Framework for Financial Data Access

The Electronic Money Association (EMA), established in 2001, is the trade body for European and UK E-Money Institutions (EMIs), Payment Institutions (PIs), Crypto Assets Providers (CASPs), and Credit Institutions (CIs) providing innovative payments solutions.

Insurely welcomes the Commissions proposal on FIDA. Paving the way forward on how to address data sharing, consumer consent, and data privacy are key to establishing a successful framework. Insurely believes that the following elements should be taken into account to ensure alignment with the needs of consumers and businesses: The Commission got it right on the breadth of the scope.

BIPAR is the European Federation of Insurance Intermediaries. It groups 47 national associations in 30 countries. Through its national associations, BIPAR represents the interests of insurance agents and brokers and financial intermediaries in Europe. Besides some large multinationals, the insurance intermediation sector is composed of hundreds of thousands of SMEs and micro-type operators.

The Association for Financial Markets in Europe (AFME) believes that the EUs proposed Financial Data Access (FiDA) framework and Payments Services Regulation (PSR), if designed correctly, have the potential to enhance the way banks operate, encourage innovation, and support a more effective and efficient data ecosystem and payments system.

AMICE welcomes the opportunity to provide feedback on the European Commissions proposed Regulation on Financial Data Access (FIDA). Removing barriers to effective and secure control and sharing of financial data is critical for fostering data-driven solutions and competition in the financial sector, ultimately benefiting consumers and businesses alike.

SIBS welcomes the current draft proposal for a Financial Data Access regime in the context of a wider Data Economy and is committed to contribute to the success of its implementation. A data economy where consumers are the real owners of their data could empower them to use relevant information for obtaining better products and convenience.

Please find attached the Position Paper of the Association of Foreign Banks in Germany (VAB) of 1 November 2023 on the Proposal for a REGULATION OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL on a framework for Financial Data Access and amending Regulations (EU) No 1093/2010, (EU) No 1094/2010, (EU) No 1095/2010 and (EU) 2022/2554 [COM (2023) 360/Procedure 2023/0205/COD].

Filed in German · English published by the European Commission

Unipol Group appreciates the possibility to provide its feedback on the initiative of the European Commission to establish a framework for using and accessing customer data in finance through the proposed Regulation on Financial Data Access (FIDA).

FIDA regulation will have a significant impact on the Polish insurance companies and insurance intermediaries and their relationships with the immediate economic environment, including insurance company clients, entities cooperating with insurance companies, and potential future insurance company competitors.

Fitch Ratings appreciates the opportunity to review and comment on the Proposal. We set forth in the attached letter our observations and suggestions regarding the Proposal; we have only responded with respect to those elements about which we have comments.

The Swedish Bankers' Association endorses the EBF's response to the EC's consultation on the framework for Financial Data Access (FIDA) but wishes to underline some additional key points as outlined below (see also attached file). In the financial sector, the concept of data sharing within the context of FIDA demands careful consideration and precision in its execution.

Aba Arbeitsgemeinschaft für Occupational Pensions e.V. is the German professional association for all matters relating to occupational retirement provision in the private sector and the public sector. According to its articles of association, the aba-neutral approach is aimed at maintaining and expanding occupational retirement provision.

Filed in German · English published by the European Commission

IPF hopes that the FIDA proposal will help to further level the playing field between bank and non-bank payment providers, as well as modernise and enhance the resilience and competitiveness of the payment sector.

European Digital Finance Association (EDFA) welcomes the opportunity to share its position on the EU payment services legislative package presented by the European Commission on 28th June 2023. EDFA hopes that the proposals will help to further level the playing field between bank and non-bank payment providers, as well as modernise and enhance the resilience and competitiveness of the payment sector.

The European Fintech Association (EFA) warmly welcomes the opportunity to share its position on the Proposal for a Regulation on a Framework for Financial Data Access (FIDA). The EFA represents a diverse group of 35+ FinTech providers ranging from payments, to lending, banking, robo-advice, investment as well as software-as-a-service for the finance sector, with a clear focus on enabling a single market for digital…

The Federation of European Risk Management Associations (FERMA) is a European professional association, which represents, through its 22 Member Associations in 21 countries, nearly 5,000 risk professionals. FERMA speaks on behalf of professional risk managers. Within our membership network, there are individuals who are responsible for the insurance programs of their enterprise.

