Does the EU have open banking?
Yes — the EU has open banking through the Payment Services Directive 2 (PSD2), which came into force across EU member states from 2018. PSD2 gave consumers the right to share bank data with authorised Third Party Providers (TPPs) and enabled payment initiation services. However, EU open banking has been widely regarded as less successful than the UK’s CMA-mandated model due to inconsistent API implementation across banks and member states.
How does EU open banking differ from the UK’s framework?
The UK’s open banking model was mandated by the CMA in 2016 with a single technical standard (built by Open Banking Ltd) that all nine mandated banks had to implement. The EU’s PSD2 framework allowed banks to choose their own technical approaches, resulting in hundreds of different API implementations across 27 member states. This fragmentation made it harder for TPPs to build scalable pan-European services, contributing to underperformance relative to the UK.
Why are open banking models in Europe underperforming?
The main reasons for European open banking underperformance are: inconsistent API quality across banks, no single mandated standard equivalent to the UK’s, limited payment initiation adoption by consumers, and fragmentation across jurisdictions. The European Banking Authority (EBA) has acknowledged these challenges. The EU is addressing them through PSD3 — the third Payment Services Directive — which introduces stricter API quality standards and aims to create a more effective open banking environment by 2026.
Open Banking in Practice: Post-Brexit, the UK is developing its own open banking framework independently through JROC, diverging from the EU’s PSD3 approach. Some UK-based open banking providers are navigating both frameworks simultaneously as they expand into EU markets. The UK’s relative success in open banking has been cited by regulators in Australia, Brazil, and the US as a model for their own frameworks. Read our analysis of global open banking on openfuture.world.
FAQ
Which EU countries have the most developed open banking?
Germany, France, and the Netherlands have the most active open banking ecosystems within the EU, though all lag behind the UK in TPP activity and consumer adoption.
Is PSD3 the same as open banking?
PSD3 is the EU’s updated open banking directive, replacing PSD2; it introduces stricter API standards and new payment initiation rights, moving the EU closer to the UK model.
Which country in Europe is easiest to open a bank account?
Germany, the Netherlands, and Estonia have strong digital banking infrastructure; N26, Revolut, and Wise offer easy account opening across most EU countries.