Ten Years of Open Banking: Were We Looking for the Wrong Revolution?

Ten years ago, we believed Open Banking would shake up European banking. I believed it would: new competitors would challenge established banks, customers would take control of their financial data, and entirely new business models would emerge.

Today, we must admit that didn’t happen, at least not with the disruptive force we expected. But after spending the past few months researching the topic, I am increasingly convinced that we may have underestimated what Open Banking actually achieved.

Looking back at a decade of expectations

I still remember the discussions around PSD2 when I was working as Senior Product Manager in Daily Banking at a bpost bank. Open Banking was one of those topics that created both excitement and anxiety, and in our small bank: mostly anxiety.

For some, it represented an opportunity to innovate. For others, it was another regulatory obligation requiring substantial investments, with little clarity about the potential return. And then there was the uncomfortable idea that banks would be forced to give third parties access to customer accounts and transaction data, potentially losing control over an important part of their customer relationships.

There were plenty of bold predictions. Fintech companies would challenge traditional banks, customers would increasingly manage their finances through independent applications, and banks risked becoming little more than regulated infrastructure providers.

Ten years later, very little of that happened at the scale originally anticipated.

So, was Open Banking a disappointment?

At The Banking Scene, I started our first Open Banking Interview Series in 2019, speaking with banks about their ambitions, concerns and expectations. Looking back at those interviews today is particularly interesting. Some predictions were remarkably accurate, others proved overly optimistic, and a few concerns that dominated discussions back then have almost disappeared from the agenda.

Earlier this year, I decided to revisit the topic. Together with Nicola Breyer, we explored how the industry has changed and where it might be heading.

Between June and September 2026, we interviewed representatives from KBC, Deutsche Bank, Rabobank, Isabel, the European Payments Council, bunq, Paylume, msg for banking and several other organisations. We complemented those conversations with discussions from The Banking Scene conferences, including insights from the Central Bank of Brazil and The Banking Scene Payments BBQ Night.

The result is our research paper, Open Banking and Embedded Finance in Europe: A Benelux Perspective on Regulation, Sentiment, and the Road Ahead.

Rather than repeating the research here, I want to share a few observations that stayed with me throughout the interviews.

Regulation opened the market, but where was the business?

A conversation that especially resonated with me was with Gijs Boudewijn, Chairman of the European Payments Council. He shared an observation that captures much of what we discovered:

“Regulation can open up a market, but it cannot create one.”

The regulator aimed to stimulate competition by requiring banks to provide access to payment account data, assuming innovation would follow once those barriers were removed. Technically, the approach worked: banks invested heavily in APIs, authentication, security, and connectivity, while third-party providers gained regulated access to financial information.

But regulation couldn't guarantee customers would want the services it enabled. Personal Financial Management applications are probably the best example. For years, we discussed bringing all your accounts together in one application to help customers understand their spending habits and manage their finances.

The technology was there, but customer enthusiasm remained limited. Meanwhile, banks struggled to identify why they should invest beyond their minimum regulatory obligations. As time flew by, so did the sense of urgency: banks didn’t lose clients by ignoring premium options.

Building and maintaining APIs costs money, and the absence of a remuneration model made additional investments difficult to justify.

I find the ongoing FiDA discussion particularly interesting for precisely this reason. Europe is considering extending mandatory data sharing beyond payments, towards insurance, investments, mortgages and pensions.

The ambition is understandable, but have we sufficiently established where customer demand exists?

I am not convinced that another broad regulatory framework automatically brings us closer to meaningful innovation, nor do most of the experts I spoke to. Yet without PSD2, many of today's developments might never have happened.

Three countries, three different approaches

Another interesting finding emerged from comparing Belgium, the Netherlands and Luxembourg. Although all three implemented the same European framework, their approaches differed considerably.

Dutch banks generally approached Open Banking with considerable commercial ambition. ABN AMRO and Rabobank developed APIs that went beyond PSD2 requirements, particularly for corporate customers.

Belgian banks initially shared similar ambitions, but took a more cautious approach to implementation. Luxembourg followed a different path, with several banks joining forces through LUXHUB to build shared infrastructure.

