Open Finance in International Comparison – Insights for Switzerland
In the first part of this blog series, Stefan Knaus provided an overview of the current state of Open Finance in Switzerland. In this article, we look beyond Switzerland’s borders and ask: How far along are other countries in implementing Open Finance? What lessons can be learned from international initiatives? And above all, what recommendations can be derived for the Swiss financial center to remain competitive on a global scale?
Why an international comparison is useful
Open Finance is not just a Swiss topic, nor is it limited by national borders. Instead, global standards, platforms, and regulatory frameworks are emerging to shape how financial data will be shared, leveraged, and monetized in the future. A survey by Konsentus revealed that by the end of 2023, more than 65 countries – about one-third of all nations worldwide – had launched national open banking initiatives, advanced Open Finance or Open Data projects, or were actively developing them (see Figure 1) [1,2].
The opening of financial data has moved beyond being a regional experiment and has become a global trend that is fundamentally transforming the financial industry. For Switzerland, this presents an opportunity to learn from international developments and best practices in order to strengthen its own competitiveness.
Source: Konsentus 2023 [2]
International momentum and success models
Brazil – Open Finance as an accelerator
Brazil has built an impressive Open Finance ecosystem in just a few years. Since 2020, the Central Bank has been driving Open Finance Brasil, an initiative that extends beyond traditional payments to encompass loans, insurance, and investment products. A consortium of more than 80 financial institutions ensures unified API standards and registries, greatly supporting scalability.
Adoption has grown rapidly: in 2023 more than 51.9 billion API calls were recorded, and in 2024 this volume doubled to over 102 billion. In parallel, the number of active data-sharing consents rose from about 42.1 million at the end of 2023 to 56.8 million by the end of 2024. Banks also report that expanded data exchange has significantly improved the precision of credit decisions. The Brazilian case illustrates how regulatory clarity and consistent standardization can create a dynamic Open Finance market within a short period of time [3].
United Kingdom – Pioneer with a clear governance structure
The United Kingdom was the first country to mandate open banking through regulation in 2018. The creation of the Open Banking Implementation Entity provided a neutral body to develop standards, define security profiles, and maintain a central register. Today, more than 13.5 million individuals and businesses actively use open banking services, with nearly two billion API calls processed each month [4]. Notably, the growth in open banking payments has seen transaction volumes increase by 60 percent in just one year. With the 2025 Data (Use and Access) Act, the government is now extending the model to additional sectors such as energy and retail, paving the way toward a comprehensive smart data economy. The UK example demonstrates the importance of centralized governance and coordination for success [4–7].
European Union – NextGen PSD2 as a global standard
The European Union laid the groundwork for open banking in 2018 with the revised Payment Services Directive (PSD2), establishing a framework for standardized interfaces within the financial sector. Today, more than 3,600 banks across Europe provide APIs for the secure exchange of financial data. At the core lies the Berlin Group framework, which has become the de facto standard across Europe and is also widely applied internationally. Globally, more than 2,500 API products are now based on this standard, meaning that Europe accounts for nearly half of the world’s open banking offerings [8,9]. With PSD3, the Payment Services Regulation (PSR), and the Financial Data Access Regulation (FiDA), the regulatory framework is being expanded considerably. In the future, not only bank accounts but also loans, insurance products, and pension plans will be included. A new permission dashboard will give customers more transparency and control over their data consents. The EU demonstrates how regulatory requirements can be continuously developed to harmonize a complex internal market while simultaneously setting international benchmarks [9–12].
Singapore – Market-driven model with state infrastructure
Singapore has pursued a hybrid model for years, combining government support with market-driven momentum. As early as 2016, the Monetary Authority of Singapore (MAS) and the Association of Banks in Singapore (ABS) published an API Playbook, which provided hundreds of interfaces for banks and fintechs to build upon. In 2020, SGFinDex was launched, a platform allowing citizens to consolidate their bank, insurance, and pension data using their national digital identity, SingPass. By the end of 2024, around 400,000 people were using this service. Its success is based on trust, user-friendliness, and the state’s role as an infrastructure provider. Singapore demonstrates impressively how Open Finance can achieve broad adoption without regulatory mandates [13–15].
