#FinOpen: The gap between Open Finance data and user value delivery, and other challenges
W FINTECHS NEWSLETTER #154
👀 Portuguese Version 👉 here
👉 W Fintechs is a newsletter focused on financial innovation. Every Monday, at 8:21 a.m. (BrasÃlia time), you will receive an in-depth analysis in your email.
Welcome to the edition of the Finance is Open series.
Every other Wednesday, in addition to the traditional Monday editions, I will cover key topics and the latest updates on what's happening in Open Finance, both in Brazil and around the world.
Finance is Open is sponsored by
Iniciador is the complete infrastructure platform specialized in Regulated Open Finance, enabling Payment Initiation and Data Access.
The solution removes technology and compliance concerns, allowing clients — with their own regulatory license or using Iniciador’s — to focus on new products and business growth.
Last week, Brazilian Open Finance entered a new phase. Institutions with more than five million customers are now required to join the ecosystem, slightly expanding the agenda’s reach. This is significant because it adds over 220 million financial relationships to the system and directly impacts around 36 million Brazilians.
Still, integration remains incomplete. About 106 banks and fintechs are not yet part of the ecosystem, either because they are not subject to regulatory mandates or have not joined voluntarily. These institutions serve around 8 million people who have an exclusive relationship with them, making them invisible in the data flows. This new phase expands access, but also exposes the limits of coverage and the ongoing challenge of building a truly inclusive base.
This situation reinforces a structural issue that has accompanied Open Finance since the beginning. A large part of the financial system understood the agenda first as a regulatory obligation and later as a commercial opportunity. This perspective reveals the sector’s difficulty in dealing with elements that are not directly under its control. Data, by reflecting the client’s life outside the institution, does not fit the ownership mindset that has traditionally shaped the financial industry. Instead of turning this access into qualified listening, many institutions chose to package, price, and promote it. They treated data as raw material for sales, not as a form of connection.
Treating data as a product means forgetting that it does not originate within the institution. It is brought by the customer based on a trust agreement, which should be grounded in mutual benefit. In this arrangement, the bank is not the owner of the information but its temporary guardian. Data should not be seen as a shelf item, but as an extension of someone’s lived experience. In Open Finance, data follows a logic of exchange, not possession. Understanding this from day one has set some institutions apart.
Today, nearly 40% of people who consented to data sharing say they received no benefit in return. This suggests that data is being used without delivering real value to the client. When institutions access this information only to reinforce pre-formatted offers, there is no genuine listening, just a repetition of old practices now rebranded as "Open Finance."
The narrative void
Recent data from a study by EY shows that the way consent is presented to users directly affects their willingness to share data in Open Finance. Institutions that place the data-sharing button on the home screen of their apps capture, on average, 50% fewer consents than those that embed the option within specific user journeys, such as credit simulations or service onboarding. Even when funnel success rates are similar, simply making the option visible does not ensure engagement. What truly matters is the context in which the data is requested and the clarity of the benefit perceived by the user at that moment.
This behavior shows that visibility is not the same as adoption. When the button appears isolated on the home screen without a clear value proposition, customers tend to ignore it. On the other hand, when data sharing is integrated into a journey that already interests the user, such as improving a credit proposal or consolidating financial information, consent is seen as an enabler rather than an extra task. This indicates that the effectiveness of Open Finance relies more on integration and purpose than on visual prominence.
This lack of connection between consent and perceived value helps explain the high level of user dissatisfaction. Nearly 40% of complaints about Open Finance on Reclame Aqui report that data sharing did not generate any direct benefit. Among these users, 92% say that even after authorizing the use of their information, they were not granted better credit limits.
Beyond the perception of uselessness, other factors worsen the experience. More than one fifth of the complaints are related to outdated data, which compromises the accuracy of the analyses performed by institutions. Among incumbent banks, 70% are above average in this type of complaint, and half of them also lead in complaints about difficulties in the consent process.