This makes sense in light of the market context: Belgium already had Isabel, which provided multibank connectivity for corporate customers long before PSD2. Some opportunities Dutch banks uncovered through Open Banking were therefore already being addressed in Belgium. And Luxembourg… well, the Luxembourg market concluded that individual banks could not afford to invest heavily in a non-competitive area such as PSD2 connections.

This also helps explain another recurring finding: Open Banking seems to have delivered more tangible value in business banking than in retail banking.

When APIs automate bookkeeping, reconcile transactions or simplify treasury management, customers see the benefits immediately.

Perhaps we spent too much time searching for the next revolutionary banking application and not enough time noticing the improvements taking place in business processes.

Open Banking is becoming invisible

Throughout this year’s interviews, Open Banking itself rarely seemed to be the conversation’s ultimate focus. Although we invited people to discuss Open Banking, conversations increasingly shifted to Embedded Finance, customer journeys, accounting software, wealth management and artificial intelligence.

That makes sense: customers don’t wake up wanting to use an API. They want to solve a problem, complete a transaction or receive a service.

Today, artificial intelligence is entering the picture. Nicola Breyer made an observation I particularly liked:

“Machine-readable is one thing. AI-interpretable is a different story.”

For years, the industry focused on making financial data accessible, but it didn’t make insights accessible. AI could make that information far more useful by interpreting it, combining it with other information, and potentially acting on it.

That raises an uncomfortable strategic question for banks: if customers increasingly interact with AI assistants rather than directly with their banks, who controls the intelligence behind financial decisions? And who manages the customer relationship?

What do I conclude after this research?

First, Open Banking may be more successful than its reputation suggests. We have spent years measuring PSD2 against expectations of disruption, new competitors and widespread consumer adoption. By those standards, its success is debatable. Yet PSD2 also pushed banks to invest in APIs, strengthen security, rethink data ownership and build external collaboration capabilities, changes that may matter more than the retail applications we anticipated.

Second, the next chapter should be driven much more by customer needs than by regulatory ambitions. Before launching another extensive regulatory exercise, the industry should identify the business opportunities it can support. FiDA illustrates this tension: broader financial data sharing is appealing, but implementation costs, commercial incentives and customer demand need more attention. Karl Illing's proposal to start with a coalition of the willing, prove successful use cases and then expand is worth considering.

Third, the future of Open Banking may increasingly be determined outside traditional banking. Ten years ago, regulators clearly set the agenda. Today, banks, fintechs, software providers and technology platforms increasingly shape how financial services are delivered. AI could accelerate that shift considerably. Banks will need to decide where they want to create value: through customer relationships, regulated capabilities, financial intelligence or partnerships.

Fourth, trust and customer control will become increasingly important. As financial data is shared more widely, customers need greater transparency and control over who accesses their information and for what purpose. Permission dashboards, granular consent mechanisms and the ability to revoke access easily will become essential. Regulation should provide these safeguards while allowing the market to develop services that deliver genuine customer value.

Finally, Open Banking's greatest legacy may be the infrastructure it leaves behind. PSD2 pushed banks to invest in APIs, security, data sharing and connectivity. What started largely as a compliance exercise is increasingly becoming the foundation for commercial services, from Embedded Finance and Banking-as-a-Service to AI-driven propositions. The next decade will be less about opening access to financial data and more about turning that access into services customers actually value.

There is some irony in that. For years, the industry questioned whether its Open Banking investments would ever deliver sufficient returns. Now, just as Open Banking is disappearing from the strategic agenda as a standalone topic, those investments may become increasingly valuable.

Open Banking did not deliver the revolution many predicted ten years ago. But it may have helped prepare European banking for the much broader transformation now taking shape.

And for me, that is a much more interesting conclusion than simply declaring PSD2 a success or a failure. I can’t wait to evaluate the topic again in 3 years.

Based on The Banking Scene's research paper, Open Banking and Embedded Finance in Europe: A Benelux Perspective on Regulation, Sentiment, and the Road Ahead, September 2026.

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