PensionsEurope welcomes the the Commission's proposal for a framework for Financial Data access (FIDA) which is a key component of the Commission's digital finance strategy presented in September 2020. We also would like to highlight that experiences from other financial services such as payment services cannot be simply applied to the Institutions for occupational retirement provision (IORPs) which are included in…

After a thorough examination of the Financial Data Access (FIDA) proposal, France Assureurs considers that the text in its current form raises concerns for European consumers and is unrealistic in its envisioned implementation. The numerous clarification requests from Members States confirm that this proposal should be extensively rewritten.

On 28th June 2023, the European Commission presented a proposal for a regulation on an Open Finance Framework, with a view to enable consumer data sharing and third-party access in the financial sector, in light of the EU digital finance strategy.

The FNMF shares the overall objective of having a regulatory framework to foster innovation in the insurance sector. Nevertheless, the FNMF remains vigilant about this project, given the negative impacts it could have on insurers and, above all, on policyholders. Find attached our position paper.

Assogestioni shares the Commission's objective, pursued with the Proposal, to promote digital transformation and adoption of data-driven business models in the EU financial sector, by facilitating access of data to certain categories of customer data in financial services.

We welcome the proposed Regulation and shares the objectives that it intends to pursue. We are convinced that the sharing of financial data constitutes a key factor for i) improving the quality of the services provided and the protection guaranteed to customers and for ii) the adoption by companies, in the development of their business models and commercial offers, of a data-driven approach, truly oriented towards…

FIDA should exclude pension data when already shared under an existing national pension tracking service (NPTS). In several MSs, data related to occupational pensions are already made accessible to customers and third parties through a NPTS. In Belgium, a well-functioning and well-established NPTS covers the first pension pillar (statutory pensions) and the second pension pillar (occupational pensions).

The German insurance industry generally supports the European considerations to promote a data-driven financial system. With the presented legislative proposal on a framework for access to financial data ("FiDA"), retail and corporate customers are to be given more creative scope in the use of their financial data.

The Association of Credit Card Issuers in Europe represents the specialised credit card issuing industry in the EU. ACCIE welcomes the Commission's proposals for a new Framework for Financial Data Access. Our feedback can be found in the attached file.

For several years, ETPPA has contributed to the European Commissions work in the Financial Data Access arena by participating in its Financial Data Space Expert Group, its Open Finance report and providing feedback to its targeted consultation.

Finance Innovation, is a trusted hub for the financial sector. It focuses on digital and sustainable transformation, supporting innovative projects by startups and helping major groups identify trends. By bringing together finance industry players, Finance Innovation fosters partnerships and business opportunities, driving innovation, competitiveness, and job creation in France and internationally.

The Italian Banking Association supports the objectives of the proposal for a regulation on a Framework for Financial Data Access (FIDA) as part of the European Digital Finance Strategy. The proposal takes into account some important concerns represented by the financial industry during the preliminary consultation held in 2021.

Position of the FSA on the proposal for a regulation on access to data in the financial sector (“IFAD”) – “Have your say” of the European Commission dated 28 June 2023. It is with the greatest interest that the FSA welcomed the consultation for opinion launched on 28 June by the European Commission, whose general aim is “to improve economic performance for customers of financial services (consumers and businesses)…

Filed in French · English published by the European Commission

Sage welcomes the European Unions proposed framework to open access to a wide range of customer financial data. By opening up this data, financial institutions and approved third party providers will have renewed capacities to provide new and innovative services to customers.

Adigital welcomes the opportunity to provide feedback to the EU Commissions proposal on Financial Data Access and revision of the Payments Services Directive (PSD2). We are aligned with the goals of building off of prior legislative work to: (i) create an even more competitive and innovative payments' ecosystem in Europe; (ii) increase payment speeds and lower payment costs for European customers; (iii) enhance…

The Luxembourg Bankers Association (ABBL) is the largest professional association in the financial sector in Luxembourg, representing the majority of financial institutions as well as regulated financial intermediaries, law firms, consultancies, auditors, market infrastructures, e-money and payment institutions. The association counts more than 190 members institutions and 60 additional related members.

Insurance Ireland welcomes the FiDA proposal. However, we outline some considerations: Scope.We suggest a phased approach by line of business with pre-defined timelines, starting with motor and home insurance Art.4 requires further clarity especially whether the customer should have the right to access this data themselves, automate such data access with software, or authorize a FISP to access the data on their…

The French Banking Federation takes note of the FIDA legislative proposal, which aims at promoting a fair and equitable data-sharing economy, following on from the cross-sectoral Data Act and Digital Governance Act. The FBF conducted a rigorous analysis of the proposed regulation and would like to draw the Commission's attention to some strong concerns: A.

