In our response to the European Commission’s targeted consultation on Open Finance, we state that Open finance should complement what exists and works well in the market today: it should add value to existing markets and systems for the sharing and reuse of financial data. Data sharing among lenders and other providers of services via credit databases is a case in point.

From a credit referencing perspective, Open Finance should not lead to an overall decrease in the comprehensiveness, supply and accuracy of credit information, and on the ability of CRAs to fulfil their duties and lend stability to the credit system.

In our view, Open Finance must prioritise use cases with high potential and benefit for consumers and firms, as well as clear industry incentives. Moreover, open finance must be based on a level playing field, including fair competition and equal, and fair access to data.