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Open finance framework

Banking and financial services

The initiative aims at extending data sharing and third-party access currently provided in relation to payments to a wider range of financial sectors and products, based on the principle that financial services customers own and control both the data they supply and which is created on their behalf. It will build on horizontal measures, such as the Data Act.

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Public consultation

ID: 13241

Lobbying Activity

74 responses

Consultation response

DIGITALEUROPE, 26 Jul 2022

Of the policy options in the Inception Impact Assessment, DIGITALEUROPE supports the promotion of market-driven standardisation to address the existing technical obstacles to data reuse without introducing any new data access rights. Within an EU voluntary data sharing framework, Open Finance…

Consultation response

SMEunited aisbl, 30 May 2022

SMEunited supports all initiatives, which facilitate access to finance of SMEs. Improving access to data can improve access to finance from third parties. However, for SMEs it is important to control access to their data. This means, even if SME data are stored at a platform or similar locations,…

French Banking Federation slams risky "big bang" data sharing

Fédération bancaire française, 31 Oct 2023

The federation claims mandatory data sharing is unrealistic and lacks impact analysis. They want a narrower definition of customer data excluding inferred information. Compensation for sharing should be reconsidered and aligned with the Data Act.
Restricting data access would reduce compliance costs and protect banks' commercial trade secrets.
Big Tech companies would lose access to valuable European consumer financial data.

Insurance Europe seeks narrower scope for EU financial data rules

Insurance Europe, 1 Nov 2023

The federation requests a step-by-step implementation focusing only on retail customers and demonstrated use cases. It seeks explicit exclusions for sensitive health data and proprietary trade secrets to protect competitive innovation. They also propose a two-stage implementation timeline to allow for technical development.
A narrower scope and phased timeline would reduce compliance costs and protect internal models.
Tech gatekeepers and commercial clients would be excluded from accessing valuable insurance data sets.

Consultation response

Insurance Europe, 2 Aug 2022

Open finance, if designed with the right framework, has the potential to positively impact both consumers and insurers. However, it is important to get the framework right, so that the potential can truly be achieved. This raises important considerations in relation to consent management, the scope…

AFME Urges Market-Driven Compensation and Longer Open Finance Timeline

Association for Financial Markets in Europe, 1 Nov 2023

AFME requests narrowing data scope to exclude inferred data and wholesale corporate clients. They propose a 48-month implementation timeline and market-driven compensation.
This avoids sharing sensitive intellectual property and reduces the burden of real-time requirements.
Big Tech gatekeepers and medium-sized companies would face market exclusion or higher access costs.

European Banking Federation urges gradual approach to financial data sharing

European Banking Federation, 31 Oct 2023

The federation requests a 48-month implementation timeline instead of 18 months, a gradual staged approach starting with limited data sets, and clear exclusion of derived and inferred data from mandatory sharing. They emphasize that reasonable compensation should cover investments in data infrastructure, not just direct sharing costs.
This would protect their proprietary assessment methods and give them compensation for data infrastructure investments.
Financial technology companies lose quick access to bank customer data for innovation purposes.

Banking Federation Urges Voluntary Open Finance Framework

European Banking Federation, 2 Aug 2022

The federation requests a voluntary data-sharing framework based on market needs rather than mandatory access rights. They want provisions covering consumer protection, liability, compensation, and technical standards developed through market-driven initiatives. They argue no new mandatory data access rights should be introduced until other economic sectors have comparable frameworks.
This would prevent them bearing infrastructure costs without compensation while competitors access their data.
Third-party fintech providers lose mandated free access to bank-held customer data.

German insurers urge narrower scope for financial data access

Gesamtverband der Deutschen Versicherungswirtschaft e.V., 31 Oct 2023

The GDV requests limiting the scope to new contracts and excluding accident insurance. They also seek an implementation period extended to 36 months for companies.
Excluding legacy contracts would prevent disproportionate technical efforts and massive IT costs.
Consumers risk harm if their sensitive health and personal data is misused.

