Open finance, which lets customers securely share their data with third parties, now extends across payments, banking, insurance, investments, and a wide range of services. Many hope that by facilitating a level playing field among providers, and improving the choice, quality, and convenience of available financial services via responsible customer-permissioned data sharing, open finance will serve to accelerate financial inclusion.

AFI member central banks and financial regulators have identified four approaches to data sharing ecosystems: open banking, open finance, open API, and open data. A recent member survey revealed that 85% of respondents were taking some form of action in this area. While most action is at early stages (52% of survey respondents are conducting feasibility assessments, and only four percent have fully implemented open finance frameworks), respondents cited a number of anticipated financial inclusion benefits, including:

• Enhanced competition
• Enhanced customer choice
• Expanded access to tailored financial products
• More innovation
• More collaboration between traditional and non-bank institutions
• Improved trust in the financial ecosystem

Recommendations, but no roadmap

In January 2025, AFI published a Policy Development and Implementation Guide for Inclusive Open Finance, developed with insights from our Digital Financial Services Working Group, and grounded by survey data from our members.

The intention was not to set out a definitive roadmap (“do X, then Y, then Z”), but rather to set out some guiding policy principles, based on real-world insight and practical experience, which would help countries design and implement open finance policy interventions or initiatives.

These guiding principles include:

One size doesn’t fit all: for open finance to be successfully implemented, approaches must reflect, and be tailored to, a country’s context, and to the maturity of its financial services sector.

Take a horizontal, not vertical, view: Open finance benefits from an ecosystem approach which allows solutions to emerge and interconnect, and facilitates collaboration, across an entire industry, rather than in vertical siloes. This benefits the many, not the few.

Recognize the major challenges: Regulators trying to implement open finance frameworks have encountered two broad categories of challenges:

• Ecosystem challenges, such as data privacy and protection concerns, the lack of a clear regulatory framework, consumer trust and education issues, and the lack of necessary digital infrastructure.
• Implementation challenges, such as limited technical capacity, lack of interest from industry actors, limited technical infrastructure, and lack of resources.

A growing body of collective, global insight

AFI’s Policy Guide is a non-prescriptive framework. It leaves policymakers space and leeway to select and adapt their approach, according to country conditions.  It does, however, propose five core policy components, following observations of what has worked around the world. These are:

• Governance structures
• Ecosystem design
• Policy provisions
• Data sharing, APIs, and security specifications
• Implementation and monitoring 

The Guide explores about what good policy might look like for each of these pillars. Before embarking on policy development, however, the Guide advises conducting a comprehensive readiness assessment of both internal and external factors, in order to understand the current regulatory environment, ecosystem dynamics, and market readiness for open finance.

AFI’s Guide is not intended as ultimate wisdom, but rather as a living document. It will be enriched and adapted in line with countries’ experiences, and as our collective understanding grows about open finance’s role in building an inclusive, sustainable, resilient financial landscape.

We are still in the early stages. But from what we have seen so far, the signs are positive, suggesting that flexible, country-led approaches to open finance can indeed deliver breakthrough financial inclusion gains.

Equally, data sharing frameworks such as open finance will play a key role in accelerating competition in financial services, an issue which AFI’s Competition Enablers Knowledge Exchange (CKX) is studying closely.

We look forward to seeing where open finance goes next, and where inclusion goes with it.