The Bank for International Settlements doesn’t do hype. When it publishes a working paper on open finance, it’s worth reading carefully – not for the optimism, but for the honesty.
BIS Papers No. 168 , published in March 2026, draws on international evidence from across the G20 to assess where open finance is working, where it isn’t, and what has to be true for it to scale. The findings are broadly positive. They’re also clear-eyed about what the ecosystem still gets wrong.
Five passages stood out to us. Not because they’re surprising – but because they say plainly what the industry has been circling around for years.
- BIS on open finance risk: “Risks include cyber threats, privacy breaches, data misuse, algorithmic bias, market concentration and unclear accountability that can undermine consumer protection and ecosystem stability if not governed effectively.”
Invela’s view: Open finance doesn’t govern itself. The value is real — so is the risk. Network infrastructure that embeds trust from the start isn’t a nice-to-have. It’s what makes the ecosystem safe to scale.
- BIS on why standards matter: “Mandating well-defined technical standards is a prerequisite for scalable and interoperable open finance.” In jurisdictions with minimal or absent regulation, “there can be slower adoption and higher compliance costs for firms as they navigate inconsistent standards and limited coordination.”
Invela’s view: The BIS is talking about technical standards. But the same principle holds across every layer of the ecosystem. Without consistent standards for accreditation, risk assessment and accountability, every participant still navigates alone — higher costs, slower adoption, more friction. Consistency isn’t just a connectivity problem. It’s a trust problem. And it has to be solved at network level.
- BIS on liability and accountability gaps: “Advancing open finance policies requires regulatory clarity, resilient infrastructure and institutional coordination.”
Invela’s view: Legislative clarity creates the framework. Regulatory clarity sets the rules. But the market has to build the infrastructure that makes it real. All three have to move — and they have to move in sync.
4) BIS on asymmetric risk: “Banks are mandated under regulations like PSD2 in the EU to share customer financial data with third-party providers… However, non-banks, fintech companies or big techs are not subject to equivalent obligations.”
Invela’s view: If obligations only flow one way, so does liability. Open finance needs a risk management layer that covers the whole network — not just the institutions already required to participate.
5) BIS on lack of trust as a blocker: “Willingness to share data remains limited even when benefits are clearly presented… only 27% indicated that they would share data to obtain those benefits.”
Invela’s view: Even when the benefits are clear, most people won’t share their data. Adoption doesn’t fail because of technology. It fails because trust hasn’t been built into the system. That’s the problem Invela exists to solve.
The BIS paper ends with a call for “resilient, inclusive and trustworthy open finance ecosystems that balance innovation with consumer protection and market integrity.” That’s not a vision statement. It’s a design requirement.
The infrastructure that meets that requirement doesn’t emerge from good intentions or regulatory mandates alone. It has to be built — deliberately, at network level, with risk management and accountability embedded from the start.
That’s what we’re building.
