Data Access Governance in Open Banking as a Strategic Feasibility Test

Why data access governance is the real constraint in open banking

Open banking strategies are often discussed in terms of APIs, partnerships, and new customer propositions. In reality, the decisive constraint is governance: whether the bank can control who accesses customer financial data, under what conditions, for what purpose, and with what evidence. Data access governance (DAG) is the operating discipline that turns open banking from “data sharing” into regulated, customer-directed access that can withstand scrutiny.

Regulatory frameworks such as PSD2 and GDPR, along with comparable regimes like Australia’s Consumer Data Right (CDR), are not simply compliance drivers. They define the acceptable risk posture for ecosystem access. DAG becomes the mechanism that prevents customer-consent models from degrading into weak identity, over-broad permissions, and opaque data flows that increase fraud, misuse, and reputational exposure.

What makes open banking access governable rather than merely available

Consent is a control system, not a user experience feature

Open banking frameworks rely on explicit, informed consent as the gateway to data access, with customer ability to revoke access. For feasibility, consent must operate as an enforceable control with clear scope boundaries: which data, which duration, which third party, and which permitted purpose. If consent is captured but not operationally bound to access decisions, DAG fails in predictable ways: stale authorizations persist, permissions sprawl beyond necessity, and disputes become difficult to resolve because evidence is incomplete.

A feasible DAG approach treats consent as part of identity, authorization, and audit. That means revocation must be immediate and verifiable, permission scopes must map to data elements and endpoints, and consent history must be retained with sufficient fidelity to support customer inquiries and supervisory review.

Security is foundational because open banking expands the attack surface

Open banking security guidance emphasizes that standardized, secure APIs are central to the model and that strong customer authentication and encryption practices are expected. DAG is the governance wrapper around those controls. It ensures that identity verification, token handling, and transport protections are consistent across channels and partners, and that deviations are detected and remediated before they become systemic weaknesses.

Feasibility breaks when security is designed as a project deliverable rather than as an operating discipline. In open ecosystems, threats exploit inconsistency: differences across APIs, products, and partner onboarding paths create weak links that attackers and fraud networks can target. DAG makes consistency governable by anchoring security controls to policies, roles, and monitoring that are enforceable across the environment.

Interoperability increases governance burden unless standards are enforced

Open banking depends on interoperability across participants and APIs. As regimes evolve, including discussion of PSD3 and the next phase of open banking, banks face pressure to support broader access patterns while maintaining privacy and security constraints. DAG is feasible when standards are enforced through clear policy, consistent metadata, and auditable controls. Without that discipline, interoperability multiplies exceptions and partner-specific variants, increasing both operational complexity and control drift.

Core components of data access governance that scale in open banking

Policies and standards that translate regulatory requirements into operating rules

DAG begins with explicit policies that define who can access which data, for what purpose, and under what conditions. Best-practice guidance for data access governance emphasizes that policies should integrate access models with metadata management so that rules can be consistently enforced. For open banking, policy design must go beyond general access statements and define consent scoping, partner eligibility requirements, logging expectations, and the circumstances under which access must be denied or paused.

Clear roles and decision rights to prevent “everyone owns it, no one owns it”

Governance frameworks frequently emphasize accountability as a core principle. In open banking, accountability must cover at least three layers: data ownership (what is shared and how it is defined), access governance (how decisions are made and exceptions are handled), and operational execution (how controls are implemented and monitored). Feasibility improves when decision rights are explicit: who approves new data scopes, who signs off on third-party onboarding, who accepts residual risk, and who owns remediation for recurring access issues.

Access controls designed for least privilege under dynamic conditions

Open banking access decisions are not static. They depend on customer authorization, third-party status, device and session signals, and data sensitivity. Implementing least privilege with Role-Based Access Control (RBAC) can work for internal access, but Attribute-Based Access Control (ABAC) and policy-driven authorization can be better suited for ecosystem access where permissions depend on context. What matters for feasibility is not the label, but whether the access model can enforce granular scope, prevent privilege creep, and produce evidence explaining why access was granted.

Audit and monitoring as continuous assurance, not periodic review

Open banking creates high-volume access events across many endpoints. DAG must include continuous logging, anomaly detection, and review to identify misuse and maintain compliance. This monitoring is also how the bank detects consent mismatches, partner behavior deviations, and emerging threats. Guidance across governance and open banking security sources emphasizes that transparency and monitoring are essential to maintaining trust and reducing risk.

Data catalog and metadata management as the control plane for scale

As open banking expands, governance requires visibility into data assets, sensitivity classifications, and how datasets map to API scopes. Data governance sources highlight that metadata supports understanding, accountability, and consistent policy enforcement. In DAG, metadata becomes the mechanism that keeps permissions aligned to definitions. If metadata is incomplete or stale, the bank cannot reliably enforce purpose-limited access at scale because it cannot consistently identify what is being shared and how it should be protected.