The EMF-ECBC recognises the strategic importance of the Open Finance Framework and welcomes the opportunity to comment on the European Commissions Proposal for a Regulation on a Framework for Financial Data Access (FIDA), which is expected to have far-reaching implications for the banking industry and therefore the mortgage industry.

Assosim expresses its general appreciation for the effort of the European Commission to establish a framework governing access to and use of customer data in finance, which could facilitate access to data also by smaller market participants at more proportionate costs.

While the Commission states that "these proposals are focused on the interests of consumers, competition, security and trust", mutual insurers stand by the legislator to promote together a set of tools and mechanisms at the service of these issues.

While the Commission states that "these proposals are focused on the interests of consumers, competition, security and trust", mutual insurers stand by the legislator to promote together a set of tools and mechanisms at the service of these issues.

ACCIS is the voice of organisations responsibly managing data to assess the financial credibility of consumers and businesses. Established as an association in 1990, ACCIS brings together more than 50 members from countries all over Europe as well as associates and affiliates across the globe.

We are basically satisfied with the proposal for a regulation presented by the Commission. However, we consider it appropriate to specify in the Regulation, in a clear manner, that is permissible the compensation for data retention by the data holders, and that it is not instead permissible to provide for a compensation for the sale of customer data by the data holder to an end-user: customers data are in fact the…

Dear Sir/Madam, please find enclosed our comments on the draft Regulation “Framework for Financial Data Access”. We look forward to taking this into account. If you have any questions, please do not hesitate to contact us. Yours sincerely [name removed] (Executive Board FRIDA e.V.) Slobodan Pantelic (FRIDA e.V. Board)

Filed in German · English published by the European Commission

The Digital Currencies Governance Group (DCGG) welcomes the opportunity to provide feedback on the Regulation for Financial Data Access (FIDA). Please find attached our comments. We would be delighted to discuss our response in more detail should there be any questions or points of clarification that may support your assessment.

We would like to share our feedback on the consultation on the Open Finance Framework. We have included our comments in the separate attachment. Thank you very much for your consideration. We are happy to engage in a dialogue and provide further input and support.

The Association of the Luxembourg Fund Industry (ALFI) represents the face and voice of the Luxembourg asset management and investment fund community. The Association is committed to the development of the Luxembourg fund industry by striving to create new business opportunities, and through the exchange of information and knowledge.

Please find attached the comments from ASNEF, the Spanish Finance Houses Association, duly registered in the Transparency Registry with nº 11218815591-29, with regards to the European Commission's proposed Regulation on the Financial Data Access Framework.

Please find atttached the comments from FEBIS , the Federation of Business Information Services on the proposed Financial Data Access regulation. FEBIS members are business information providers whose core business is to provide business information reports , creditworthiness assessments, credit scores on businesses for businesses.

With the draft Framework for Financial Data Access (FIDA), the EU Commission aims to facilitate access to customer data for a wide range of financial services. This is intended to promote the exchange of data between companies in the financial sector as a whole. Thus, FIDA sets the regulatory framework for open finance.

Occupational pension funds (IORPs) are included in the scope of this proposal. PensioPlus stresses that second pillar pension funds are inherently different from other financial market entities. IORPs are not-for-profit, they operate in a triangular relationship with social partners and do not have any shareholders and, most importantly, they do not sell any products, since employees mainly benefit from mandatory…

AEIP recognises that FiDA proposal is part of the initiative of the Commission to accelerate its work on digital finance. In our position, we present key messages from pension funds and healthcare funds to express certain considerations for genuine adjustments and safeguards. AEIP advocates for greater clarity regarding the potential obligations that this proposal could impose on pension funds.

The European Savings and Retail Banking Group (ESBG) took note of the European Commission's proposed Regulation on the Financial Data Access Framework and its commitment to establish clear rights and obligations to manage customer data sharing in the financial sector beyond payment accounts, and to promote innovative financial products and services for users and stimulate competition in the financial sector.

CEN and CENELEC welcome the proposed Framework on Financial Data Access (FIDA) as a great step in promoting data driven finance. CEN and CENELEC are already playing a role in developing standards that will facilitate the ability of European industry to conform with recent EU initiatives in data sharing, such as the Data Governance Act and the Data Act.

The Dutch Federation of Pension Funds welcomes the European Commissions proposal for the Financial Data Access Regulation. Pension data are an important part of an individuals financial situation. Providing access to occupational and personal pension data assists pension fund members and beneficiaries in obtaining a more comprehensive overview of pension entitlements and personal finances.

The European Association of Co-operative Banks (EACB) welcomes the opportunity to provide its preliminary comments on a proposal for a Regulation on a Framework for Financial Data Access (FIDA) as part of the European Commissions 'Have your Say' consultation. This response aims to elaborate on the EACB's stance, emphasising key points of support and issues needing further consideration.

