Ten years after PSD2, it is fair to ask whether Open Banking has delivered on its promise. There are multiple ways to look at it. If the objective was to create a framework that allows financial data to move securely between institutions, then Open Banking has undoubtedly achieved something remarkable. Europe now has a financial data infrastructure that simply did not exist before.

That is, in theory, in my opinion, because if, on the other hand, the ambition was to fundamentally reshape customer experiences, stimulate widespread innovation and create a new generation of financial services, the verdict becomes less straightforward.

Banks are working hard today to get PSD3 and PSR implemented, and behind the curtains, there is heavy lobbying on FiDA, all new initiatives to try to solve what failed under PSD2.

At the same time, over the past 5 years, AI has evolved into an almost unstoppable revolution in technology, and the big AI providers need data, a lot of data. So it’s no surprise that, in parallel, they are working on open banking initiatives, not through a regulatory lens, but as private organisations eager to consume more data and build more compelling use cases for their AI engines.

It’s in that context that we asked Nicola Breyer for a webinar on open banking and embedded finance. Regular attendees of The Banking Scene may remember Nicola Breyer from our Amsterdam conference in 2025, where she joined us to discuss FiDA and the future of financial data sharing. Having worked at the intersection of banking, fintech and financial data for many years, Nicola has been closely involved in the evolution of Open Banking from its regulatory beginnings to today’s much broader Open Finance debate. Given the rise of AI, changing customer expectations and ongoing discussions around PSD3, PSR and FiDA, it felt like the right moment to reconnect and ask a fundamental question: after ten years of Open Banking, who is really setting the direction of travel?

Is Open Banking a Success in Europe?

Rather than debating PSD3, API standards or consent management frameworks, we found ourselves discussing artificial intelligence, platform economics and the future ownership of the customer relationship.

Nicola argued that, from a value creation perspective, Open Banking has largely failed to live up to expectations. She repeated the popular opinion that the industry struggled to create compelling reasons for customers to use it. Too often, Open Banking was approached as a compliance exercise rather than as a strategic opportunity to rethink customer engagement. Banks built APIs because regulators required them, but very few institutions viewed Open Banking as a mechanism to deepen customer relationships or create entirely new forms of value. That often led to low-quality open banking connectivity and a lack of interest to connecting.

What Can Europe Learn From Brazil to Make Open Banking More Successful?

The contrast with Brazil is particularly interesting. On May 28, the Central Bank of Brazil joined us in Brussels, so we heard first-hand what open finance looks like there. That is a completely different evolution from what we saw in Europe.

During the discussion, Brazil repeatedly emerged as an example of a market where Open Finance evolved beyond regulatory compliance and became an ecosystem-wide transformation. Brazilian banks were hardly enthusiastic when the framework was introduced. Many resisted, questioned its value or worried about the implications.

Yet once implemented, the market began to discover opportunities that had not been obvious beforehand. New business models emerged. New forms of collaboration developed. Participation became less about complying with regulation and more about creating value.

The lesson for Europe may therefore be twofold: coordinated infrastructure accelerates adoption, but long-term success ultimately depends on creating compelling use cases.

Has Europe spent too much time discussing governance and not enough time discussing outcomes?

How AI is Shaping the Open Banking Agenda Worldwide

The conversation in the webinar quickly moved away from Open Banking itself. Artificial intelligence repeatedly surfaced as the dominant theme. For years, the industry’s central question was who should have access to customer data. Today, the more important question may be who is capable of interpreting that data and transforming it into meaningful advice, recommendations and actions.

Or even stronger: if the big AI platforms come with compelling use cases, which bank can afford to stay behind?

Nicola explained that major AI providers increasingly view financial services as one of their most important future domains. Consumers are already using AI tools to understand spending patterns, optimise savings decisions and explore investment opportunities. In the United States, recent announcements made this very concrete. This development may fundamentally change the competitive landscape. For years, banks viewed fintechs as the primary challengers to their position. Today, the more significant challenge may come from AI platforms that sit between customers and financial institutions.

Traditionally, banks occupied a privileged position. They manufactured financial products, owned the distribution channels, and controlled interactions with customers. Even as banking became digital, that basic model remained intact. Customers may have stopped visiting branches, but they still interact through their bank's mobile apps and digital channels.

