Orchestrating Open Banking for platform growth: 2026 outlook
Open Banking has moved from compliance to commercialisation, with PSD2 establishing an important baseline. According to Stephen Whitehouse, head of payments for Europe at Oliver Wyman, PSD3 and the Financial Data Access Act (FiDA) will further drive this movement, increasing the scope of data involved and thereby enabling new business models and use cases.
Within the next 12 to 18 months traditional financial providers need decide what role they want to play – becoming an orchestrator or risk becoming an utility. In my view, there will be three decisive shifts: incumbents becoming data orchestrators, platforms scaling embedded finance, and a rising global debate about who pays for API access.
From access provider to data orchestrator
Banks for now still hold the majority of client relations. By growing towards the platform for a customer’s entire financial life, banks can secure that position in the future. Many incumbent firms are transforming their mindset, shifting from pure providers of account data into active orchestrators of financial information.
For retail clients that means a single dashboard that combines transaction histories, savings, insurance, and a transparent view of pensions, creating a 360-degree financial platform. For commercial clients that means a single-pane platform that embeds accounting, tax, invoicing, and payments.
Make consent simple, enforce contracts, and log everything. Offer catalogued, ready-to-use data feeds – standard transaction categories, payroll markers, and pension tags – so partners can integrate without custom work. Run a searchable API catalogue, a developer sandbox, and an orchestration layer that chains calls and handles retries. Move quickly to protect the customer interface; move slowly and you lose it.
Non-banks continue to leverage embedded finance
Embedded finance is now a core design pattern for many non-financial platforms and marketplaces. Both vertically oriented (e.g. platforms for restaurants, hospitality) and horizontally oriented (e.g. accounting, tax) software firms and large commerce platforms are embedding payments, lending, and insurance capabilities to increase customer stickiness, battling with banks to capture the client interface and tap into additional revenue streams.
When platforms combine premium application programming interfaces (APIs) with variable recurring payments and instant payment rails, they raise conversion, lower cost-to-serve, and improve reconciliation. The commercial prize shifts from owning the customer to orchestrating a trusted ecosystem.
Who pays for API access?
The industry must settle fair, transparent pricing for API-enabled data. Discussion in the United States about banks charging for API access has made this unavoidable. Charging without principles risks erecting barriers for start-ups and creating data gatekeepers. Refusing to charge risks unsustainable system load and a degraded developer experience.
We need transparent cost-allocation models that reflect true marginal cost for heavy services such as bulk historical queries and enrichment. We also need tiered commercial constructs, such as usage tiers or revenue sharing, to preserve innovation while enabling cost recovery. Regulators should set guardrails to prevent anti-competitive pricing and to protect smaller firms.
Regulatory and market implications
Even though the legislation drafts are not final yet, PSD3 and FiDA will be additional enablers to drive open finance adoption and harmonization through more standardized data access. Regulators must focus on interoperability, non‑discrimination in API access, and oversight of systemically important third parties. Industry bodies must converge on developer experience standards, documentation, and minimal service‑level agreements so integrations are predictable and reliable.
Learnings from the early PSD2 days should shape the next wave of open finance regulation – avoiding fragmented standards, weak SLAs, and poor developer experience.
A new EBA‑commissioned study led by INNOPAY [a business of Oliver Wyman], underscores these points and maps the practical implications of FiDA for banks and platforms. According to the report, FiDA expands data scope across savings, mortgages, investments, pensions, and insurance; it introduces compensation for data holders; and it asks the industry to lead scheme design backed by binding rules.
The study draws on interviews with more than 50 senior executives across 15 EU markets and highlights three urgent issues: high estimated implementation costs, tight timelines, and the risk of fragmented schemes.
Further reading: FIDA: Turning Open Finance compliance into a strategic opportunity.
Practical priorities for the next 12 to 18 months
Incumbent banks should productize their data, ‘platformise’ core operations, and launch certified partner marketplaces. Platforms should embed finance end to end, secure the necessary licenses or partnerships for regulated services.
Financial capability providers should design composable offers that plug into platform marketplaces, insist on transparent API terms, and perfect low-friction consent experiences. Regulators, industry bodies and market players should define principles for fair pricing, mandate minimal interoperability standards, and monitor concentration risk.
Open Banking’s value will come from embedding data as reliable core for financial services – either serviced through embedding partners or distributed to end-customers directly. Determining and then executing on the best-fitting data strategy will be key to win in this market. Having chaired the payments stage at the Open Banking Expo, I believe the architecture for the next wave is in place. The test is execution: platformise, productize, and partner at speed.
