PaymentsPedia recently reviewed a paper by Douglas Arner Ross Buckley, Dirk Zetzsche, Christine Menglu Wang, that explores the evolution of Open Banking, Open Finance, and Open Data globally.
The paper presents a powerful argument: Open Finance is no longer just about APIs and regulatory obligations. It is becoming a cornerstone of national digital public infrastructure (DPI) — alongside identity systems, payments rails, and data-sharing frameworks.
Key Takeaways:
- Open Finance is moving from voluntary to mandatory frameworks.
- It is expanding beyond financial data into cross-sector open ecosystems.
- Governments must build shared infrastructure — not just mandate data access — to drive innovation, inclusion, and sustainable development.
The paper compares models from India, Brazil, Australia, Singapore, and the EU, offering valuable insights into different regulatory and infrastructure approaches.
PaymentsPedia’s Critical Perspective:
While the paper makes a compelling case for infrastructure-driven Open Finance, several critical risks require deeper attention:
- Data Monopolization: Dominant players could still centralize control despite open frameworks.
- Cybersecurity Vulnerabilities: Wider data access increases systemic securitySecurity security Measures used to protect transaction data from fraud and cyber threats. risks.
- Cross-Border Fragmentation: Differing country approaches risk creating friction and regulatory arbitrage.
- Consent Fatigue: Consumers could disengage from meaningful consent, weakening trust.
Moreover, while the case studies are rich, greater use of real-world adoption data (e.g., uptake rates in Australia’s CDR or India’s AA network) would have grounded the paper’s insights even further.
📄 Read the full paper: Building Open Finance: From Policy to Infrastructure

Vibhu is a global payments leader and PhD researcher in real-time payments, dedicated to making payments simpler, smarter, and more inclusive. With 20 years of payments experience across Citibank, Adyen, IKEA, Snapdeal, iPayLinks — and markets spanning India, China, Southeast Asia, Europe, and Australia— he brings a truly global perspective to the future of money. Vibhu is also the founder of PaymentsPedia.com, a knowledge hub where he shares insights on cards, crypto, cross-border flows, and real-time rails.📧 vibhu@paymentspedia.com | LinkedIn