Best practices that improve feasibility under ecosystem pressure

Adopt zero trust principles to reduce reliance on perimeter assumptions

Open banking dissolves perimeter-based trust by design. A zero trust approach aligns well with DAG because it assumes that every request must be authenticated, authorized, and evaluated in context. Feasibility improves when identity verification is strong, authorization is policy-driven, and access is continuously monitored. This reduces exposure to compromised partner systems and credential abuse scenarios that can otherwise spread quickly across the ecosystem.

Automate access provisioning and governance workflows to reduce error and drift

Automation is frequently recommended for data classification, access provisioning, and monitoring to ensure consistent enforcement and reduce manual error. In open banking, automation is also a feasibility requirement: manual approvals and one-off exceptions do not scale as partner volumes grow. Automated workflows should still preserve governance controls, including documented approvals for policy changes, versioning of authorization rules, and traceable audit evidence.

Manage third-party risk as part of access governance, not separately

Open banking depends on third parties who must meet accreditation and security requirements. DAG feasibility depends on whether third-party governance is integrated with access decisions: partner status and assurance results must influence authorization outcomes in real time. Where third-party risk is managed as a separate process, banks can end up granting access to partners whose risk posture has deteriorated, simply because access controls are not connected to current oversight signals.

Design transparency to reduce disputes and strengthen customer trust

Transparency is often framed as a customer requirement, but it is also a control objective. When customers can view, modify, and revoke permissions, the bank reduces the probability that stale authorizations persist and increases defensibility when disputes arise. Transparency also supports ethical and privacy expectations that sit alongside regulatory requirements, particularly as open banking models broaden.

Audit regularly, but prioritize continuous verification

Periodic audits and penetration testing remain important, but feasibility requires continuous verification because open banking environments change rapidly through new partner integrations, API changes, and evolving fraud tactics. Governance should treat audits as a validation mechanism for whether continuous controls are operating as intended, rather than as the primary mechanism for discovering weaknesses.

Where feasibility commonly breaks in data access governance

Scope creep that turns “minimum necessary” into “everything available”

Open banking can encourage broad data sharing for innovation. Without strong governance, that can lead to permissions expanding beyond the intended purpose. Feasibility requires enforcing purpose limitation through scope design, policy review, and monitoring that detects unusual access patterns and over-collection risk.

Fragmented governance across product platforms and regions

Many banks operate multiple cores, data stores, and channel platforms. DAG feasibility breaks when each platform implements its own access patterns, consent logic, and logging approaches. This fragmentation increases control gaps and weakens the bank’s ability to respond consistently to customer inquiries and regulatory requests.

Insufficient evidence to explain access decisions under scrutiny

When incidents occur or customers dispute access, leadership teams need evidence: what was shared, why, and under which authorization. If logs are incomplete, if metadata is unclear, or if consent records are not tied to access events, the bank may be unable to defend its decisions. This becomes a governance and reputational risk even when the underlying access decision may have been appropriate.

Feasibility indicators executives can use to oversee DAG readiness

Executives can improve decision quality by using a small set of indicators that reveal whether DAG can scale as open banking expands:

Percentage of open banking data scopes mapped to authoritative definitions, sensitivity classifications, and owners
Consent lifecycle performance, including revocation effectiveness and dispute volumes tied to authorization claims
Policy compliance rates for least-privilege access, including exceptions and remediation aging
Audit log completeness and retention coverage for open banking access events and consent linkage
Detection rates for anomalous partner access patterns and time to contain misuse
Third-party assurance coverage and the proportion of partners with current security attestations tied to access eligibility

These measures turn DAG into a governable capability rather than a set of design intentions.

Validating strategic feasibility for open banking data access governance

Open banking and data sharing ambitions are feasible only when data access governance can scale across partners, products, and evolving standards while maintaining consent integrity, least-privilege access, and audit-ready transparency. Treating DAG as a feasibility test helps executives separate “API availability” from “defensible access,” and it clarifies which prerequisites must be strengthened before expanding data scopes or accelerating ecosystem partnerships.

Capability benchmarking strengthens this decision-making discipline by showing whether governance, metadata, access control design, monitoring, and third-party oversight are mature enough to sustain open banking at production scale. Used well, a maturity assessment converts DAG from a policy aspiration into a sequenced capability plan that reduces supervisory risk and customer harm exposure. That is where DUNNIXER can support leadership teams by mapping DAG requirements to operating model and control capabilities and by providing an objective readiness baseline through the DUNNIXER Digital Maturity Assessment, increasing confidence that open banking strategy is prioritized and executed in line with current digital capability constraints.

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.