Consultation response

Finanssiala ry - Finance Finland, 28 Jun 2022

Finance Finland (FFI) supports efforts towards fair data sharing in which the treatment of different players is based on a true level playing field and reciprocity. The focus of opening up data should not be solely on the financial sector, but broadly on all sectors of society. Data access, sharing…

Italian Banking Association Urges Gradual Rollout of Open Finance Rules

Associazione Bancaria Italiana, 31 Oct 2023

ABI recommends a staggered approach to data sharing to protect customer interests. They request a narrower data scope that excludes trade secrets and processed data. The association also demands equal access rules to prevent unfair competition from non-EU providers.
Stricter rules would prevent Big Tech from gaining a dominant position using bank data.
Non-financial tech companies would face stricter barriers and limited access to bank data.

Spanish Banking Association demands data sharing reciprocity across all sectors

Asociación Española de Banca, 31 Oct 2023

AEB proposes that the framework "should not impose new data sharing obligations" on banks. They want a "level playing field" where all participants share data reciprocally.
Banks would protect their internal expertise while gaining access to non-financial data pools.
Non-financial firms lose the benefit of "asymmetric access" to data without providing reciprocity.

Consultation response

Asociación Española de Banca, 2 Aug 2022

Find attached our comments

Finance Denmark Calls for 48-Month Open Finance Implementation Delay

Finance Denmark, 1 Nov 2023

The group requests extending the implementation timeline to 48 months and excluding derived data from the scope. They also advocate for a market-driven compensation model for data holders.
Narrowing the data scope would reduce technical complexity and the resource burden on financial institutions.
Customers not using online banking may lose access to new data management tools and protections.

Consultation response

Finance Denmark, 1 Aug 2022

On behalf of Finance Denmark we welcomes the European Commission initiative to enable data sharing and third-party access in the financial sector. Please find our comments attached

Insurance Ireland urges phased approach and clarity on EU financial data access rules

Insurance Ireland, 31 Oct 2023

Insurance Ireland requests a phased implementation starting with motor and home insurance, at least 3.5 years total timeline, and EU-wide interoperable standards with local flexibility. They seek clarity on data protection requirements, scheme operations, and whether customers can control what data is shared.
This would give insurers more time to develop systems and avoid large complexities and costs.
New third-party data providers gain access without comprehensive regulation, potentially harming consumer protection.

Consultation response

PwCIL, 27 Jul 2022

PwC International Ltd (PwC), on behalf of the PwC network, welcomes the European Commission initiative to enable data sharing and third-party access in the financial sector. Please find our comments attached

Co-operative banks demand voluntary schemes and limited data scope

European Association of Co-operative Banks, 6 Oct 2023

The association requests that data sharing schemes be voluntary rather than mandatory and implemented over a longer timeline. They advocate for a gradual approach that excludes sensitive derived data and limits requirements for continuous real-time access.
Narrower data requirements would protect proprietary trade secrets and lower technical infrastructure costs.
Large technology companies would be blocked from accessing banking data to protect traditional retail models.

Consultation response

European Association of Co-operative Banks, 4 Jul 2022

We welcome the EC’s data strategy and its commitment to creating a single market for data that will constitute a potential source of growth and innovation. Recognizing the leading role of the financial sector in the overall digital transformation of the economy, the EC’s ambition to promote…

Consultation response

Zurich Insurance Company Ltd, 4 Jul 2022

Zurich Insurance favors the policy option introducing new data access rights in a limited number of areas. Data sharing within the financial sector and across sectors should be driven by clearly defined consumer propositions and use cases, providing the basis for determining specific rights and…

European savings banks demand fair compensation for data sharing

European Savings and Retail Banking Group, 23 Oct 2023

ESBG requests a gradual implementation and a compensation model that covers all data preparation costs. They insist that processed data and trade secrets must be excluded from the sharing requirements.
This would allow banks to recover more costs and protect proprietary information.
Fintech companies would lose free access to valuable, high-quality bank-processed information.

