How AI can unlock Open Finance
The OECD identifies AI and Open Finance as two of the most influential trends in global…
The wait is nearly over. The European Parliament and EU Council have provisionally signed off. Soon, the work to move from PSD2 (Payment Services Directive 2) to PSD3 (Payment Services Directive 3) and PSR (Payment Services Regulation) can begin.
This evolution is good news for consumers and businesses – they’ll both benefit from wider data sharing, better fraud prevention and more interoperability between EU banks.
But what does this actually mean? In this article, we’ll explain the EU’s Open Banking journey and what you need to do to get ready for the new regulations.
PSD3 is the EU’s Open Banking legislation. It’s an update on PSD2, which launched in 2018 and changed the way money moves in Europe. PSD2 drove instant digital payments, fintech innovation, and customer-centric financial services. PSD3 will take things even further by elevating transparency, reinforcing data security, and strengthening consent management.
You may be wondering, then: why is it needed? Well, PSD2 has had “mixed success” in its uptake (the European Commission’s words, not ours). According to the most up to date figures, In 2024 Europe accounted for 31.3% of the global Open Banking market and had more than 64 million users in the EEA (European Economic Area), generating €12.4bn in revenue in 2025. That’s great. However, non-banks found it difficult to compete due to a lack of infrastructure access. And poorly performing APIs and substandard UX for consumers did not help either.
So, PSD3 and PSR aim to remove these issues:
PSD3: the directive. This is the rulebook for financial institutions. It covers market infrastructure, the firms that can operate as payment institutions, their licensing, and the required governance standards.
PSR: the regulation. This covers the mechanics of day-to-day payments, consumer rights, and how Open Banking APIs must perform, and responsibility for fraud liability. Unlike PSD2, this applies identically across all 27 EU member states, with no room for interpretation.

Banks that invested in API quality since 2018 are well-positioned to succeed – and it’s not just them who’ll benefit:
There are 5 key changes that will improve on the foundations of the PSD2 era:
What’s changing?
PSD3 introduces a set of mandatory, EU-wide measures to tackle payment fraud head-on, particularly the surge in scams that trick consumers into authorizing payments themselves.
Why?
Fraud levels across the EU have risen sharply, but the rules designed to stop it have been inconsistent and unevenly enforced.
Key drivers
A combination of eroding public trust and political momentum — particularly lessons learned from the UK — has pushed fraud protection to the top of the regulatory agenda.
What’s changing?
PSD3 moves beyond simply mandating Open Banking to setting minimum quality standards. This means third-party access will no longer be negatively impacted by poor infrastructure.
Why?
The promise of Open Banking under PSD2 was largely undermined by the poor technical reality banks delivered in practice.
Key drivers
Persistent underperformance and fragmentation have prevented Open Banking from reaching its potential as a payments infrastructure.
What’s changing?
PSD3 levels the playing field by giving non-bank payment providers direct access to infrastructure they previously had to obtain through their competitors.
Why?
Non-banks have been at a structural disadvantage where they’re dependent on the very banks they compete with for access to core financial infrastructure.
Key drivers
The status quo has created higher costs and slower innovation, which is at odds with the EU’s broader ambitions for a competitive digital economy.
What’s changing?
Rather than applying blanket authentication requirements, PSD3 introduces a more calibrated approach, matching the level of friction to the actual level of risk.
Why?
Blanket SCA requirements under PSD2 created unnecessary friction that damaged conversion rates without meaningfully improving security.
Key drivers
Sustained pressure from merchants and measurable drops in consumer completion rates have made SCA reform a commercial as much as a regulatory priority.
What’s changing?
The PSR shifts the rules from directives — which each country interprets and implements differently — to directly applicable regulations, creating a single, consistent framework across the EU.
Why?
PSD2’s directive model created a fragmented patchwork of rules, which firms exploited and regulators struggled to enforce consistently.
Key drivers
Fragmentation has undermined both market integrity and the EU’s ability to compete as a unified payments bloc.
So, PSD3 and the PSR improve on PSD2. How can you make the most of it?
Just because PSD3 is a regulation doesn’t mean it should be treated as a compliance cost. It can be a revenue generator if you position yourself correctly.
While PSR doesn’t allow banks to charge for the mandated Open Banking data access, banks can monetize the new regulations through premium services that go beyond the regulatory minimum. This opens the door to revenue from access charges for enriched data, SLA-backed access, VRPs (Variable Recurring Payments) and value-added APIs.
Think of how AWS turned internal infrastructure into a global business. Banks that treat their APIs as a product, rather than a compliance obligation, can monetize access to account data, transaction history, and payment initiation in ways that create entirely new revenue lines.
This can be a marketable feature. Banks with the strongest and most user-friendly SCA will lose less money through fraud and be able to attract and retain more customers. Walmart’s 2024 pay-by-bank launch working with Fiserv illustrates this point well.
Despite the product offering a smoother checkout experience, consumer reaction was skeptical. Not because the technology was flawed, but because people didn’t trust Walmart with their bank account the way they trust their bank. PSD3 gives them the tools to strengthen trust and actively market it.
PSR ends regulatory arbitrage and fragmentation, so banks operating in multiple member states will now have a single set of compliance rules and fewer product variations. A bank currently maintaining seven slightly different versions of the same product across seven EU countries can consolidate into one. That’s a cost saving, it’s a faster time-to-market when launching new features, and a more consistent experience for customers wherever they are in the EU.
And if you’ve got clean APIs, established data infrastructure, and effective partnership models when FIDA lands (the EU’s Open Finance legislation), then you’ll have a head start for Open Finance. Banks that invested early in Open Banking found themselves well-positioned to onboard fintech partners quickly when demand grew.
The same logic applies here: if you treat PSD3 compliance as a foundation rather than a finish line, you will be first to market when FIDA creates demand for mortgage, insurance, and investment data sharing.
PSR is expected to be published in the Official Journal in summer 2026 and will come into force 20 days later. More provisions will apply 21 months after coming into force, so we can expect the new payee verification regime in early 2028, and the liability shift applying 3 months after that, in mid-2028. The transposition of PSD3 by EU member states will follow broadly the same track.
With the ink drying on the final texts for the next stage of the EU’s payments rulebook, we now understand what the transition from PSD2 to PSD3 and PSR will look like.
Under PSD2, banks held an advantage by controlling infrastructure access. When the new regulations come into force, they won’t have this edge. The new era will bring about a competitive shift, one that rewards quality data, products, and partnerships.
Changing your infrastructure to be both compliant and competitive will take time. Building APIs as a commercial product doesn’t happen overnight and neither does creating the partnership models that will thrive when FIDA comes into effect.
The banks that treat the next 12-18 months as a time to build and launch will enter the next phase of Open Banking and Open Finance already at race pace. The cost of being slow on PSD2 was reputational; under PSD3, if you’re late, the cost will be commercial.
We can help with the PSD3 transition.
If you’re working on what PSD3 readiness looks like for your institution, and need help plotting the API roadmap, data infrastructure, or partnership strategy, RedCompass Labs can help with that journey. Get in touch now.
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Geetha Narkhede
Senior Business Analyst, RedCompass Labs
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