Eight open finance risk questions every chief risk officer and compliance lead should be asking in 2026

Louise Beaumont
May 27, 2026
5 min read

The panel on 3 June at Money20/20 Europe isn’t going to settle the regulatory debate. What it will do is force some harder questions about what firms are actually doing to manage open finance risk - not in theory, but in practice.

Before the panel, here’s the Open Finance Risk Readiness Checklist:

  1. Do you know how many third, fourth and nth party providers are currently accessing your customers’ data - not at onboarding, but right now?
  2. Regulators govern vertically. Your customers’ data moves horizontally. Does your risk management approach cover all the segments it crosses?
  3. Are you relying on aggregators to manage the risk of third-party providers in your chain, and have you verified whether they have the ability to do that, and do it continuously?
  4. Is your third-party risk monitoring continuous, or only point-in-time? If a fintech in your network suffered a breach today, or mis-used data, how quickly would you know?
  5. Does your risk framework hold if the regulatory framework stalls or fragments?
  6. Have you mapped the liability chain in your open finance model - including who bears the risk in the parts of the chain you don’t directly control?
  7. Is your compliance posture the floor or is it the ceiling? The firms moving fastest are building beyond regulatory minimums now.
  8. Could you answer all seven questions above in a board-level conversation tomorrow? If not, which gaps would you highlight first?

No answers yet - those come on 3 June. Agnieszka Scott, Michael Salmony, Todd Clyde and Louise Beaumont. Horizon Stage. 12:15. Save this checklist. We’ll return to it in the post-event report.