Luxembourg banking group calls for clearer financial data rules

Association des Banques et Banquiers, Luxembourg, 31 Oct 2023

The association requests clearer data definitions and exemptions for trade secrets. They advocate for longer implementation timelines and standardized permission dashboards.
Excluding trade secrets and extending timelines would reduce compliance risks and costs.
Fintech firms and data users would receive less data and face delays.

Unipol Group Demands Data Reciprocity and Longer Implementation Timelines

Unipol Assicurazioni S.p.A:, 1 Nov 2023

Unipol requests excluding sensitive health data and proprietary insights from sharing obligations. They advocate for a reciprocity clause to ensure fair competition with tech gatekeepers. Finally, they propose extending the regulatory implementation timeline to thirty-six months.
These changes would protect their commercial secrets and lower immediate technical costs.
Big Tech firms would lose their exclusive control over valuable consumer information.

France Assureurs demands extensive rewrite of open finance proposal

Fédération Française de l'Assurance, 31 Oct 2023

France Assureurs argues the proposal needs an extensive rewrite to protect consumers and trade secrets. They advocate for cross-sector reciprocity and a longer implementation timeline than the current 18 months.
These changes would protect insurers' commercial secrets and prevent unmanageable infrastructure costs.
High-risk consumers could face exclusion as data sharing encourages selective insurance coverage.

Luxembourg fund industry urges EU to narrow financial data scope

Association Luxembourgeoise des Fonds d'Investissement, 27 Oct 2023

ALFI recommends excluding legal persons from the scope to avoid high costs and management complexities. They also request that data sharing be limited to raw data, keeping internal assessments confidential. Finally, they call for a compensation model that covers infrastructure investments and potential liabilities.
This would reduce administrative burdens and protect the industry's secret internal scoring systems.
Smaller companies might struggle if the new rules favor larger firms with more resources.

Dutch pension funds seek tailored rules for data sharing

Pensioenfederatie (Federation of the Dutch Pension Funds), 11 Oct 2023

The Federation requests four-monthly updates and the exclusion of disability pension data to prevent exclusion. They also argue that insurance-based pension products should be included in the regulation.
Tailored standards would help avoid costly administrative overhauls and reduce unnecessary data management expenses.
Commercial data users lose the ability to influence technical standards and functional data sharing designs.

Consultation response

Finance Sweden, 14 Jul 2022

Data protection and respecting the GDPR principles need to be the focus of any initiative in the data sharing area especially as data literacy amongst consumers is still at a low level. It’s vital to ensure that the customer understands which consents they approve and to whom and on a regular basis…

European FinTech Association urges optional data sharing schemes

European FinTech Association, 31 Oct 2023

The EFA wants customers to access, automate, or authorize data sharing via software tools. They argue that participation in data sharing schemes should remain strictly optional.
Optional participation avoids the overhead of price regulation and technical fragmentation.
Vulnerable customers may lose access to tools if data holders charge high fees.

Digital Currencies Governance Group urges crypto exclusion from FIDA

Digital Currencies Governance Group Limited, 30 Oct 2023

The group requests excluding digital asset market participants from the proposal's scope. They argue that complying with FIDA alongside new crypto rules would be too overburdening.
This would reduce compliance costs and ease the transition into the regulated EU market.
Consumers and the data-driven economy would lose the benefits of effective data sharing.

Standardization bodies urge EU to recognize role in financial data

European Committee for Standardization, 20 Oct 2023

The organization requests a concrete reference to European standards organizations within the regulation text. They propose extending the timeframe for setting up data schemes to 24 months.
This ensures their technical work remains central to EU policy while reducing pressure.
Consumers and digital finance startups face a delayed rollout of data-sharing benefits.

PensionsEurope demands specific data sharing rules for pension funds

PensionsEurope, 31 Oct 2023

PensionsEurope wants the framework to build on existing tracking services and exclude sensitive health-related data. They argue the implementation timeline is unrealistic and requires significant extension. The group also seeks flexibility in how often pension data is updated.
This strategy avoids expensive parallel investments and reduces administrative burdens for funds.
Major technology firms would be restricted from using financial data for competition.

