Updated: October 2020
The banking industry acknowledges that it is necessary to promote data-driven innovative services, and that
data sharing can be helpful for that purpose. If data sharing is mandated beyond PSD2, then, instead of
making data available free of charge for the recipient, it would be necessary to implement a model based on
mutual benefits (similar to those applied in the telecommunications industry and in the United States) under
which data access should be on commercial terms to ensure the maintenance of infrastructure and further
investments in innovation.
According to the model above, financial organisations would be able to share data with other licensed financial
services providers whenever requested, while being compensated for the technical costs of necessary
infrastructure implementation. These costs would be reasonable and would guarantee non-discrimination of
smaller providers. Without this compensation model, open finance initiatives would make it costly to hold large
amounts of data, which is equivalent to having large amounts of clients. There would be discrimination against
the largest providers of financial services.
In the areas of standardisation and interoperability, ESBG advocates for the establishment of a sufficiently
flexible and broad framework of which the requirements would be limited to elements that are truly useful in
the perspective of "productive" standardisation.
ESBG agrees with the principle of data sharing. However, in sectors where data is particularly sensitive,
like the financial sector, data sharing should not be mandatory. Data sharing is a complex issue which needs
to be balanced against several other factors, such as:
As an advocate of technology neutrality, ESBG believes that the service and/or the product should always be
regulated and not the technology. Though ESBG members have the possibility of accessing external data
owned by BigTech companies, this usually comes at a high price. Some members have already encountered
difficulties in using external data from other companies due to prohibitive prices. ESBG believes the financial
sector does not need any further regulation in data sharing.
Europe is undergoing a digital transition that is changing our societies and economies at an unprecedented
speed. Data is at the core of this transformation.
Through the consultation on a European data strategy, the European Commission aims at making the EU a
global data space, a role model and a leader for a society empowered by data. The goal is to create a
European single market for data where:
ESBG submitted a response to the consultation in May 2020, with additional comments.