Australia – Ambition with early challenges
Australia introduced the Consumer Data Right to create a particularly comprehensive framework that would link banking, energy, and telecommunications [16]. Expectations were high, but results have so far fallen short. By the end of 2023, only 0.31 percent of bank customers were actively using the system, and many data-sharing agreements had not been renewed. Challenges include low consumer awareness, high implementation costs for providers, and a lack of compelling use cases [17]. Nevertheless, studies estimate the model’s long-term economic potential at more than AUD 16.7 billion [16]. To realize this, the government is focusing on relevant use cases and lowering entry barriers [18]. The Australian case underlines that regulation and state support alone are insufficient if customer benefits are not clear and tangible.
Lessons for the Swiss financial center
The different models show that there is no single path to success. Brazil and the United Kingdom highlight the strong impact of clear regulatory direction, while Singapore demonstrates that market-driven approaches can also succeed when supported by state infrastructure and clear guardrails. Australia, on the other hand, serves as a cautionary example, showing that regulation alone remains ineffective if customer value and acceptance are not at the forefront.
For Switzerland, this implies that the current voluntary approach will only be sustainable if it is complemented by common standards, binding roadmaps, and overarching market coordination. It will also be crucial to develop applications early on that deliver visible benefits to customers. Multi-banking solutions, transparent pension dashboards, or smart budgeting tools could build acceptance and trust in Open Finance.
Another key factor could be the introduction of a state-backed e-ID in 2026, which – similar to SingPass in Singapore -could become a central enabler for trust and usability. Finally, international interoperability must not be overlooked. Open Finance should not be limited by national borders but understood as a cross-border ecosystem. It is already evident that the standards of Switzerland’s European neighbors will play a decisive role in the long term.
Outlook
This marks the end of the second part of our blog series on Open Finance. While Stefan Knaus explored the situation in Switzerland in the first article, here we have drawn international comparisons and translated the key lessons into concrete recommendations for the Swiss financial center.
A more detailed overview of international developments and their relevance for Switzerland will be presented in the White Paper currently being developed by OpenBankingProject.ch in cooperation with PPI Schweiz, scheduled for publication at the end of October 2025. The results will be presented at the 13th members’ event of OpenBankingProject.ch on November 12, 2025, at Ergon Informatik AG in Zurich. For questions regarding the White Paper, the event, or current developments in Open Finance, please feel free to contact Stefan Knaus and Friedrich-Philipp Wazinski.
References
1. Konsentus. One in Three Nations now on the Open Banking Journey, Konsentus Study Shows | Konsentus [Internet]. 2023 [cited 2025 Jul 3]. Available from: https://www.konsentus.com/one-in-three-nations-now-on-open-banking-journey-konsentus-study-shows/
2. Konsentus. The World of Open Banking and Open Finance: October 2023 | Konsentus [Internet]. 2023 [cited 2025 Sep 30]. Available from: https://www.konsentus.com/open-banking-world-map-oct-2023
3. Open Banking Brasil. Relatório Anual 2024. 2024;
4. Open Banking Limited. API performance stats – Open Banking [Internet]. 2025 [cited 2025 Jul 14]. Available from: https://www.openbanking.org.uk/api-performance/
5. Open Banking Limited. Adoption Analysis – The open banking Impact Report 2025 May [Internet]. 2025 [cited 2025 Jul 14]. Available from: https://openbanking.foleon.com/live-publications/the-obl-impactreport-7/adoption-analysis
6. Gov UK Department for Science I& T. Data (Use and Access) Bill factsheet: growing the economy [Internet]. 2024 [cited 2025 Jul 14]. Available from: https://www.gov.uk/government/publications/data-use-and-access-bill-factsheets/data-use-and-access-bill-factsheet-growing-the-economy
7. UK Parliament. Data (Use and Access) Act 2025 – Parliamentary Bills – UK Parliament [Internet]. 2025 [cited 2025 Jul 14]. Available from: https://bills.parliament.uk/bills/3825
8. The Global Open Data Tracker. NextGenPSD2 – Ozone [Internet]. 2025 [cited 2025 Sep 30]. Available from: https://ozoneapi.com/the-global-open-data-tracker/library/nextgenpsd2/