French financial firms urge longer deadlines and data exclusions

Association française des sociétés Financières, 31 Oct 2023

The group demands excluding credit solvency data and trade secrets from sharing requirements. They also request extending the implementation timeline from eighteen to thirty-six months.
These changes would safeguard proprietary business information and lower immediate compliance burdens.
Third-party financial service providers lose access to critical data for innovative products.

Assogestioni urges equal data sharing rules for big tech

Assogestioni - Italian Investment Management Association, 31 Oct 2023

They want all participants to share data equally to prevent imbalances with tech giants. They also suggest limiting data scope and extending implementation timelines.
This would protect European asset managers from market dominance by foreign digital firms.
Consumer groups would lose direct influence over data sharing schemes if relegated to advisory roles.

German banks urge gradual rollout of EU open finance rules

Die Deutsche Kreditwirtschaft, 26 Oct 2023

The committee advocates for a step-by-step approach and longer implementation deadlines to manage technical complexity. They also suggest alternative governance models to ensure more efficient decision-making within data sharing schemes.
A slower implementation timeline reduces immediate compliance costs and protects proprietary internal risk assessment models.
Consumers may face increased security risks and the danger of receiving poor investment advice from third parties.

Consultation response

Die Deutsche Kreditwirtschaft, 2 Aug 2022

The German Banking Industry Committee (GBIC) welcomes the opportunity to respond to the call for evidence on the European Commission’s open finance framework initiative. The following comments supplement our response to the Commission’s targeted consultation on 5 July 2022. We support the European…

ACCIS Demands Clarity on Credit Data in FIDA Proposal

ACCIS, 31 Oct 2023

ACCIS urges the Commission to clarify the ambiguity regarding the inclusion and exclusion of data for creditworthiness assessments. They call for better alignment between conflicting recitals and articles within the framework.
Clarifying the framework protects existing, well-functioning credit reporting systems from regulatory confusion.
Consumer groups risk being targeted with unfair or discriminatory credit offers if exclusions are removed.

Consultation response

Insurely AB, 1 Nov 2023

Insurely welcomes the Commissions proposal on FIDA. Paving the way forward on how to address data sharing, consumer consent, and data privacy are key to establishing a successful framework. Insurely believes that the following elements should be taken into account to ensure alignment with the needs…

Consultation response

Febelfin, 31 Oct 2023

Please find enclosed, the response of Febelfin, the Federation of the Belgian Financial Sector, to the proposal for a Framework for Financial Data Access (FIDA).

AEIP Urges Alignment of EU Open Finance with Pension Tracking

European Association of Paritarian Institutions of Social Protection, 24 Oct 2023

AEIP requests that the new framework builds on existing national pension tracking services. They also urge the exclusion of disability data to prevent unfair discrimination.
This approach prevents expensive administrative overhauls for non-profit pension institutions and their members.
Pension beneficiaries face lower benefits if funds must pay for redundant data systems.

Consultation response

Federation of European Risk Management Associations, 31 Oct 2023

The Federation of European Risk Management Associations (FERMA) is a European professional association, which represents, through its 22 Member Associations in 21 countries, nearly 5,000 risk professionals. FERMA speaks on behalf of professional risk managers. Within our membership network, there…

Mortgage lenders warn FIDA proposal risks competition from BigTech

European Mortgage Federation - European Covered Bond Council, 31 Oct 2023

The mortgage industry wants data sharing limited to raw information and exclusion of sensitive creditworthiness assessments. They also recommend extending the implementation timeline and clarifying definitions to avoid confusion.
Excluding sensitive loan data protects mortgage lenders from competitors exploiting their internal creditworthiness methodologies.
Tech giants lose easy access to customer profiles if strict reciprocity rules are implemented.

