Open Banking and PSD3: Opportunities for International Clients in 2026

Open banking — the regulatory-mandated sharing of financial data between banks and authorised third parties — has fundamentally altered what is possible in personal and business financial management. For internationally mobile individuals managing accounts across multiple countries and currencies, the implications are particularly significant. The upcoming transition to PSD3 in Europe extends these possibilities further.

This guide explains what open banking is, how PSD2 created the framework, what PSD3 will change, and — most practically — how internationally mobile clients can use these frameworks to manage their global financial lives more effectively.

The Origins: PSD2 and the Open Banking Mandate

The Second Payment Services Directive (PSD2) came into force across the EU in 2018 and was implemented in the UK through the Open Banking Standard, developed by the Competition and Markets Authority (CMA). The core mandate was straightforward but transformative: banks must allow regulated third-party providers to access customer account data (with customer consent) and initiate payments on their behalf.

Before PSD2, banks were walled gardens. Your financial data sat exclusively with each institution, inaccessible to other services unless you gave them your login credentials — a practice known as "screen scraping" that was insecure and unreliable. PSD2 replaced this with standardised, secure APIs (Application Programming Interfaces) through which authorised third parties could access your data with your explicit consent, using proper authentication.

Two categories of third-party provider were created:

Account Information Service Providers (AISPs): These read your account data — balances, transactions, statements — across multiple banks and present it in a consolidated view. Budgeting apps, accountancy software, wealth management platforms, and financial planning tools use AISP access to give you a unified picture of your finances.

Payment Initiation Service Providers (PISPs): These can initiate payments from your bank account on your behalf, without you needing to log into your bank. This underpins "pay by bank" functionality — where you pay a retailer directly from your bank account rather than via a card network — and can be cheaper for merchants than card payments.

Open Banking in Practice for International Clients

For individuals managing accounts across multiple jurisdictions, open banking's most immediate value is consolidated account visibility.

Consider a British expat living in Dubai with:

• A UK sterling current account (NatWest)
• A UK investment account (Hargreaves Lansdown)
• A UAE dirham account (Emirates NBD)
• An EU euro account (N26)
• A multi-currency Wise account

Before open banking, getting a comprehensive view of net cash position across all of these required logging into five separate apps or portals. With an AISP connection, a single financial management app can aggregate all account balances and transactions in real time, convert to a reference currency, and provide a consolidated cash position.

Applications such as Emma, Money Dashboard, Moneyhub, and Cleo offer this functionality for UK and EU accounts. Some wealth management platforms — including tools provided by private banks — use AISPs to incorporate external accounts into portfolio reporting.

Limitations across borders: Open banking mandates under PSD2 apply to EU and UK banks. UAE, US, Australian, or other non-EU/UK banks are not obligated to provide open banking APIs. Coverage therefore depends on which countries' banks you use. The UAE has its own open banking framework developing under CBUAE guidance, with implementation continuing through 2025–2026.

Payment initiation for international use: PISP functionality is most developed for domestic payments within individual markets. Cross-border payment initiation via open banking APIs is not yet widely available — most international payments still require you to log into your bank directly.

The UK Open Banking Journey

The UK's Open Banking Implementation Entity (OBIE, subsequently renamed Open Banking Ltd) created one of the most developed open banking ecosystems globally. By the end of 2025 there were around 16.5 million active open banking user connections in the UK (up from roughly 12 million a year earlier), and successful open banking payments reached approximately 30 million per month over the second half of 2025 — some 351 million payments across 2025 as a whole, up around 57% year on year.

Key UK developments include:

Variable Recurring Payments (VRPs): Mandated open banking VRPs allow payment service providers to initiate sweeping payments between a customer's own accounts without requiring separate authorisation for each transaction. The initial mandate covers intrabank sweeping only, but commercial VRPs (where third-party providers can initiate payments to any payee) are being rolled out through 2025–2026, which will enable sophisticated automated cash management applications.

Request to Pay: Built on the New Payments Architecture, Request to Pay allows payees to send a payment request to a payer, who can pay in full, in part, or defer — reducing late payments and improving cash flow management for businesses.