9. Blader RF. Open Banking Is Finally Coming To America. 2024.
10. The Global Open Data Tracker. NextGenPSD2 [Internet]. 2025 [cited 2025 Jul 14]. Available from: https://ozoneapi.com/the-global-open-data-tracker/library/nextgenpsd2/
11. The Global Open Data Tracker. Bahrain Open Banking Framework – Bahrain [Internet]. 2025 [cited 2025 Sep 8]. Available from: https://ozoneapi.com/the-global-open-data-tracker/library/bahrainobf/
12. Europäische Kommission. RICHTLINIE DES EUROPÄISCHEN PARLAMENTS UND DES RATES [Internet]. 2023 [cited 2025 Sep 30]. Available from: https://eur-lex.europa.eu/legal-content/DE/TXT/HTML/?uri=CELEX:52023PC0366
13. LUXHUB. Empowering Innovation: How Singapore’s Open Banking is Reshaping Finance – LUXHUB [Internet]. 2025 [cited 2025 Jul 14]. Available from: https://luxhub.com/empowering-innovation-how-singapores-open-banking-is-reshaping-finance/
14. Chiang S. Banks, insurers see more customers using SGFinDex for financial planning | The Straits Times [Internet]. 2025. 2025 [cited 2025 Jul 14]. Available from: https://www.straitstimes.com/business/banks-insurers-increasingly-see-customers-using-sgfindex-for-financial-planning
15. Monetary Authority of Singapore. Singapore Financial Data Exchange (SGFinDex) [Internet]. 2024. 2024 [cited 2025 Jul 14]. Available from: https://www.mas.gov.sg/development/fintech/sgfindex
16. Deloitte. Harnessing the Consumer Data Right to provide a $16.7 billion boost to Australia’s economic future | Deloitte Australia [Internet]. 2024 [cited 2025 Jul 14]. Available from: https://www.deloitte.com/au/en/about/press-room/harnessing-consumer-data-right-provide-16-7-billion-boost-australias-economic-future-110324.html
17. Australian Banking Association. Release of Strategic Review into roll-out of the Consumer Data Right – Australian Banking Association [Internet]. 2024 [cited 2025 Jul 14]. Available from: https://www.ausbanking.org.au/release-of-strategic-review-into-roll-out-of-the-consumer-data-right/
18. Jones S. Consumer Data Right expansion to deliver a better deal for consumers | Treasury Ministers [Internet]. 2025 [cited 2025 Jul 14]. Available from: https://ministers.treasury.gov.au/ministers/stephen-jones-2022/media-releases/consumer-data-right-expansion-deliver-better-deal
With a strong academic background in International Economics and Development (B.A., University of Bayreuth) and a master's degree in Strategy, Impact & Entrepreneurship (Católica Lisbon School of Business & Economics), he combines in-depth scientific expertise with practical research. During his time as an Assistant Researcher at the Blockchain Research Lab, he dedicated himself to independent scientific research into blockchain technology and its social benefits. In this context, he published several scientific papers in renowned journals, including on blockchain-based fan tokens and on digital real estate economics in the metaverse. He also analyzed the integration of blockchain technology in unmanned aerial systems, researched the motivational drivers of investors in the digital ecosystem and examined the potential of modular blockchains.
Thanks to his international experience in Norway, the Czech Republic, Hungary, Portugal and Germany, he brings an intercultural perspective to his research and consulting work.