Consultation response

Finance Norway, 23 Oct 2023

Please find Finance Norways feedback on the Commissions proposal for a regulation of Financial Data Access enclosed.

Consultation response

SIBS SGPS, SA, 1 Nov 2023

SIBS welcomes the current draft proposal for a Financial Data Access regime in the context of a wider Data Economy and is committed to contribute to the success of its implementation. A data economy where consumers are the real owners of their data could empower them to use relevant information for…

Consultation response

European Third Party Providers Association, 31 Oct 2023

For several years, ETPPA has contributed to the European Commissions work in the Financial Data Access arena by participating in its Financial Data Space Expert Group, its Open Finance report and providing feedback to its targeted consultation. We are pleased that some of our recommendations were…

AMICE demands data reciprocity and sensitive information exclusions

AMICE - Association of Mutual Insurers and Insurance Cooperatives in Europe, 1 Nov 2023

AMICE recommends excluding health data and proprietary information from the data-sharing mandate. They also advocate for an explicit reciprocity clause with tech giants and an extended implementation timeline.
This would protect their intellectual property and prevent competition imbalances with tech giants.
At-risk policyholders could face much higher premiums if mutual solidarity models are weakened.

Consultation response

AMICE - Association of Mutual Insurers and Insurance Cooperatives in Europe, 2 Aug 2022

While the development of innovative technologies and better access to more data creates opportunities to better serve consumers, it also calls on policymakers to ensure that consumers are even further protected. AMICE welcomes the opportunity to provide feedback to the European Commission’s call…

Consultation response

Fitch Ratings Ltd, 1 Nov 2023

Fitch Ratings appreciates the opportunity to review and comment on the Proposal. We set forth in the attached letter our observations and suggestions regarding the Proposal; we have only responded with respect to those elements about which we have comments. Fitch Ratings is strongly of the opinion…

Consultation response

PensioPlus, 24 Oct 2023

Occupational pension funds (IORPs) are included in the scope of this proposal. PensioPlus stresses that second pillar pension funds are inherently different from other financial market entities. IORPs are not-for-profit, they operate in a triangular relationship with social partners and do not have…

Consultation response

Verbond van Verzekeraars / Dutch Association of Insurers, 1 Nov 2023

The Dutch Association of Insurers welcomes the proposal of the European Commission with respect to the framework for Financial Data Access (FIDA). Please find our feedback on FIDA in attached document.

Consultation response

Insurance & Pension Denmark (Forsikring & Pension), 1 Nov 2023

Please find the feedback of Insurance & Pension Denmark in the attached file.

Consultation response

Assuralia, beroepsvereniging van verzekeringsondernemingen, 31 Oct 2023

FIDA should exclude pension data when already shared under an existing national pension tracking service (NPTS). In several MSs, data related to occupational pensions are already made accessible to customers and third parties through a NPTS. In Belgium, a well-functioning and well-established NPTS…

Consultation response

Association of Credit Card Issuers in Europe, 31 Oct 2023

The Association of Credit Card Issuers in Europe represents the specialised credit card issuing industry in the EU. ACCIE welcomes the Commission's proposals for a new Framework for Financial Data Access. Our feedback can be found in the attached file.

Consultation response

AMF Italia - Associazione Intermediari Mercati Finanziari, 31 Oct 2023

Assosim expresses its general appreciation for the effort of the European Commission to establish a framework governing access to and use of customer data in finance, which could facilitate access to data also by smaller market participants at more proportionate costs. Nevertheless, in a…

Consultation response

European DataWarehouse GmbH, 27 Oct 2023

Dear Sirs, please see attached the European DataWarehouse GmbH response. Kind regards Marco Angheben

Consultation response

Associazione Italiana Private Banking, 1 Nov 2023

Please find enclosed the AIPB (Italian Association of Private Banking) feedback on the European Commissions Proposal on Financial Data Access (FIDA). Best regards, AIPB

Consultation response

European Association of Credit Rating Agencies, 12 Oct 2023

In the attached position paper, we argue that the inclusion of credit rating agencies ("CRAs") in FIDA poses material challenges to the business of CRAs but also contradicts the fundamental principles of the CRA Regulation.

