Scheme2 The Open Finance Blueprint

From Regulatory Challenge to Strategic Opportunity: The Blueprint for European Data Sharing.

Scheme² The Open Finance Blueprint E-book Cover

The era of Open Finance requires more than a guide; it demands a strategic toolkit. As FIDA mandates the creation of complex data-sharing schemes, Scheme² The Open Finance Blueprint delivers the complete implementation package. This is a definitive, actionable toolkit for transforming a legal requirement into a strategic advantage. Also available as a standard e-book.

Foundation for Financial Innovation FinTech Poland Logo

Proudly under the patronage of the Foundation for Financial Innovation FinTech Poland. This collaboration highlights a shared mission to foster an innovative digital finance ecosystem. The principles in Scheme² directly support the Foundation's work to build a competitive financial market across Poland and the EU.

Europe's financial landscape is undergoing a monumental shift from Open Banking to a comprehensive Open Finance framework. Regulations like the Financial Data Access (FIDA) framework and the Digital Euro are not just incremental changes; they mandate a new market structure built on governed data-sharing schemes. For institutions navigating this complex transition, the critical question is: how do we build these schemes efficiently, compliantly, and strategically?

Scheme² The Open Finance Blueprint provides the answer. Drawing on critical lessons from pioneering initiatives like SPAA, VOP, and giroAPI, this toolkit moves beyond theory to offer a prescriptive, step-by-step implementation framework. It is the definitive resource for architects of the new financial ecosystem.

Two pages from the Scheme² book demonstrating its clear content and structured methodology for Open Finance and FIDA schemes

Excerpts from the book

Your Strategic Toolkit for FIDA & Open Finance Schemes:

  • The Scheme² Generator: An interactive workflow tool that translates the blueprint into a practical, step-by-step process. Systematically define your data exchange scheme's legal, business, and technical pillars and generate a complete rulebook structure.
  • The Complete Blueprint: Guiding you through every phase of your payments scheme or data scheme development: from defining purpose and governance to building a robust rulebook, creating a fair compensation model, and establishing critical operational infrastructure.
  • A clear deconstruction of the European regulatory landscape, including the crucial interplay between FIDA, the Data Act, and GDPR for any Open Finance scheme.

This toolkit is an indispensable asset for any industry leader, strategist, product manager, or policymaker tasked with building the future of European finance.

The Scheme² Generator: Your Project Accelerator

The expert methodology embedded in the Scheme² Generator is designed to reduce the time and effort required to build your data-sharing scheme by an estimated 30-40%. By providing a structured workflow and pre-defined templates, it eliminates ambiguity and streamlines decision-making for FIDA compliance.

This strategic toolkit is a small investment for a massive return on your entire project lifecycle, empowering you to move faster and with greater confidence in the Open Finance landscape.

Screenshot of the Scheme² Generator, a workflow tool for building an Open Finance data exchange scheme

“A great contribution from Maciej that is long overdue to explain how a scheme or schemes could help to (finally) deliver on the promise of Open Banking”

Eric Tak
Senior Cards & Payments Executive

“Just in time before we will see a plethora of Open Finance Schemes getting created, Maciej has made the effort in conceptionalising his longstanding and broad experience in this arena into a framework, which can - and hopefully will - be used by the many, many initiatives in the finance industry...”

Ralf Ohlhausen
Chair ETPPA
Maciej Kostro, author of Scheme² and expert in Open Banking

About the Author

Maciej Kostro has worked in digital banking and payments for more than twenty years, with a focus on the development of Open Banking in Europe. He was the leader of the PolishAPI standard initiative, which established the PSD2 API standard for the Polish market, and is currently the service owner for ING's PSD2 XS2A APIs in Europe.

He also participates in broader industry discussions as an active member of the Berlin Group's openFinance Taskforce. As a member of several working groups within the European Payments Council, he contributed to the creation of the SEPA Payment Account Access (SPAA) scheme.

Abstract & FAQ

Understanding the regulatory context and strategic importance of building effective data sharing schemes under the new Open Finance regime.

