Thought Leadership | Banking and Financial Services

Simplifying regulatory navigation in open banking

From screen scraping to FAPI-grade APIs: how FIs can build compliant, scalable open banking platforms without slowing innovation.

Download as PDF 8th May, 2024
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Open banking promises new revenue and richer customer experiences. But for financial institutions, navigating a fragmented regulatory landscape while keeping pace with fintech rivals is the harder problem to solve.

Open banking today:

  • Screen scraping still dominates data collection in the US and Canada, creating serious credential-sharing security risks for consumers and institutions alike.
  • The FDX standard, adopted by nine of the top 10 US banks, is shifting over 12 million customers from screen-scraping to secure, standardized API access.
  • The CFPB’s 2023 personal financial data rights proposal signals a coming regulatory framework that will reshape how FIs collect, share, and protect consumer data.
  • Embedded finance and SME banking represent the most underexplored value-added use cases available through open banking APIs today.

The road to open banking – a look back in time

Open banking didn’t arrive fully formed. Its origins trace back to the early 2000s in the EU, where the Payment Services Directive (PSD2) laid the legal groundwork for a new payments era, one that forced banks to share customer data with authorized third parties through standardized open banking APIs. Fintech companies seized that opening fast. Customer-centric banking models followed, and traditional institutions responded with banking-as-a-service offerings of their own.

Retail consumers and SMEs began feeling the difference through products they hadn’t had access to before. But in North America, the story took a different turn. Screen scraping, not APIs, became the dominant method for data aggregation, and it remains prevalent across the US and Canada today. The security implications are real: customers sharing banking credentials with unregulated third parties creates exposure that regulators can no longer ignore.

The Financial Data Exchange (FDX), introduced in 2018, shifted that trajectory. Nine of the top 10 US banks have since adopted FDX open banking standards, bringing over 12 million customers off screen scraping and onto API-based data sharing. That’s not incremental progress. It’s structural change. The Consumer Financial Protection Bureau’s 2023 proposal on personal financial data rights accelerated momentum further, signaling that open banking solutions in the US are moving from voluntary adoption to regulatory expectation. Bank-fintech partnerships are now the natural outcome, and consumer control over data has become the new baseline.

Driving momentum toward the road ahead

Regulatory comprehension sits at the center of every open banking decision FIs face today. The challenge isn’t just keeping pace with new mandates; it’s translating dense, jurisdiction-specific requirements into architecture choices and product roadmaps that hold up under scrutiny. That translation work is where most institutions lose time and money.

Screen scraping illustrates the tension well. It remains the dominant data-collection method across North America, yet financial regulators are actively working to replace it with standardized open banking API frameworks that meet high-grade security demands. Nine of the top 10 US banks have already adopted FDX open banking standards, pulling more than 12 million customers away from credential-sharing models. The direction is clear. What’s less clear, for many FIs, is how to move at enterprise scale without compromising compliance or blowing the budget.

The priorities ahead are sharper than they appear on the surface. Secure, FAPI-compliant API infrastructure, enterprise-grade consent management, and a flexible open banking platform architecture capable of supporting embedded finance and SME banking use cases represent the immediate agenda. Modular, cloud-agnostic design isn’t a preference at this point; it’s an operational requirement for any institution pursuing open banking solutions that need to scale and adapt as regulations shift.

And AI-powered data governance is entering this equation faster than many anticipated. Digital transformation with AI now sits alongside compliance as a capability FIs can’t treat as separate workstreams. Getting both right, together, is the actual challenge.

Addressing open banking’s regulatory hurdles

Three pressures sit at the core of every open banking conversation today. Build APIs secure enough to satisfy regulators. Create an ecosystem where third-party developers can actually build on those APIs. And manage customer consent in a way that’s both legally airtight and genuinely usable.

None of these is simple in isolation. Together, they define the hard edge of open banking compliance.

