November 2023
The Swiss Finance Council believe that FIDA has the potential to unlock data sharing between wealth management firms, WealthTech firms and other service providers within the EU.
However, it is key that FIDA ensures a fair and secure data ecosystem that adds value to consumers and end users. We welcome that the management of the access to customer data will be left to market actors through the setting-up of financial data sharing schemes, while ensuring financial incentives and a level playing field for data holders.
We welcome a clarification of the scope of the proposed mandatory customer data access rights, and in particular support limiting the access rights to retail and SME customer categories and corresponding data. A staggered approach to the introduction of client types for data sharing would also allow to manage implementation costs and focus on key use cases first.
More broadly, we would support the adoption of a gradual approach to development of data sharing schemes based on customer demand. A focus on real added value use cases would reduce the significant implementation costs for data holders, as they will not be compensated for building the necessary technical infrastructure, modalities and standards to share their data with data users when there is no real demand by customers.
Finally, we would support minimum API standards and security requirements to help open finance scale. We also support the introduction of a clear and fair liability regime, which would provide guarantee legal certainty and help gain trust of customers to share their data with financial information service providers