transformation leaders, thought leaders, investors, regulators and
+government officials that have been interviewed over the past 3
+[years. The full list of reports of this series is available on Deloitte.](https://www.deloitte.com/global/en/Industries/financial-services/research/realizing-the-digital-promise-in-financial-services.html)
+[com.](https://www.deloitte.com/global/en/Industries/financial-services/research/realizing-the-digital-promise-in-financial-services.html)
+
+2. [“Embedded finance: Connecting the dots.” IDG Connect. May 24,](https://www.idgconnect.com/article/3661555/embedded-finance-connecting-the-dots.html)
+2022.
+
+3. [“Shifting from Open Banking to Open Finance: Results from the](https://www.oecd-ilibrary.org/finance-and-investment/shifting-from-open-banking-to-open-finance_9f881c0c-en)
+[2022 OECD survey on data sharing frameworks.” Organization for](https://www.oecd-ilibrary.org/finance-and-investment/shifting-from-open-banking-to-open-finance_9f881c0c-en)
+Economic Co-operation and Development (OECD). January 2023.
+
+4. [API standards for data-sharing (account aggregator). Bank for](https://www.bis.org/publ/othp56.pdf)
+International Settlements (BIS) - Consultative Group on Innovation
+and the Digital Economy. October 2022.
+
+5. [“53 Important Statistics About How Much Data Is Created Every Day.”](https://financesonline.com/how-much-data-is-created-every-day/#:~:text=The%20answer%20would%20be%20146%2C880,devices%20connected%20to%20the%20Internet)
+Finance Online – Reviews for business. March 2023.
+
+6. [https://plaid.com/use-cases/lending/](https://plaid.com/use-cases/lending)
+
+7. [https://plaid.com/use-cases/wealth/](https://plaid.com/use-cases/wealth/)
+
+8. [https://www.pensionsdashboardsprogramme.org.uk/](https://www.pensionsdashboardsprogramme.org.uk/)
+
+9. [https://www.mastercardservices.com/en/reports-insights/my-data-](https://www.mastercardservices.com/en/reports-insights/my-data-my-payment-open-banking-south-korea)
+[my-payment-open-banking-south-korea](https://www.mastercardservices.com/en/reports-insights/my-data-my-payment-open-banking-south-korea)
+
+10. [https://www.cdr.gov.au/rollout](https://www.cdr.gov.au/rollout)
+
+[11. “POR EL CUAL SE EXPIDE EL PLAN NACIONAL DE DESARROLLO](https://colaboracion.dnp.gov.co/CDT/portalDNP/PND-2023/2023-05-05-texto-conciliado-PND.pdf)
+[2022- 2026 “COLOMBIA POTENCIA MUNDIAL DE LA VIDA”. National](https://colaboracion.dnp.gov.co/CDT/portalDNP/PND-2023/2023-05-05-texto-conciliado-PND.pdf)
+Development Plan 2022-2026. Available at:
+
+12. IIF & Deloitte
+
+13. [https://www.openbanking.org.uk/news/uks-open-banking-launch-](https://www.openbanking.org.uk/news/uks-open-banking-launch-13-january-2018/ )
+[13-january-2018/](https://www.openbanking.org.uk/news/uks-open-banking-launch-13-january-2018/ )
+
+14. [Interim report: The ecosystems imperative. Realizing the Digital](https://www.iif.com/Publications/ID/5177/Interim-report---The-ecosystems-imperative)
+Promise Series. IIF & Deloitte. December 2022.
+
+15. Group created by the HM Treasury, the Competition and Markets
+Authority, the Financial Conduct Authority, and the Payment System
+Regulator.
+
+[16. “Future Development of Open Banking in the UK.” Joint Regulatory](https://www.openbanking.org.uk/wp-content/uploads/SWG-Report-The-Future-Development-of-Open-Banking-in-the-UK-Feb-2023.pdf)
+Oversight committee. February 2023.
+
+[17. “New Smart Data Council to drive forward savings for household](https://www.gov.uk/government/news/new-smart-data-council-to-drive-forward-savings-for-household-bills#:~:text=Smart%20Data%20involves%20the%20secure,supporting%20families%20to%20save%20money.)
+[bills.” UK government. 17 April 2023.](https://www.gov.uk/government/news/new-smart-data-council-to-drive-forward-savings-for-household-bills#:~:text=Smart%20Data%20involves%20the%20secure,supporting%20families%20to%20save%20money.)
+
+18. [Interim report: The ecosystems imperative. Realizing the Digital](https://www.iif.com/Publications/ID/5177/Interim-report---The-ecosystems-imperative)
+Promise Series. IIF & Deloitte. December 2022.
+
+19. [Interim report: The ecosystems imperative. Realizing the Digital](https://www.iif.com/Publications/ID/5177/Interim-report---The-ecosystems-imperative)
+Promise Series. IIF & Deloitte. December 2022.