I. General support to the initiative On behalf of the Czech Insurtech Association, we would like to express our strong support for the proposed Open Finance Framework (FIDA) and, specifically, the development of an Open Insurance Framework.

DECO welcome this proposal. General comments: Acknowledging the objective of promotion of a data driven economy, it is important that there is a regulatory framework to establish the rules by which data sharing happens. This is particularly relevant for financial data as it entails sensitive information of natural persons and firms.

Covid - 19 crises explicitly has shown the fragllity of the business processes in many sectors . The one of the most sensitive, certainly, has been the tourism ecosystem (not just because it is composed from traveling, hosting, selling, marketing and organization & logistic processes, but also each of those segments need to be settled during the complete payment process with the coherence of maintaining the arrenged…

While the development of innovative technologies and better access to more data creates opportunities to better serve consumers, it also calls on policymakers to ensure that consumers are even further protected. AMICE welcomes the opportunity to provide feedback to the European Commission’s call for evidence on open finance framework and data sharing in the financial sector.

Open finance, if designed with the right framework, has the potential to positively impact both consumers and insurers. However, it is important to get the framework right, so that the potential can truly be achieved. This raises important considerations in relation to consent management, the scope of the data sharing and ensuring a level playing field among market participants.

The European Banking Federation (EBF) welcomes the opportunity to comment on the European Commission’s Call for Evidence on an “Open Finance Framework – enabling data sharing and third-party access in the financial sector.” A European data economy which unlocks new opportunities for customers – individuals and firms – through increased data sharing is a priority that the European banking sector welcomes in the…

The German Banking Industry Committee (GBIC) welcomes the opportunity to respond to the call for evidence on the European Commission’s open finance framework initiative. The following comments supplement our response to the Commission’s targeted consultation on 5 July 2022.

Of the policy options in the Inception Impact Assessment, DIGITALEUROPE supports the promotion of market-driven standardisation to address the existing technical obstacles to data reuse without introducing any new data access rights.

Data protection and respecting the GDPR principles need to be the focus of any initiative in the data sharing area especially as data literacy amongst consumers is still at a low level. It’s vital to ensure that the customer understands which consents they approve and to whom and on a regular basis receive an update of said consents and how to manage these.

We welcome the EC’s data strategy and its commitment to creating a single market for data that will constitute a potential source of growth and innovation. Recognizing the leading role of the financial sector in the overall digital transformation of the economy, the EC’s ambition to promote data-driven innovation through an EU financial data space is also understood.

Zurich Insurance favors the policy option introducing new data access rights in a limited number of areas. Data sharing within the financial sector and across sectors should be driven by clearly defined consumer propositions and use cases, providing the basis for determining specific rights and obligations.

I think it is the wrong way to soften data protection regulations more and more and at the same time to complicate the handling for the user for legal compliance. I refer to the GISAD statement on the Digital Euro at https://ec.europa.eu/info/law/better-regulation/have-your-say/initia- tives/13392-A-digital-euro-for-the-EU_en

Finance Finland (FFI) supports efforts towards fair data sharing in which the treatment of different players is based on a true level playing field and reciprocity. The focus of opening up data should not be solely on the financial sector, but broadly on all sectors of society. Data access, sharing and usage should be considered in a broad context, with focus on cross-sectoral data sharing, i.e. the data economy.

We propose to introduce an obligation to undergo a licensing process for the actors who are granted access to the data to ensure that it is genuine actors based on cybersecurity and suitability. It is not possible for the consumer/business to assess before accepting the disclosure of information.

Filed in Swedish · English published by the European Commission

Background We develop software and hardware to open doors (gate, door, etc.). The customer opens a port by scanning the QR code attached to the object. Payment is then made by payment card or in Sweden also by Swish. Our desire In order to further streamline the above technical solutions, we need access to the banking transaction when it occurs, i.e. in real time.

Filed in Swedish · English published by the European Commission

SMEunited supports all initiatives, which facilitate access to finance of SMEs. Improving access to data can improve access to finance from third parties. However, for SMEs it is important to control access to their data. This means, even if SME data are stored at a platform or similar locations, the SMEs must have control over who can access them.

Slovak consumers provide this feedback through the SPOTREBITEOV SR and the AVES Association and express their absolute disagreement. Given the current and persistent unfair trading practices in the financial sector in the Slovak environment, open finance cannot reasonably be expected to have an overall positive societal impact.

Filed in Slovak · English published by the European Commission