PSD3: What's Coming and What It Means

The European Commission published its proposals for PSD3 (and an accompanying Payment Services Regulation, PSR) in June 2023. The European Parliament and Council reached a provisional agreement on the package in November 2025, and the final texts are expected to be published in the EU Official Journal around mid-2026. Because the PSR is a directly applicable regulation followed by a transition period of roughly 21 months, the new rules are expected to apply in practice from late 2027 or 2028 rather than immediately.

The key changes PSD3 introduces include:

Improved data access: PSD2's open banking APIs were often technically substandard — banks met the letter of the regulation while implementing APIs that were slower, less reliable, and less feature-rich than their proprietary interfaces. PSD3 tightens technical performance requirements and introduces performance monitoring.

Financial data access beyond payments: One of the most significant PSD3 developments is the companion Financial Data Access (FIDA) Regulation, which extends the open banking principle beyond payment accounts to include savings accounts, mortgages, insurance products, pensions, and investment accounts. This vastly expands the scope of financial data that can be shared with authorised third parties.

Enhanced fraud protections: PSD3 strengthens the liability framework for payment fraud, including Authorised Push Payment (APP) fraud, aligning EU rules more closely with the approach taken in the UK where banks bear greater responsibility for fraud losses.

Non-bank payment service providers: PSD3 improves the framework for non-bank payment service providers to access payment systems, potentially enabling more competitive cross-border payment services.

Open finance, not just open banking: The combination of PSD3 and FIDA effectively creates a framework for "open finance" — where a customer could, in principle, authorise a wealth management platform to see their complete financial picture across all products and institutions, enabling genuinely personalised financial advice at scale.

Practical Opportunities for Globally Mobile Clients

Consolidated wealth dashboards: As FIDA extends data access to investments, pensions, and insurance, the ability to build a comprehensive view of total wealth across all products and institutions — without manual data entry — becomes practically achievable. For HNW individuals with complex multi-jurisdictional financial arrangements, this represents a significant operational improvement.

Automated cash management: VRPs and similar open banking primitives enable sophisticated automated cash sweeping — ensuring that idle balances are automatically moved to higher-yield accounts, that current accounts are topped up from savings when they fall below a threshold, or that multi-currency balances are maintained at target levels. What previously required treasury software or manual management can increasingly be automated through open banking APIs.

Smarter FX management: Open banking data aggregation, combined with FX alert services, enables more systematic monitoring of multi-currency positions and timely action when exchange rates reach target levels.

Simplified KYC and onboarding: Open banking data can be used by new financial institutions to verify income, verify account ownership, and assess creditworthiness, making multi-bank account opening faster and less burdensome. For expats who regularly need to open new accounts, this can meaningfully reduce friction.

Accountancy integration: For internationally operating businesses, open banking integration with accountancy platforms (Xero, QuickBooks, Sage) across multiple bank accounts in multiple countries dramatically reduces the manual reconciliation burden.

Security Considerations

Open banking is built on OAuth 2.0 and mutual TLS authentication standards, which are significantly more secure than screen scraping. However, security considerations remain:

• Only grant access to FCA-regulated (UK) or PSD2-authorised (EU) AISPs and PISPs. Check the FCA register or European Banking Authority register before connecting any app to your accounts.
• Consent can be revoked at any time — your bank must allow you to revoke open banking access consents directly through its app or online banking portal.
• AISPs have read-only access to your account data; they cannot move funds. PISPs can initiate specific payments you explicitly authorise but cannot create standing instructions without your ongoing consent.
• Be cautious of any service that asks for your banking username and password — this is a sign of legacy screen scraping, not open banking.

How Global Investments Can Help

Global Investments uses open banking-enabled tools as part of its wealth management service, helping internationally mobile clients achieve consolidated visibility across their banking and investment accounts, automate routine cash management, and integrate multi-jurisdictional financial data into coherent reporting.

For clients building or restructuring their international banking architecture, we can advise on which accounts and institutions support the most robust open banking connectivity, and how to structure accounts to enable the automated management capabilities that open finance frameworks are making possible.

Contact us to discuss how open banking technology can work within your specific financial structure.

Information is provided for educational purposes as of 2026. PSD3 and FIDA are subject to legislative change during EU implementation. Open banking connectivity varies by institution and jurisdiction. Seek professional advice before making financial decisions based on this guide.