+
+
+20. [Interim report: The ecosystems imperative. Realizing the Digital](https://www.iif.com/Publications/ID/5177/Interim-report---The-ecosystems-imperative)
+Promise Series. IIF & Deloitte. December 2022.
+
+21. See Digital Identity box on page 13 for additional considerations.
+
+22. More regulatory detail on these and other leading examples are
+shared in another section of this report.
+
+23. [Open Banking Implementation Entity (OBIE). The origins of Open](https://www.openbanking.org.uk/about-us/)
+Banking. Completion of the roadmap.
+
+[24. “Restoring electricity affordability and Australia’s competitive](https://www.accc.gov.au/system/files/Retail Electricity Pricing Inquiry%E2%80%94Final Report June 2018_0.pdf)
+[advantage: Retail electricity Pricing Inquiry – Final Report. Australian](https://www.accc.gov.au/system/files/Retail Electricity Pricing Inquiry%E2%80%94Final Report June 2018_0.pdf)
+[Competition & Consumer Commission.” 2018.](https://www.accc.gov.au/system/files/Retail Electricity Pricing Inquiry%E2%80%94Final Report June 2018_0.pdf)
+
+25. Deloitte Canada analysis
+
+[26. “Disruptor 50 – 2022.” #47. Plaid. CNBC. May 2022.](https://www.cnbc.com/2022/05/17/plaid-disruptor-50.html)
+
+[27. “Fintech in 2022: A story of falling funding, fewer unicorns and](https://techcrunch.com/2023/01/19/fintech-in-2022-a-story-of-falling-funding-fewer-unicorns-and-insurtech-ma/)
+[insurtech M&A.” Mary Ann Azevedo, TechCrunch. January 2023.](https://techcrunch.com/2023/01/19/fintech-in-2022-a-story-of-falling-funding-fewer-unicorns-and-insurtech-ma/)
+
+28. [E-Estonia. Interoperability services. X-Road. 2023.](https://e-estonia.com/solutions/interoperability-services/x-road/)
+
+[29. “Report on Open Finance.” Expert Group on European financial data](https://finance.ec.europa.eu/system/files/2022-10/2022-10-24-report-on-open-finance_en.pdf)
+space. 2022.
+
+30. [Domain.](https://www.domain.com.au/)
+
+31. [DBS Marketplace](https://www.dbs.com.sg/personal/marketplaces/listings/homeliving-renovation)
+
+[32. “Global Findex Database 2021: Financial Inclusion, Digital Payments,](https://www.worldbank.org/en/publication/globalfindex)
+[and Resilience in the Age of COVID-19. “Washington, DC: World Bank.](https://www.worldbank.org/en/publication/globalfindex)
+Demirgüç-Kunt, Asli, Leora Klapper, Dorothe Singer, and Saniya
+Ansar. 2022.
+
+[33. “Commerzbank and T-systems to deliver automated supply-chain](https://www.commerzbank.com/en/hauptnavigation/presse/pressemitteilungen/archiv1/2023/quartal_23_01/presse_archiv_detail_23_01_106122.html)
+[financial services.” Commerzbank. February 2023.](https://www.commerzbank.com/en/hauptnavigation/presse/pressemitteilungen/archiv1/2023/quartal_23_01/presse_archiv_detail_23_01_106122.html)
+
+34. Deloitte proprietary analysis based on AcquisitionAI tools
+
+[35. “Do data policy restrictions impact productivity performance of firms](https://ecipe.org/wp-content/uploads/2018/10/Do-Data-Policy-Restrictions-Impact-the-Productivity-Performance-of-Firms-and-Industries-final.pdf)
+[and industries?” European Centre for International Political economy](https://ecipe.org/wp-content/uploads/2018/10/Do-Data-Policy-Restrictions-Impact-the-Productivity-Performance-of-Firms-and-Industries-final.pdf)
+(ECIPE) and Digital Trade Estimates.
+
+[36. “Klarna wins over the US.” Mary Ann Azevedo, TechCrunch. February](https://techcrunch.com/2023/02/22/fintech-klarna-ceo-on-u-s-growth-momentum/)
+2023.
+
+[37. “Financial data unbound: The value of open data for individuals and](https://www.mckinsey.com/industries/financial-services/our-insights/financial-data-unbound-the-value-of-open-data-for-individuals-and-institutions)
+[institutions – Discussion paper. “ McKinsey Global Institute. June](https://www.mckinsey.com/industries/financial-services/our-insights/financial-data-unbound-the-value-of-open-data-for-individuals-and-institutions)
+2023.
