Consent Management Capability Gaps for Open Banking and Data Sharing

Why consent has become a primary open banking readiness constraint

Open banking and broader data-sharing models reframe customer data access from a bilateral relationship into a governed ecosystem. In this environment, consent is not only a legal requirement. It is the control mechanism that determines whether the institution can share data confidently, revoke access reliably, evidence compliance, and preserve customer trust at scale.

Many banks approach consent as a user experience layer or a compliance workflow. That framing misses the real risk: consent is an enterprise control that must synchronize business rules, API authorization, data minimization, and audit evidence across multiple products and systems. Weakness in any one of these components becomes a capability gap that constrains open banking participation or increases the probability of breach, customer complaint, or supervisory finding.

Defining consent management capabilities in banking terms

Consent management in banking refers to the processes and platforms used to collect, record, manage, and enforce customer permissions for data use and sharing. The operational requirement extends beyond “getting permission.” It includes verifying the customer’s intent, ensuring the customer was informed, enabling revocation, and enforcing those decisions immediately across all connected systems and third parties. Industry and vendor guidance commonly describe consent management platforms as centralizing consent collection and record keeping to support accountability and ongoing compliance obligations.

For executives, the practical definition should be narrower and more testable: the bank’s consent capability is mature only when consent decisions can be proven, enforced, and monitored across the full lifecycle of data access.

Capability gaps that most commonly derail open banking and data sharing

The gaps below are expressed as executive tests. They make it easier to assess whether the current state can support data sharing without creating hidden liabilities.

Granularity gap

What it looks like: Consent is captured at a broad level (for “data sharing”) rather than at the level of data type, purpose, and duration. Customers cannot clearly distinguish between sharing balances versus transaction history, or budgeting use versus loan decisioning use.

Why it matters: Broad consent increases conduct risk and creates unnecessary exposure if third parties access more data than required. It also reduces defensibility when customers dispute outcomes or regulators question whether data minimization and purpose limitation were followed.

Executive test: Can the bank demonstrate, in a single view, the exact scope (data, purpose, channel, third party, duration) for every active consent?

Informed-consent gap

What it looks like: Disclosures are generic, inconsistent across channels, or not easily retrievable after the fact. The bank cannot reconstruct the exact terms that were presented when the customer consented.

Why it matters: Informed consent is a defensibility requirement. If the institution cannot demonstrate clarity of customer understanding and affirmative action, it will struggle to resolve disputes and prove compliance with privacy obligations that require transparency and accountability.

Executive test: Can the institution reproduce the consent screen, language, and version shown to the customer at the moment of authorization?

Revocation and lifecycle gap

What it looks like: Customers can withdraw consent only through non-digital channels, the experience is difficult to find, or revocation takes time to propagate. Expired consents persist in downstream systems.

Why it matters: Revocation is operational risk disguised as a UX detail. If customers cannot revoke easily, the institution increases complaint risk and reputational exposure. If revocation is not enforced promptly, the bank can unintentionally allow unauthorized access, creating breach and regulatory risk.

Executive test: Is revocation available in the primary channel, and can the bank prove that access tokens and downstream entitlements are invalidated within defined time thresholds?

Audit trail and evidence gap

What it looks like: Consent logs exist but are incomplete, fragmented, or not tamper-evident. Logging does not capture the terms presented, the actor, the channel, and the resulting authorization state. Reporting requires manual stitching.

Why it matters: Open banking increases the frequency and diversity of access events, which increases the need for automated evidence generation. Without strong record keeping and accountability, the institution cannot demonstrate control effectiveness or respond quickly to inquiries and incidents. Guidance on consent management typically emphasizes detailed record keeping to support accountability and compliance reporting.

Executive test: Can audit and risk teams obtain a complete consent history for a customer and third party without manual reconciliation across systems?

Standards and authorization gap

What it looks like: The bank uses inconsistent authorization patterns across APIs, relies on credential sharing, or lacks standardized token governance. Integration teams implement bespoke security approaches per partner.

Why it matters: Open data sharing depends on secure authorization flows and consistent handling of tokens and scopes. Vendor and open banking documentation frequently point to OAuth 2.0 and OpenID Connect patterns as the basis for delegated authorization and secure token management, but implementation inconsistency is a common enterprise gap.

Executive test: Are scopes, token lifetimes, renewal rules, and revocation mechanisms standardized as enterprise policy rather than partner-specific engineering decisions?

Real-time enforcement gap

What it looks like: Consent changes are stored in a consent repository but do not reliably control access in real time. Downstream caches and data services continue to serve data after revocation. Exceptions are detected only after the fact.

