Benchmarking Open Banking Reforms Around the World

Ten years after the first open banking regulations were enacted, it is now possible to compare the results of those law reforms in different jurisdictions. An assessment of progress towards open banking in the European Union, United Kingdom, United States, Australia, Hong Kong, India and China reveals a paradox: jurisdictions that regulate less have made more progress in providing end users with new financial services, while jurisdictions that have imposed top-down mandates have made digital transformation more difficult for financial institutions to achieve. American financial institutions and American regulators can draw a few lessons from the decade of experience with open banking regulations around the world. These include the essential role of voluntary industry collaboration, the need to harmonize entrepreneurship with compliance, and challenges of remaining connected to customers through rapidly changing communication channels and interfaces. The current status of legal challenges to Consumer Financial Protection Bureau efforts to enact open banking regulations will be analyzed in light of those lessons.