The German Banking Industry Committee (GBIC) supports in principle a Framework for Financial Data Access that exploits the opportunities of the data economy for European consumers, businesses and the EU economy as a whole. The top priority is therefore that FIDA creates a secure infrastructure for sharing customer data, takes into account customer and market needs, and promotes fair competition for open finance. In this regard, the present Commission draft for open finance is in parts too ambitious to be successfully implemented under the formulated regulatory requirements and the given implementation deadline. We therefore advocate a step-by-step approach with successive expansion of the scope of FIDA, which should be subject to evaluation and possible adjustment before each further expansion stage. This is the only way to gain the necessary experience and avoid difficulties that would stand in the way of the legislators intentions in the long term.
