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FIDA Open Finance

Current state of the Luxembourg market following ABBL and Deloitte survey

In June 2023, the European Commission published a legislative proposal for Financial Data Access (FIDA). Following this publication, the Luxembourg Bankers' Association (ABBL) and Deloitte launched a survey in September 2023 with the main objective of gathering the views of ABBL members while assessing the level of awareness of institutions at an early stage, their positioning, opportunities for new product development and expected challenges.

Deloitte and ABBL survey


FIDA is set to profoundly impact the financial industry by shifting toward Open Finance and introducing major changes across various aspects:

  • Customer data sharing: Data holders will be required to share a broad set of information to data users upon customer permission (including savings, loans, mortgages, investments, insurance, etc.)
  • Technical interface: Data holders will have to implement a technical interface (API platform) in order to enable data sharing
  • Permission dashboard: Data holders will have to put in place permission dashboard for customers with real-time view on access granted and ability to modify and withdraw permissions

The results of the survey indicated that two-thirds of the participants think that FIDA will represent more challenges than opportunities, including:

  1. Data management and accessibility: Ensure proper data sharing, governance and protection
  2. Risk protection and security: Enhance cybersecurity measures and limit risk of frauds
  3. Implementation: Build technical interface and permission dashboard
  4. Readiness: Adhere to financial data sharing scheme(s) 18 months after adoption
  5. Competition: Increase competition with new business models and new actors able to access strategic data about customers

39% of credit institutions are seeking to leverage on FIDA by also acting as data users to access information from other companies and industries. Countless opportunities exist for financial institutions to increase revenue, notably through:

  • New services: Foster innovation with the creation of new products and services based on data sharing
  • Cross-sell: Facilitate cross-selling and bundling of financial packages
  • Client insights: Improve client profiling and insights to get a holistic view of customer financial situation
  • Tailored offering: Allow for more tailor-made offerings, such as personalized financial advice
  • Compensation: Enable data compensation for providing access to data and API platform

What are the key highlights of the ABBL and Deloitte’s survey?


  • FIDA represents a major shift toward data sharing and Open Finance
  • Standardization across data domains and industries is foreseen to be complex
  • A challenging timeline is proposed, with 18 months to adhere to financial data sharing scheme
  • Despite recent publications, the overall level of readiness is still limited, as most participants are yet analyze in detail FIDA regulation and its impacts
  • FIDA will bring countless opportunities to increase revenue with new offerings, data compensation and innovation

Feel free to contact us if you want more information about FIDA implications, support regulatory compliance and identify new revenue opportunities.



Alexandre Havard
Partner | Advisory & Consulting
+352 45145 3148

Maxime Gaborieau
Senior Manager | Advisory & Consulting
+352 45145 3508

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