Beyond credit
The challenge of turning consent into a meaningful experience becomes even more complex when looking at high-income individuals. EY data shows that less than 15% of Brazilian investors have active consent in Open Finance, despite being a segment with high potential for added value. Even with low participation, interest is there, as about 20% of complaints from this group refer to the fact that their financial institutions still do not participate in Open Finance. This share is almost twice the overall average, revealing a latent demand that is not being met.
The behavior of institutions also helps explain this mismatch. Although the volume of investment API calls has grown at more than twice the average rate of the ecosystem, 73% of these calls remain concentrated in traditional fixed-income banking products. There is a clear disconnect between what the ecosystem prioritizes and where high-net-worth individuals are actually interested. Investment funds represent 33% of the total volume invested in Brazil but account for only 10% of investment API calls. Products such as equities, government bonds, and credit fixed income barely appear in the integrations, which highlights the lack of diversity in how data is being used.
This misalignment becomes even more evident when looking at the behavior of so-called "ultra-high-net-worth" individuals. More than half of the capital in exclusive funds is allocated to government bonds, yet only 1% of investment API calls are directed toward that asset class. In addition, between 30% and 50% of this group’s portfolios are held abroad, where foreign exchange plays a central role in portfolio composition. Even so, FX-related API calls in Open Finance represent only 0.03% of the total. The low usage reveals that the ecosystem still does not speak the language of more sophisticated investors or provide responses aligned with their actual needs.
The invisible business user
The effort to make Open Finance more relevant is not limited to high-income individuals. It must also reach the business segment, where the potential for value remains largely untapped. In Brazil, Open Finance penetration among businesses is only 3%, far below the 20% reported in the United Kingdom. Although business users represent only 1% of the ecosystem's unique users, they account for 4% of the complaints, showing a disproportionate level of dissatisfaction and indicating that their needs are not yet being properly addressed.
Much of the problem lies in the perception that the ecosystem was designed almost exclusively for retail customers. One in five participants states that business clients are simply not a priority in current strategies. Additionally, 17% of respondents admit they have no clear value proposition for this segment. This is especially concerning given that over 82% of small and medium-sized enterprises would be willing to share their business data in exchange for more personalized services, and nearly two-thirds would be willing to pay for them.
Another critical point is the complexity of business banking relationships. Most SMEs have accounts with multiple institutions, and a quarter of them maintain relationships with between six and ten banks. Even so, more than a third of these companies speak with their account manager once a month or less. While this frequency may be sufficient for many, it also reveals an underexplored opportunity. In previous editions of this newsletter, I have discussed how the relationship between companies and financial institutions tends to be long-lasting but often superficial and not driven by data.
Meetings are occasional, reactive, and frequently based on outdated perceptions. Open Finance may be exactly what is missing to make this relationship more strategic. By putting the right data in the hands of account managers, institutions can turn these interactions into more proactive, contextualized, and useful experiences for the business. With simpler journeys, integrated offerings, and relevant responses, Open Finance stops being just infrastructure and becomes a true driver of value for companies.
What EY’s data clearly shows is that Open Finance still talks more about potential than about real-world application. Although the ecosystem is technically advanced, it still struggles to deliver meaningful value to those who share their data. The individual user sees little to no return. The high-income investor is presented with generic offerings. The entrepreneur feels that no proposal is truly designed for their business needs. Consent has become an ambiguous symbol. It represents what could exist, but has not yet materialized.
The next steps for Open Finance must address this gap directly. If they do not, the agenda will continue to grow on the surface while becoming hollow inside. It will accumulate integrations, APIs, and promises of innovation but fail to build trust, foster engagement, or create meaningful relationships with the people who matter most. These are the users who share their data in the hope of receiving something better than what they had before.
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Until the next!
Walter Pereira
Disclaimer: The opinions expressed here are solely the responsibility of the author, Walter Pereira, and do not necessarily reflect the views of the sponsors, partners, or clients of W Fintechs.