Insights
March 20, 2026

Open finance is scaling - but the risk model isn't keeping up

Open finance is scaling - but the risk model isn't keeping up
Short answer

The open finance risk model hasn't kept pace with ecosystem growth. Invela sets out the structural change needed before AI-driven participants arrive.

Key takeaways

  • Screen scraping gave way to APIs, APIs multiplied the participants, and AI is about to multiply them again.
  • When something goes wrong in the chain between bank, intermediary, fintech and end-consumer, everyone points somewhere else: a governance problem, not a technology one.
  • The risk is a stack, and most organizations in open finance manage only part of it.
  • Four US open finance leaders at the FDX Global Summit mapped what the risk is, where liability should sit and what it takes to fix the current model.

Data now moves through more systems, more business models, and more hands than anyone designed for. Screen scraping gave way to APIs. APIs multiplied the participants. AI is about to multiply them again.

And somewhere in that chain - between the bank, the intermediary, the fintech, and the end-consumer or business - something goes wrong.

When it does, everyone points somewhere else.

That's not a technology problem. It's a governance problem. And it's the question that keeps general counsel, chief risk officers, open finance leads and regulators awake at night - because the existing frameworks weren't built for this world.

The risk isn't one thing. It's a stack. And most organizations operating in open finance today are only managing part of it.

At the FDX Global Summit, four of the sharpest minds in US open finance - a banker, a lawyer, an intermediary & third-party provider, and an infrastructure provider - sat down to map it properly. What the risk actually is. Where liability should sit. Why the current model has already broken down. And what it will actually take to fix it.

The debate was unvarnished. The conclusions were uncomfortable. And the framework they arrived at has direct implications for every bank, credit union, intermediary, and fintech operating in the ecosystem today.

Download the report to find out what they said.

Download report

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Louise Beaumont
Written by
Head of Marketing, Communications & Design

Louise Beaumont leads marketing, communications and design at Invela, with 30+ years in tech and fintech and 15+ in open banking and open finance.

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