Why it matters: The value of consent management rests on enforcement. If revocation is not enforced immediately, the bank cannot credibly claim it controls data sharing. Open banking consent guidance highlights the need to manage and revoke third-party access in real time, which requires tight integration between consent state and authorization enforcement.

Executive test: Can the bank block data access at the API gateway or authorization server based on current consent state, not a periodic sync?

Multi-channel consistency gap

What it looks like: Consent can be captured in one channel but not managed in another, or terms vary by channel. Branch and contact center processes do not align with digital channels.

Why it matters: Inconsistent channel behavior undermines customer trust and complicates compliance. Consent management guidance commonly emphasizes consistency across channels as a design requirement, especially where customers expect to manage permissions through digital self-service.

Executive test: Do customers see a single, consistent consent view and the same set of management actions regardless of channel?

Where consent capability gaps originate in the operating model

Consent weaknesses often reflect operating model fragmentation rather than tooling gaps. Common root causes include unclear ownership between product, risk, and technology; decentralized API delivery without enterprise security standards; and data architectures that cannot reliably map entitlements to downstream data services. When the consent lifecycle spans customer interfaces, identity, API authorization, and data provisioning, governance and architectural alignment determine whether the capability is controllable.

As a result, capability gap identification should not focus solely on the existence of a consent platform. It should assess whether the platform is embedded into the control plane of the bank: identity, authorization, monitoring, and audit evidence generation.

How to evaluate consent platform fit without turning the decision into vendor selection

Consent management platforms and consent management providers can help centralize capture, policy, and record keeping, but they do not eliminate the need for enterprise design discipline. A bank can use a platform while still failing on enforcement, auditability, or channel consistency if integration is partial or policy ownership is unclear. Vendor and platform landscapes frequently include privacy and consent management providers and open banking components, but executive evaluation should remain capability-based.

When assessing fit, the key question is not “which platform is best,” but “which capabilities are already strong and which require targeted remediation.” This is especially important where open banking standards and authorization practices must be applied consistently, and where consent records must remain defensible over time.

Strategy validation and prioritization through open banking capability gap identification

Open banking ambitions are often framed as ecosystem growth and customer experience improvement. The strategy validation test is whether the institution’s consent and data sharing capabilities can support those ambitions without expanding compliance risk or operational fragility. When gaps exist, they should be treated as portfolio prerequisites rather than defects to be fixed later.

Prioritization becomes clearer when consent is viewed as an enterprise control. Investments that strengthen consent granularity, evidence-by-design, standardized authorization, and real-time enforcement typically unlock multiple downstream initiatives, including data aggregation, partner propositions, and personalization. Conversely, attempting to scale open banking use cases before these capabilities are mature tends to create hidden remediation portfolios and reputational exposure.

Validating open banking readiness by mapping consent gaps to capability maturity

Identifying capability gaps requires a structured way to compare the bank’s current consent lifecycle against the implied requirements of open banking participation: granular permissions, informed disclosures, easy revocation, audit-grade records, standardized authorization, and real-time enforcement. Without a consistent maturity lens, institutions can overestimate readiness based on isolated pilots, or underestimate the operational dependencies that emerge at scale.

A digital maturity assessment creates that comparability by evaluating consent management as part of a broader capability system spanning governance, data, security, architecture, and operations. By linking observed gaps to measurable maturity dimensions, executives can decide which remediation work is prerequisite, how to sequence open banking initiatives, and how to set scale criteria that protect trust and compliance outcomes. This is where the DUNNIXER Digital Maturity Assessment is relevant: it helps leadership test whether strategic ambitions for data sharing are realistic given current digital capabilities, and it provides a defensible basis for prioritizing the control-plane investments that make open ecosystems sustainable.

Reviewed by

Ahmed Abbas

The Founder & CEO of DUNNIXER and a former IBM Executive Architect with 26+ years in IT strategy and solution architecture. He has led architecture teams across the Middle East & Africa and globally, and also served as a Strategy Director (contract) at EY-Parthenon. Ahmed is an inventor with multiple US patents and an IBM-published author, and he works with CIOs, CDOs, CTOs, and Heads of Digital to replace conflicting transformation narratives with an evidence-based digital maturity baseline, peer benchmark, and prioritized 12–18 month roadmap—delivered consulting-led and platform-powered for repeatability and speed to decision, including an executive/board-ready readout. He writes about digital maturity, benchmarking, application portfolio rationalization, and how leaders prioritize digital and AI investments.