FERMA’s head of EU affairs, Charles Low, considers the risk implications and potential of the Framework for Financial Data Access and why data sharing risk must be safeguarded

You may be familiar with the term ‘open banking’, used to refer to when access to financial data is provided to third parties via the use of APIs.

But you would be forgiven for not knowing that a key driver behind open banking was regulation - the EU Payment Services Directive (PSD) and its revision, PSD2.

regulation graphic

The EU is now looking to replicate the success of open banking in other areas of financial services, including insurance.

In June 2023, the European Commission put forward a legislative proposal for a Framework for Financial Data Access (FIDA) to enable data sharing and third-party access across financial services.

FIDA is part of the broader EU Digital Finance Strategy to facilitate greater data sharing and third-party access for a wide range of financial sectors and products, in line with data protection and consumer protection rules.


FIDA establishes this data-sharing framework through the creation of Financial Data Sharing Schemes.

These are intended to bring together holders and users of data to create opportunities for third parties to turn this data into innovative products and services.

From FERMA’s perspective, what is of particular interest is that FIDA has non-life insurance in its scope.

A critical area of focus for risk managers is the need to ensure a transparent and controlled environment is maintained – with adequate safeguards – that foments the sharing by companies of non-life insurance data.

While FIDA represents an opportunity for innovation in the (re)insurance market, risk managers must highlight the importance of reassurance on how to adequately control and permit access to the shared data and on the access to data that would be useful for them.

“A critical area of focus for risk managers is the need to ensure a transparent and controlled environment is maintained”

Furthermore, FIDA brings the possibility of FERMA or its member associations being classified as a “customer organisation”, which would grant them a space in the financial data-sharing schemes established by FIDA.

As the representative of the corporate clients of insurers, FERMA advocates for innovation in the B2B market segment and believes that FIDA can be the key proposal to initiate such a process.

Improving access to relevant data will serve as a catalyst for the development of value-adding insurance products or to enhance existing insurance solutions.

Also, for it to succeed, customers must be sure their data is treated appropriately before sharing it. The quality, meaning and structure of the data shared through the envisioned mechanism by FIDA is fundamental for it to have an added value.


The deadline for submission of feedback in the sequence of the Public Consultation of stakeholders by the European Commission was 1 November.

Next up will be the political negotiations on the proposal, which will be conducted between the co-legislators.

At the level of the Council of the EU (i.e., the Member States), the working party on Financial Services and Banking Union is in charge of examining the file.

The European Parliament’s Economic and Monetary Affairs (ECON) Committee will work on the file, with the final vote on the topic scheduled for 21 March 2024.

FERMA will continue to monitor developments relating to FIDA and is supportive of any policy intervention that leads to innovation in the (re)insurance sector.