+
+[38. “Global Findex Database 2021: Financial Inclusion, Digital Payments,](https://www.worldbank.org/en/publication/globalfindex)
+[and Resilience in the Age of COVID-19. “Washington, DC: World Bank.](https://www.worldbank.org/en/publication/globalfindex)
+Demirgüç-Kunt, Asli, Leora Klapper, Dorothe Singer, and Saniya
+Ansar. 2022.
+
+[39. “Open Banking for Fintech and Retail Banks -- Accelerate your digital](https://www.thisisbud.com/banks)
+[transformation with Open Banking.” Bud. 2023.](https://www.thisisbud.com/banks)
+
+40. [Unlocking lending opportunities. Plaid. 2023.](https://plaid.com/customer-stories/flexport/)
+
+
+-----
+
+[41. “M&T empowers consumers during times of financial instability.” MX.](https://www.mx.com/case-studies/mt-bank-empowers-consumers/)
+2020.
+
+[42. “Shaping Europe’s digital future: Open Data.” European Commission.](https://digital-strategy.ec.europa.eu/en/policies/open-data)
+June 2022.
+
+43. [The Consumer Data Right. Australian Competition & Consumer](https://www.accc.gov.au/focus-areas/the-consumer-data-right)
+Commission.
+
+[44. “Open Application Programming Interface (API) for the Banking](https://www.hkma.gov.hk/eng/key-functions/international-financial-centre/fintech/open-application-programming-interface-api-for-the-banking-sector/)
+[Sector.” Hong Kong Monetary Authority.](https://www.hkma.gov.hk/eng/key-functions/international-financial-centre/fintech/open-application-programming-interface-api-for-the-banking-sector/)
+
+[45. “The state of open banking in Europe — in 4 charts”, Sifted.eu. April](https://sifted.eu/articles/state-europe-open-banking-uk-fintech)
+5, 2022.
+
+[46. “Open Banking Limited publishes Trustee End of Implementation](https://www.openbanking.org.uk/news/open-banking-limited-publishes-trustee-end-of-implementation-roadmap-summary-report/)
+[Roadmap summary report.” OBIE. January 2023.](https://www.openbanking.org.uk/news/open-banking-limited-publishes-trustee-end-of-implementation-roadmap-summary-report/)
+
+[47. “A study on the application and impact of Directive (EU) 2015/2366](https://data.europa.eu/doi/10.2874/996945)
+[on Payment Services (PSD2)”, European Commission, Directorate-](https://data.europa.eu/doi/10.2874/996945)
+General for Financial Stability, Financial Services and Capital Markets
+Union, Bosch Chen, I., Fina, D., Hausemer, P., et al., Publications Office
+of the European Union, 2023.
+
+48. According to the report, the calculations relate to 1125 credit
+institutions and banking groups/associations and 189 TPPs.
+
+49. The Legal Entity Identifier (LEI) ideated by the Financial Stability
+Board (FSB) and developed by ISO as an ISO standard has been a
+useful data standard that has gained more relevance and usage
+[along these last years. For more info, please visit the FSB site and the](https://www.fsb.org/work-of-the-fsb/market-and-institutional-resilience/post-2008-financial-crisis-reforms/legalentityidentifier/)
+[GLEIF site.](https://www.gleif.org/en)
+
+[50. “Fintech and regtech standardization,” EU Commission. Joinup.](https://joinup.ec.europa.eu/collection/rolling-plan-ict-standardisation/fintech-and-regtech-standardisation)
+
+51. [Consumer Data Right. Australian Government.](https://www.cdr.gov.au/)
+
+[52. “Singapore Financial Data Exchange (SGFinDex).” Association of](https://abs.org.sg/consumer-banking/sgfindex)
+Banks of Singapore.
+
+[53. “Investment holdings data included in SGFinDex” Monetary Authority](https://abs.org.sg/docs/library/sgfindex---press-release-by-mas.pdf)
+of Singapore and Smart Nation Singapore. Joint Media Release.
+September 2021.
+
+[54. “Unleash the Power of Data through Commercial Data Interchange](https://cdi.hkma.gov.hk/)
+[(CDI).” Hong Kong Monetary Authority.](https://cdi.hkma.gov.hk/)
+
+55. PSD2 established a compulsory framework for payments information
+being shared and payments being initiated by third party providers,
+and thus creating two different roles such as the Payments Initiation
+Service Provider (PISP) and the Accounts Information Service
+Provider (AISPs).
+
+[56. PSD2 is currently under revision. See European Commission website.](https://finance.ec.europa.eu/regulation-and-supervision/consultations/finance-2022-psd2-review_en)
+
+[57. “Data act: member states agree common position on fair access to](https://www.consilium.europa.eu/en/press/press-releases/2023/03/24/data-act-member-states-agree-common-position-on-fair-access-to-and-use-of-data/)
+
+
+[and use of data,” European Council of the European Union. 24 March](https://www.consilium.europa.eu/en/press/press-releases/2023/03/24/data-act-member-states-agree-common-position-on-fair-access-to-and-use-of-data/)
+2023.