Start with the API question. Financial-grade API standards exist precisely because standard API security isn’t sufficient for banking data. Meeting those standards demands more than good intentions from an engineering team; it requires a purpose-built open banking platform that’s cloud-agnostic, auditable, and designed to evolve as regulatory expectations shift. That’s a meaningful engineering investment, and it has to work before any third party touches a single endpoint.

The marketplace problem is different but equally real. A locked-down API that no one can discover, test, or build on isn’t open banking. It’s just an API. FIs need a structured environment where developers can subscribe, sandbox, and validate integrations without exposing production systems. Getting this right is what separates open banking solutions innovation from open banking as compliance theater.

Consent management may be the hardest challenge of all. The CFPB’s proposed personal financial data rights rule signals where regulation is heading in the US: structured, timely, and revocable access to data, with hard limits on how third parties collect and retain it. FIs that treat consent as a checkbox will find themselves rebuilding from scratch. Those who treat it as infrastructure, baked into identity federation and access control from the start, build something that compounds in value.

An open banking playbook addressing the three regulatory gaps

Three regulatory gaps sit at the heart of every open banking implementation: securing APIs against evolving threats, building a consent management layer that satisfies both regulators and customers, and creating an API marketplace that third-party developers can use. Each one is solvable. None of them should be solved in isolation.

Our open banking playbook addresses all three through a cloud-agnostic, open-source architecture built for financial institutions that can’t afford to move slowly. The foundation is a templatized deployment model that cuts three to five months off development timelines, letting banks reach market before the regulatory window shifts again. That speed matters when open banking compliance innovation and payments modernization are moving targets, not fixed destinations.

But speed without security is just exposure. The consent management layer, built on Red Hat Keycloak, supports user federation from any identity provider and implements financial-grade API standards end to end. FIs get enterprise-level consent controls without building from scratch. And because the architecture is cloud-agnostic, banks aren’t locked into a single infrastructure provider when open banking platform requirements evolve.

For FIs already navigating digital transformation with AI on the horizon, this matters beyond compliance. An open cloud-native architecture is the prerequisite for embedding generative AI, agentic automation, and data modernization capabilities into banking services later. The open banking playbook isn’t just a compliance tool. It’s the engineering foundation that makes everything else possible.

Driving open banking with a cloud-native architecture

Think about what actually slows open banking adoption down. It’s rarely a lack of ambition. It’s architecture that can’t flex fast enough, consent systems bolted on as afterthoughts, and APIs that meet yesterday’s security standards while regulators are already drafting tomorrow’s. Our open banking solution addresses each of these pressure points head-on, built on an open cloud-native architecture designed from the ground up to give banks and financial institutions speed, security, and real configurability.

At its core, the solution combines five integrated components: a financial-grade API marketplace, consent management with FAPI enablement, standardized banking APIs, mock data for safe testing environments, and cloud deployment templates that cut time to market by three to five months. No proprietary lock-in. No opinionated cloud dependency. Just a templatized, cloud-agnostic foundation that FIs can adopt, customize, and scale on their own terms.

What makes this architecture distinct is how it treats consent and security not as compliance checkboxes but as structural priorities. Red Hat Keycloak handles enterprise-level consent and user federation, while financial-grade API standards ensure the kind of high-security access controls regulators now expect. The result is an open banking platform capable of supporting embedded finance, open finance use cases, and new open banking payment solutions without requiring a complete infrastructure rebuild each time the regulatory landscape shifts. Banks that want to explore open banking solutions innovation, monetize services through third-party developer ecosystems, or strengthen open banking compliance can do all three from the same foundation. Built to accelerate. Engineered to deliver.

Implementing an end-to-end open banking solution

Think of it as construction, not configuration. Building a production-ready open banking solution means sequencing work carefully across three distinct phases, each with its own risk profile and technical demands.

In the first two weeks, the focus is establishing a secure sandbox and completing an API security assessment. Fast, but non-negotiable. Without a validated security baseline, everything downstream carries unnecessary exposure.

