A Benelux perspective on regulation, sentiment and the road ahead

Ten years after PSD2, Open Banking didn't deliver the revolution many expected. It quietly prepared the industry for the one now emerging.

When PSD2 came into force, the industry braced itself for disruption. Banks feared losing control of the customer relationship; fintechs anticipated a wave of new retail propositions. Neither scenario played out as predicted.

This white paper looks back at a decade of Open Banking across Belgium, the Netherlands and Luxembourg, and asks what it actually achieved, where value has really been created, and what comes next. Drawing on new interviews with senior figures from KBC, Deutsche Bank, Rabobank, Isabel, the European Payments Council, Paylume, msg for banking and bunq, alongside insights from The Banking Scene Conference 2026 Brussels, it connects two conversations that are too often held separately: the regulatory agenda and the commercial reality.

The conclusion is a nuanced one. Open Banking succeeded, but not in the way anyone expected, and the infrastructure it created is now becoming the foundation for Embedded Finance, Banking-as-a-Service and AI-enabled financial services.

What's inside

• The regulatory foundations. How PSD1, PSD2 and GDPR shaped Open Banking, and why the same European legislation produced three very different approaches in the Benelux: bank-by-bank in the Netherlands, cautious in Belgium and a shared utility in Luxembourg.
• The regulation still to come. A clear explanation of PSD3, the Payment Services Regulation, the SEPA Payment Account Access scheme and FiDA, including how they relate to one another and where each stands today.
• Lessons from a decade of Open Banking. Findings from our 2026 interview series, set against the sentiment captured in The Banking Scene's original Open Banking Interviews from 2019.
• A practical case study. How bunq-as-a-Service turns regulated banking capabilities into a commercial platform that partners such as Blockrise can embed directly into their own customer journeys.
• The next decade. Five shifts that will define what follows: from Open Banking to customer value, from products to capabilities, from data access to data intelligence, the AI-driven customer interface, and from access to trust.

The key questions explored

• Did Open Banking succeed, and by what measure should we judge it?
• Why has business banking generated far more tangible value than retail?
• Can regulation create a market, or only open one?
• Will remuneration models such as SPAA finally give banks a commercial reason to invest in better APIs?
• Is FiDA the right route to Open Finance, or should Europe start with a smaller "coalition of the willing"?
• Who now sets the strategic agenda: regulators, banks or technology companies?
• How will AI agents acting on behalf of customers change the requirements for identity, consent and liability?
• Where should banks choose to compete as financial data becomes a commodity and intelligence becomes the differentiator?

Who should read it

This paper is written for professionals who need to make strategic decisions about Open Banking, Open Finance and Embedded Finance, rather than simply comply with them. It will be particularly valuable for:

• Bank leaders in strategy, product, digital, payments and innovation who are weighing where to invest beyond the regulatory minimum.
• Open Banking, API and partnership leads building the case for premium APIs and ecosystem propositions.
• Regulatory, compliance and public affairs professionals preparing for PSR, PSD3 and FiDA.
• Fintechs, technology providers and software vendors serving financial institutions, who need to understand how banks are thinking about the next phase.
• Consultants and advisers working with clients across the Benelux and wider European market.

Why download it

Most analysis of Open Banking treats regulation and commercial innovation as separate subjects. This paper brings them together, grounded in first-hand conversations with the people building and governing the market.

You'll come away with:

• A concise, jargon-free overview of the European regulatory landscape and where it is heading.
• A uniquely Benelux view, backed by ten years of interviews tracking how sentiment has evolved.
• Candid perspectives from banks, payment bodies, infrastructure providers and advisers, including where they disagree.
• A practical framework for thinking about where your organisation can create distinctive value in an ecosystem shaped by Embedded Finance and AI.

The infrastructure exists. The regulatory framework largely exists. The question now is who will turn it into value customers genuinely want.