Executive Summary

The European Union's Financial Data Access (FIDA) regulation represents a paradigm shift, mandating that financial institutions make a broad range of customer data accessible to third-party providers. This move from Open Banking to Open Finance requires the creation of formal, governed Financial Data Sharing Schemes (FDSS). These schemes are the bedrock of the new ecosystem, defining the legal, technical, and operational rules for data access. However, designing and implementing a compliant, fair, and commercially viable scheme is a complex, multi-disciplinary challenge. Scheme² The Open Finance Blueprint provides a systematic methodology to navigate this complexity, reduce ambiguity, and accelerate the development of robust data sharing schemes.

Frequently Asked Questions

What is the EU FIDA Regulation?

The Financial Data Access (FIDA) regulation is a key European legislative framework that provides a clear starting point for the future of data sharing. It requires data holders (like banks and insurers) to provide third-party access to customer data, subject to permission. Its requirements for formal Financial Data Sharing Schemes (FDSS) establish a clear set of problems that any scheme methodology must solve, from governance to compensation. You can learn more from the official EU legislative proposal.

What defines a data-sharing scheme?

A data-sharing scheme is a formal agreement or rulebook that governs how data is shared among its members. It sets common standards for APIs, establishes liability models, defines governance structures, and outlines a model for value exchange. The objective is to create a standardized, fair, and secure environment for data sharing, whether for a single market, a specific use case, or an entire industry.

What is the difference between a payments scheme and a data exchange scheme under FIDA?

A payments scheme (like SEPA) governs the rules for executing payment transactions. A data exchange scheme under FIDA governs the rules for accessing and sharing a much broader set of financial data, such as investments, insurance, and pensions. While both require robust rulebooks and governance, FIDA schemes are focused on permissioned data access rather than the movement of funds itself. Scheme² provides the framework to build both.

How does Scheme² streamline the creation of any data-sharing scheme?

Scheme² provides a universal, step-by-step blueprint for the entire lifecycle of creating a data-sharing scheme, whether it's mandated by regulation like FIDA or driven by a commercial initiative. Instead of starting from a blank page, the toolkit offers a proven methodology that covers:

  • Governance and Legal Structure: Defining roles, responsibilities, and legal agreements.
  • Rulebook Development: A systematic process for creating a comprehensive set of operational rules.
  • Technical Framework: Principles for designing APIs and infrastructure.
  • Value Exchange & Compensation Models: Frameworks for establishing fair value exchange among participants.

By using the blueprint and the accompanying Scheme² Generator tool, organizations can accelerate their path to launch, reduce project risk, and build a scheme that serves as a strategic asset.

How does Scheme² help with Open Finance compliance?

Scheme² directly addresses the core requirements of Open Finance regulations like FIDA by providing a structured methodology for creating a compliant Financial Data Sharing Scheme (FDSS). It ensures all necessary pillars—legal, business, and technical—are systematically defined, including governance, rulebooks, liability models, and compensation frameworks, which are all mandated by the regulation.

What are the first steps to creating a FIDA-compliant scheme?

The first steps involve defining the scheme's purpose and scope (e.g., which data sets, which participants). This is followed by establishing a foundational governance structure and a legal framework. The Scheme² blueprint guides you through this initial phase, ensuring you make the right strategic decisions before diving into the detailed development of the rulebook and technical standards.

Who is this toolkit for?

Industry Leaders and Strategists at banks, insurance companies, and investment firms.

Product Managers and Innovation Heads tasked with developing Open Finance services.

Compliance and Legal Officers responsible for navigating new market structures.

Policymakers and Trade Association Members involved in shaping market standards.

Fintech Founders and Developers building the next generation of financial applications.

Your Blueprint for Action

Understanding the theory is the first step. Executing with clarity and confidence is what sets market leaders apart. The Scheme² toolkit is designed to bridge that gap, providing the structure and tools necessary to move from concept to a fully operational data-sharing scheme efficiently.