The European Commission released a non-paper on the simplification of the Financial Information Data Access (FiDA) Regulation on May 16. Before we look into that, perhaps it is wise to explain first what a non-paper is (I didn’t know it until seeing the paper, for example).

A non-paper is a term often used in EU policymaking and refers to an informal working document that does not represent an official position but serves to facilitate discussions and shape future negotiations. In this case, the non-paper is a response to requests from the co-legislators during the first political trilogue, providing suggestions on how to simplify FiDA while reducing its administrative burden.

After months of legislative debate and industry discussion, it provides an insight into how Brussels intends to tackle the growing concerns of both policymakers and market participants alike.

But to what extent does it truly tackle the issues raised by the financial industry? Reflecting on the discussions at The Banking Scene Conference 2025 in Amsterdam, and the ideas shared in our earlier blog “Trust in Transition,” let us examine whether this non-paper meaningfully addresses the gaps between regulatory ambition and market reality.

Later this week, on May 22, we will continue this dialogue at The Banking Scene Conference 2025 Brussels - a timely opportunity to put these reflections back on stage and see how the conversation evolves.

Recalibrating Scope: A Step Toward Proportionality

One of the most concrete adjustments proposed is the narrowing of FiDA’s scope to focus on natural persons and SMEs, effectively excluding large corporates. It is a welcome simplification for the industry, reducing the compliance burden for data holders, especially in the investment and insurance sectors.

This change recognises a simple truth: innovation in data sharing must primarily benefit those who cannot negotiate bespoke contracts, namely, individuals and small businesses. Retail customers, who lack the legal and technological resources of corporates, stand to benefit most from standardised access frameworks. For banks, it will be easier to set up, as they can build on the rails and leverage the experience gained from Open Banking and PSD2.

The Commission’s own estimates suggest this move could save up to €370 million in the investment sector alone. I have no idea how they came up with those numbers, but if that’s true, it’s a significant win for the industry.

Identity Management: Embracing European Trust Anchors

In “Trust in Transition,” we highlighted that the success of FiDA depends not just on who accesses data, but how that access is authenticated and trusted. The non-paper's endorsement of the European Digital Identity Wallet is a welcome development. By promoting a harmonised method of customer authentication, it builds the digital equivalent of a verified handshake, mutually recognised, secure, and simple.

This inclusion reflects an evolution from viewing identity management as a technical detail to treating it as a cornerstone of secure digital finance. Trust cannot scale unless identification does, a message that our friend David Birch has been sharing ever since I started following him, and that is quite a few years.

Keeping Big Tech in Check

Another key concern raised by many in the ecosystem was the risk of regulatory asymmetry: specifically, the possibility that non-European tech giants could benefit disproportionately from open data access.

The non-paper’s proposal to exclude Digital Markets Act (DMA) gatekeepers from becoming Financial Information Service Providers (FISPs) is a strong message. It aligns FiDA with the Data Act and reinforces the EU’s commitment to digital sovereignty. Moreover, by invoking the DMA's provisions around cross-use of personal data, the Commission seeks to maintain a level playing field, one in which banks and fintechs compete fairly.

Is this a silver bullet? No. But it is a deliberate course correction, signalling that not all players can sit at the same table if they don't play by the same rules.

Standardisation: Coherence without Coercion

Perhaps the most nuanced part of the non-paper is the Commission’s dual-path proposal for data and API standards. On one hand, it acknowledges the need for harmonisation through European Standardisation Organisations (ESOs). On the other, it retains space for market-led consensus within data-sharing schemes.

This hybrid model is wise. A one-size-fits-all approach risks rigidity, but total decentralisation invites fragmentation. By aiming for coherence without coercion, the Commission attempts to build bridges between innovation and integration. Key question is what the impact will be on the implementation of FiDA.

What Remains Unresolved?

For all the progress outlined in the non-paper, some challenges persist, subtly acknowledged but not yet resolved.

• Incentivisation: There is little discussion of how banks, insurers, and fintechs will be incentivised to join or actively contribute to data-sharing schemes. Regulation without motivation rarely leads to meaningful transformation.
• Implementation Timelines: While simplification is the goal, the road to realisation remains steep. Without phased timelines and realistic adoption frameworks, even the most well-intentioned reforms risk becoming shelfware.
• End-User Trust: Consumers remain the weakest link in the data economy. The proposals touch on technical security but stop short of addressing how individuals will be educated, reassured, and ultimately empowered to engage.

Conclusion: A Meaningful Pivot - But Not Yet a Finish Line

The FiDA non-paper shows that the Commission is listening, adapting, and seeking to balance innovation with simplicity. It also demonstrates the value of the conversations we have already had on FiDA in Luxembourg in January and in Amsterdam in March. Many of the industry's core concerns: scope, identity, standardisation, and gatekeeper power, are now reflected in the evolving draft.

Yet if trust is to remain the north star, more is needed. The frameworks must now be paired with real-world incentives, operational clarity, and customer engagement strategies.

FiDA is still a regulatory project, although it should be considered a societal shift. And, like all transitions of trust, it will take more than simplification to make it work, it will require vision, pragmatism, and sustained dialogue among all players in the financial ecosystem.

And that dialogue will continue in Brussels, on May 22 - join us!