Weeks four through six shift into infrastructure engineering: CloudFormation templates, network architecture diagrams, automated deployment pipelines, and IAM role configuration governed by the principle of least privilege. Documentation isn’t an afterthought here. Every configuration parameter, dependency, and troubleshooting step gets captured, because open banking compliance requires auditability at every layer.

The full implementation runs three to six months and covers the capabilities that actually matter to customers and regulators alike: user registration, authentication, authorization, and consent management through Red Hat Keycloak. Consent isn’t just a legal checkbox; it’s the mechanism that makes open banking payment solutions trustworthy. Transaction history retrieval from linked accounts and mobile app deployment via AWS Amplify round out the build, giving financial institutions a cloud-agnostic architecture that’s ready to publish into an enterprise-level API marketplace from day one.

For FIs serious about open banking solutions innovation, this phased approach cuts 3-5 months off typical development timelines while keeping security architecture and regulatory compliance intact throughout.

The numbers behind our work

Numbers tell one story. The work behind them tells another. Across three distinct open banking engagements, Our digital transformation consulting approach translated architectural decisions into outcomes that FIs could actually measure.

Take the mobile-first digital bank we built from the ground up. A five-layered security and API gateway sat at its core, validating service access across every node in the bank’s ecosystem. The result: $150 million added to assets under management and a 23% lift in operational efficiency. Not incremental. Foundational.

Then there’s the payments experience we re-engineered. What started as a proof of concept grew into production-grade open banking API infrastructure, integrated directly with merchant kiosks. Shoppers enrolled once, checked out faster, and spent more frequently. Time spent at the kiosk dropped by 75%. That’s the kind of frictionless outcome that open banking solutions are actually capable of delivering, when the engineering is done right.

The third engagement gets at something broader. A legacy online banking platform, rebuilt on microservices architecture with an API-first approach across multiple Oracle Flexcube modules. The payoff: 85% automation coverage across bank workflows and 30% faster time to market for new features. For any enterprise serious about open banking compliance innovation and payments modernization, that speed-to-market advantage compounds quickly. Each of these engagements reflects a consistent conviction: that well-engineered open banking platforms don’t just meet regulatory demands, they create durable competitive advantage.

Building the foundation for open banking

Think of open banking not as a product launch but as an infrastructure commitment. Before any API goes live or any fintech partnership gets signed, FIs need a clear-eyed assessment of where their current architecture stands and what it takes to meet evolving open banking compliance standards without stalling innovation.

That’s the work Brillio brings to the table. Our open banking practice sits at the intersection of digital transformation consulting and financial engineering, helping banks and financial institutions design cloud-agnostic, modular foundations that can absorb regulatory change without requiring full rebuilds. From evaluating your technology stack against open banking solutions best practices to implementing enterprise-level consent management, each step is engineered to reduce time-to-market while building long-term resilience.

Scalability isn’t an afterthought here. Brillio’s open-source cloud-agnostic architecture supports templatized deployment that cuts 3–5 months off typical development cycles, so FIs can move from sandbox to production with confidence. And because open banking platforms must earn trust on multiple fronts, security standards like FAPI enablement and SR 21-14 authentication are built directly into the foundation, not retrofitted later.

The momentum compounds. Each milestone, whether that’s publishing APIs in an enterprise-level marketplace or standing up real-time consent flows, builds toward a fully realized open banking ecosystem. For institutions ready to move from reactive compliance to proactive competitive positioning, that foundation is where everything begins.

Key actions for financial institutions entering open banking:

  • Audit your current infrastructure against FDX and FAPI standards before committing to an open banking architecture build or vendor selection.
  • Prioritize consent management from day one: regulatory compliance and customer trust both depend on how well you capture, store, and validate data-sharing permissions.
  • Choose a cloud-agnostic, open-source architecture to cut three to five months off development time and avoid long-term vendor lock-in.
  • Treat the API marketplace as a revenue asset, not just a developer tool: monetizing banking services APIs through embedded finance is where the real upside lives.
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