Artificial intelligence introduces a very different dynamic. Increasingly, customers may start their financial journeys by asking an AI assistant whether they can afford a mortgage, how much they should save for retirement or whether they should refinance an existing loan. The first meaningful interaction may no longer occur in a banking environment. The institution providing the answer may not be the institution providing the product.

This possibility sits at the intersection of Open Banking, Embedded Finance and AI. Embedded Finance already demonstrated that customers care more about solving problems than about the identity of the financial institution behind the solution. Loans, payments and insurance products increasingly appear within broader customer journeys. The financial product becomes embedded within a larger experience.

Artificial intelligence may accelerate that trend even further. Customers will not necessarily seek out a financial product. They will seek guidance, context and answers. The organisation providing those answers may become far more influential than the organisation providing the underlying balance sheet.

Nicola repeatedly returned to two use cases that she believes could finally unlock the promise of data sharing. The first is the concept of a true financial home: a comprehensive overview of an individual’s financial situation combined with personalised guidance and advice. The second is what she calls a “My CFO” proposition for small businesses, where banking data, accounting information, tax obligations and operational data are brought together to help entrepreneurs make better decisions.

Neither concept is entirely new. The industry, and also The Banking Scene, has talked about financial wellness, personal financial management and small-business advisory services for years. And today, artificial intelligence suddenly makes these ideas realistic at scale. During the discussion, examples emerged of accounting platforms that already allow users to ask conversational questions about cash flow, taxes and business forecasts. Entrepreneurs increasingly rely on AI to help them understand their financial position. In many ways, AI may finally deliver the personalised financial guidance that Open Banking promised but never quite achieved.

Why the United States Is Taking the Lead in Open Banking and AI

One example that repeatedly surfaced during our discussion was Plaid. For years, Plaid was viewed primarily as a connectivity business. Its role was to connect financial data and make it accessible to applications. Today, Plaid illustrates how the value is shifting toward the ecosystem built on top of the data.

The value is increasingly shifting from infrastructure to interpretation.

Access to information is becoming a commodity. The ability to transform that information into intelligence is becoming the differentiator. That observation should not be lost on European policymakers. There is a risk that Europe spends years perfecting the plumbing while others capture the value created on top of it.

The conversation also touched on another emerging trend: agentic finance. We discussed Robinhood’s recent announcements about AI-powered investment assistance capable of taking action on customers’ behalf.

For years, Open Banking focused on the sharing of information. Agentic finance introduces the possibility of delegating decisions. Once AI systems move beyond analysis and begin acting on customers’ behalf, discussions around trust, accountability, liability and regulation become significantly more complex. Open Finance ceases to be merely about the portability of data. It becomes a discussion about the delegation of judgement.

How Should Banks Prepare for an AI-Driven Open Finance?

As Nicola stated: “Machine-readable is one thing. AI interpretable is a different story.”

She pointed to developments in the UK, where discussions increasingly focus on how data standards should evolve in an AI-driven world. In that context, accessibility alone is no longer sufficient. Data must also be understandable. Context must be preserved. Meaning must be clear. The institutions capable of providing AI-legible financial data will enjoy a significant advantage over those that merely expose APIs.

All of this brings us back to the original question: who defines the strategic agenda?

For many years, the answer seemed straightforward. Regulators set the direction through initiatives such as PSD2. Banks responded, and fintechs innovated within the framework that was created. Today, that picture is far more complex. Regulators still shape the rules, banks remain central to the financial system, and fintechs continue to push innovation forward. But increasingly, AI providers, data platforms and broader ecosystems are influencing where value is created and where customer relationships are formed.

That shift changes the strategic challenge for banks. The question is no longer only whether Open Banking succeeded as a regulatory initiative. It is whether banks can remain relevant in a world where financial decisions increasingly begin outside their own channels.

In that environment, trust, context and guidance may matter more than infrastructure alone, and ownership of the customer conversation may prove more valuable than ownership of the customer data.

You can view the full webinar recording of the session below, or watch / listen to it on your favourite podcast channel here (don't forget to subscribe for further insights from industry experts).