Eight years ago, the financial industry viewed PSD2 as a crushing regulatory burden. The mandate to build and maintain open APIs was projected to cost UK banks over £1 billion. It was seen as a forced opening of the gates to nimble fintech challengers.
Today, that narrative has been completely rewritten. What began as a compliance headache has become the foundational infrastructure for a new generation of financial services. The initial cost has been dwarfed by the value it has unlocked.
The core of PSD2, particularly Article 66¹, forced banks to provide access to payment accounts via dedicated interfaces. This wasn't optional; it was a mandate that created the open banking ecosystem. The technical standards for secure communication and strong customer authentication (SCA)² provided the rails upon which this new ecosystem could be built.
Institutions that embraced this early and invested in quality implementations are now reaping the rewards. They have differentiated themselves from competitors who saw it as a mere compliance exercise. They have built the infrastructure to create value for customers, not just meet a regulatory minimum.
The journey is far from over. The recent provisional agreement on PSD3 and the Payment Services Regulation (PSR)³, along with the formal inclusion of the Financial Data Access Regulation (FIDA)⁴ in the EU's 2026 work programme, signals the next evolutionary leap: from Open Banking to Open Finance.
FIDA will extend the principles of data access beyond payments to a wider range of financial products, including savings, investments, and insurance. This will create a truly holistic view of a customer's financial life, enabling a new wave of innovation in personalized financial services, automated advice, and what some are calling "agentic finance" – where AI agents act on a user's behalf to optimize their financial outcomes.
As we stand on the cusp of this new era, the lesson of PSD2 is clear: regulatory mandates that initially seem like a burden can become a powerful catalyst for innovation. The institutions that view PSD3 and FIDA with the same strategic lens will be the winners of the next decade.
The critical question for 2026 is: is your firm viewing the next wave of open finance as a compliance cost to be minimized, or as a strategic opportunity to be seized?
References
¹ Directive (EU) 2015/2366 (PSD2) ² Delegated Regulation (EU) 2018/389 (RTS) ³ Council of the EU, Provisional agreement on PSR and PSD3 (Dec 2025) ⁴ European Commission, Financial Data Access Regulation (FIDA) proposal
This article was originally published on LinkedIn.
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Solicitor | Fintech Law Specialist
Gavin is a specialist solicitor with over 25 years of experience in financial technology regulation, digital assets law, and emerging technology compliance. He advises premier financial institutions and innovative technology companies on complex regulatory matters across 33 jurisdictions.
Qualifications: PhD (Cryptocurrency & Stablecoin Policy), LLM (Commercial Law), Solicitor of England & Wales
Experience: £750M+ transaction value | 33 jurisdictions | Trusted adviser to Morgan Stanley, American Express, Visa, Citibank, and leading fintech innovators
Evolution of payment infrastructure and regulatory challenges