Last year, as part of its European Data Strategy and more specifically the Digital Finance Strategy, the European Commission published proposals aimed at allowing customers to share their data on “investments in financial instruments” held by financial institutions with third-party providers. The “Open Finance” initiative is taking the form of a proposal to amend the Payment Services Directive and a proposal for a Financial Data Access (FIDA) Regulation.

This project raises significant data sovereignty issues for the European Union. It could have far-reaching ramifications for wholesale market participants, which will be forced to mobilise substantial resources, despite the uncertain customer benefits in an area where many of the most advanced countries are allowing market forces to operate. At a time when AMAFI is stressing the critical importance of competitiveness for EU market participants (link News report), this proposal is extremely unwelcome. 

Accordingly, AMAFI is arguing for the scope of the regulation to exclude customers classified as professionals under MiFID, for whom data portability is not an issue.