How U.S. Open Banking Compares to the Rest of the World

While the U.S. is taking its first meaningful steps in formalising open banking with Section 1033 of the Dodd-Frank Act, other regions are further along. But comparing progress isn't just about legislation. It’s about infrastructure maturity, user adoption, industry collaboration, and whether the ecosystem is designed to truly empower consumers.

Let’s begin with a global snapshot.

Global Comparison: Where Open Banking Stands Today

Feature	🇺🇸 US	🇦🇺 AU	🇬🇧 UK	🇪🇺 EU	🇸🇬 SG
Law Mandated	✅ 1033	✅ CDR	✅	✅	❌
Accreditation	❌	✅ ADR	✅ FCA	✅	❌
API Standards	❌	✅	✅	❌	✅ (opt)
No Scraping	❌	🚧	✅	✅	🚫
Pay Initiation	❌	🚧	✅	✅	❌
Liability Rules	❌	✅	✅	✅	🚧
Reg Oversight	🚫 lim.	✅	✅	✅	🚧

United States: Market-Led Innovation, Waiting for the Guardrails

The U.S. is home to some of the world’s most ambitious fintechs, but its approach to open banking to date remains largely decentralised. Section 1033 of the Dodd-Frank Act gives consumers the right to access their data, but without regulatory teeth, that right has little consistency in practice.

The Financial Data Exchange (FDX) has emerged as a voluntary standards body, and data aggregators have helped power the growth of consumer-permissioned finance. However, screen scraping is still common, and liability between parties is often contract-based rather than regulator-enforced.

🔎 Use case spotlight:
Apps like Rocket Money and Monarch are using open banking data to flag forgotten subscriptions, automate cancellations, and offer smarter savings strategies. It’s proactive financial hygiene delivered with minimal user input.

Australia: Consent-Driven, Regulator-Backed, and Privacy-Centric

Australia’s Consumer Data Right (CDR) was built from the ground up to prioritise consumer privacy, strong consent frameworks, and secure infrastructure. It is one of the few jurisdictions to move toward an outright ban screen scraping and require third-party accreditation.

While adoption has been slow to start, it is designed for longevity. With the rollout now expanding to sectors like energy and telecommunications, Australia is becoming a multi-sector open data leader.

🔎 Use case spotlight:
In energy, open data is enabling apps that help households compare energy plans and track carbon usage in near-real time. In banking, CDR-accredited platforms like Fiskil powering platforms that use open data to offer highly personalised financial tools.

United Kingdom: The Fintech Powerhouse That Proved It Works

The U.K. took an early bet on open banking, and it paid off. Driven by PSD2 and enforced via domestic regulation, open banking in the U.K. is now part of the everyday banking experience. The Open Banking Implementation Entity (OBIE) created a single standard to ensure a consistent developer experience across major banks.

Today, over 7 million users access open banking services, from personal finance apps to SME lending and payments. Crucially, payment initiation is fully enabled, allowing third parties to initiate bank transfers directly without needing card rails.

🔎 Use case spotlight:
Startups like CreditLadder use open banking to track consistent rent payments and share this data with credit bureaus to improve a user’s credit score - especially helpful for young adults and immigrants with limited credit history.

European Union: Regulated Access, Fragmented Delivery

PSD2 was a milestone in financial regulation and set the foundation for open banking across 27 member states. However, each country’s interpretation has led to technical fragmentation. While all must offer APIs to regulated entities, the standards differ — from STET in France to Berlin Group in Germany.

The EU is now preparing to move beyond open banking with FiDA (Financial Data Access Regulation), aiming to harmonise technical standards and expand into insurance, pensions, and investments.

🔎 Use case spotlight:
Fintech platforms are integrating with EU bank APIs to automate VAT reconciliation. For example, Pleo and Soldo help SMBs instantly calculate VAT owed across countries, eliminating hours of manual work and reducing compliance risks.

Singapore: Innovation Through Collaboration

Singapore has taken a market-led approach, supporting open banking through voluntary frameworks and strong public-private collaboration. The Monetary Authority of Singapore (MAS) backs initiatives like SGFinDex, a platform that allows consumers to consolidate their financial data across institutions using the national digital ID system, SingPass.

🔎 Use case spotlight:
Robo-advisors like Endowus and StashAway use SGFinDex to access verified, real-time financial data across multiple banks. This allows them to provide highly personalised investment recommendations tailored to each user’s actual financial position.

What's next?

As the U.S. steps into this new era, it has a chance to leapfrog legacy systems by learning from others. At Fiskil, we’re ready to help make that leap by bringing global-grade standards, real-world experience, and zero-overhead infrastructure to power the next wave of open finance.

Want to explore how Fiskil can support your open banking strategy? Let’s talk.