ALFI responds to the EU Commission’s ‘have your say’ on the proposal for a regulation on a framework for financial data access

On 30 June 2023, the EU Commission launched a public ‘have your say’ to collect feedback on the proposal for a regulation on a framework for Financial Data Access. The input collected during the feedback period will be summarized by the European Commission and presented to the European Parliament and Council with the aim of feeding into the legislative debate. The open finance and financial data access proposal refers to the access and reuse of customer data, with consent, across a range of financial services. This initiative aims to enable data sharing and third party access for a wide range of financial sectors and products, in line with data protection and consumer protection rules. It is based on the principle that financial services customers own and control the data they supply and the data created on their behalf.

The evaluation of the impact on the fund industry of the application of the current proposal largely rely on a conjectural assessment due to the absence of manifest case studies and concrete applications. Nevertheless, ALFI’s analysis has highlighted fundamental considerations and recommendations pertaining to the open finance framework when applied to investment fund managers and their stakeholders. These considerations relate to:

I. Customer definition encompassing natural and legal persons
II. Effective costs and compensation
III. Scope of data to be exchanged
IV. Fragmented request possible
V. Potential side effect
VI. Timing for implementing schemes

View the ALFI response.