+
+[58. For more information on compensation, “Study for developing](https://data.europa.eu/doi/10.2838/19186)
+[criteria for assessing “reasonable compensation” in the case of](https://data.europa.eu/doi/10.2838/19186)
+[statutory data access right: study for the European Commission](https://data.europa.eu/doi/10.2838/19186)
+[Directorate-General Justice and Consumers: final report,”](https://data.europa.eu/doi/10.2838/19186)
+Directorate-General for Justice and Consumers, Monti, G., Tombal,
+T., Graef, I., Publications Office of the European Union, European
+Commission, 2022.
+
+59. “What is CDR?” Australian Government.
+
+[60. “Designing open standards for safe and secure data sharing.”](https://consumerdatastandards.gov.au/)
+Consumer Data Standards.
+
+[61. “Future Development of Open Banking in the UK.” Joint Regulatory](https://www.openbanking.org.uk/wp-content/uploads/SWG-Report-The-Future-Development-of-Open-Banking-in-the-UK-Feb-2023.pdf)
+Oversight committee. February 2023.
+
+[62. “Introduction of the Data Protection and Digital Information (No. 2)](https://questions-statements.parliament.uk/written-statements/detail/2023-03-08/hcws617)
+[Bill.” UK Government – Secretary of State for Science, Innovation and](https://questions-statements.parliament.uk/written-statements/detail/2023-03-08/hcws617)
+Technology. Statement made on 8 March 2023.
+
+63. [Open Finance Brasil.](https://openfinancebrasil.org.br/)
+
+[64. “Principles for Digital Trust Networks.” IIF. 2022.](https://www.iif.com/portals/0/Files/content/Innovation/02_15_2022_digital_trust.pdf)
+
+[65. “Draft Recommendations on the Governance of Digital Identity.”](https://engagement.oecd-opsi.org/system/documents/attachments/000/000/015/original/bc49ee5e70e788cac4f6b90b863739e44c8ae0d4.pdf)
+OECD. March 2023.
+
+[66. “Shifting from Open Banking to Open Finance: Results from the 2022](https://www.oecd-ilibrary.org/docserver/9f881c0c-en.pdf?expires=1676057943&id=id&accname=guest&checksum=506BA3D9BE10452AD64FB2EDC4DD4715)
+[OECD survey on data sharing frameworks.” OECD Business and](https://www.oecd-ilibrary.org/docserver/9f881c0c-en.pdf?expires=1676057943&id=id&accname=guest&checksum=506BA3D9BE10452AD64FB2EDC4DD4715)
+Finance Policy Papers. Organization for Economic Co-operation and
+Development (OECD). 2023.
+
+[67. “Realizing the digital promise: Call to action.” Deloitte & IIF. 2021.](https://www.iif.com/portals/0/Files/content/Innovation/10_12_2021_digitalpromise_cta.pdf)
+
+[GLobal Assured Identity Network White Paper. IIF et al. 2021.](https://www.iif.com/portals/0/Files/content/Innovation/02_15_2022_digital_trust.pdf)
+
+[68. “Principles for Digital Trust Networks.” IIF. 2022.](https://www.iif.com/portals/0/Files/content/Innovation/02_15_2022_digital_trust.pdf)
+
+[69. “Digital Identities in Financial Services Part 2: Responsible Digital](https://www.iif.com/portals/0/Files/content/Innovation/10142019_responsible_digital_ids.pdf)
+[Identities, The Key to Creating More Inclusive Economies.” IIF. 2019.](https://www.iif.com/portals/0/Files/content/Innovation/10142019_responsible_digital_ids.pdf)
+
+[70. “BIS Papers No. 126 – Corporate digital identity: no silver bullet,](https://www.bis.org/publ/bppdf/bispap126.pdf)
+[but a silver lining. Monetary and Economic Department. Bank for](https://www.bis.org/publ/bppdf/bispap126.pdf)
+[International Settlements (BIS).” 2022.](https://www.bis.org/publ/bppdf/bispap126.pdf)
+
+[71. “Perspectives: Building Trust in Financial Services through Digital](https://www.deloitte.com/global/en/services/risk-advisory/blogs/building-trust-in-financial-services-through-digital-identity-management.html)
+[Identity Management.” Deloitte. 2021.](https://www.deloitte.com/global/en/services/risk-advisory/blogs/building-trust-in-financial-services-through-digital-identity-management.html)
+
+[72. “Digital Identities in Financial Services Part 3: The business](https://www.iif.com/portals/0/Files/content/Innovation/03_06_2020_ difs.pdf)
+[Opportunity for Digital Identity.” IIF. 2020.](https://www.iif.com/portals/0/Files/content/Innovation/03_06_2020_ difs.pdf)
+
+
+-----
+
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