Consultation response

Finansforbundet Danmark, 2 Aug 2022

Finansforbundet takker for muligheden for at kunne bidrage til Kommissionens arbejde med rammeværket for open finance og muliggørelse af datadeling og tredjepartsadgang i den finansielle sektor. Se venligst Finansforbundets vedhæftede svar.

Consultation response

Polska Izba Ubezpieczeń, 1 Nov 2023

FIDA regulation will have a significant impact on the Polish insurance companies and insurance intermediaries and their relationships with the immediate economic environment, including insurance company clients, entities cooperating with insurance companies, and potential future insurance company…

Consultation response

Fédération Nationale de la Mutualité Française, 31 Oct 2023

The FNMF shares the overall objective of having a regulatory framework to foster innovation in the insurance sector. Nevertheless, the FNMF remains vigilant about this project, given the negative impacts it could have on insurers and, above all, on policyholders. Find attached our position paper.

Adigital calls for unified financial data sharing framework

Asociación Española de Economia Digital, 31 Oct 2023

Adigital suggests merging financial data rules into one framework to simplify operations. They argue that companies should only share raw data, not processed insights. They also seek legal immunity for data holders when third parties misuse data.
This would lower compliance costs and reduce legal liability for data misuse.
Third-party service providers lose access to valuable processed consumer insights.

Consultation response

Fédération Européenne des Conseils et Intermédiaires Financiers, 31 Oct 2023

On 28th June 2023, the European Commission presented a proposal for a regulation on an Open Finance Framework, with a view to enable consumer data sharing and third-party access in the financial sector, in light of the EU digital finance strategy. With this response to the consultation, the…

Consultation response

Association des Assureurs Mutualistes, 31 Oct 2023

While the Commission states that "these proposals are focused on the interests of consumers, competition, security and trust", mutual insurers stand by the legislator to promote together a set of tools and mechanisms at the service of these issues. As introduction, mutual insurers respond by…

Consultation response

Asociación Nacional de Establecimientos Financieros de Crédito (ASNEF), 27 Oct 2023

Please find attached the comments from ASNEF, the Spanish Finance Houses Association, duly registered in the Transparency Registry with nº 11218815591-29, with regards to the European Commission's proposed Regulation on the Financial Data Access Framework. ASNEF wants to remind the European…

Consultation response

Federation of European Business Information Services, 27 Oct 2023

Please find atttached the comments from FEBIS , the Federation of Business Information Services on the proposed Financial Data Access regulation. FEBIS members are business information providers whose core business is to provide business information reports , creditworthiness assessments, credit…

Consultation response

BIPAR - European Federation of Insurance Intermediaries, 1 Nov 2023

BIPAR is the European Federation of Insurance Intermediaries. It groups 47 national associations in 30 countries. Through its national associations, BIPAR represents the interests of insurance agents and brokers and financial intermediaries in Europe. Besides some large multinationals, the…

Consultation response

Verband der Auslandsbanken in Deutschland e.V. / Association of Foreign Banks in Germany, 1 Nov 2023

Please find attached the Position Paper of the Association of Foreign Banks in Germany (VAB) of 1 November 2023 on the Proposal for a REGULATION OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL on a framework for Financial Data Access and amending Regulations (EU) No 1093/2010, (EU) No 1094/2010, (EU)…

Consultation response

aba Arbeitsgemeinschaft für betriebliche Altersversorgung e.V., 1 Nov 2023

Die aba Arbeitsgemeinschaft für betriebliche Altersversorgung e.V. ist der deutsche Fachverband für alle Fragen der betrieblichen Altersversorgung in der Privatwirtschaft und dem öffentlichen Dienst. Satzungsgemäß setzt sich die aba neutral für den Bestand und Ausbau der betrieblichen…

Consultation response

Finance Innovation, 31 Oct 2023

Finance Innovation, is a trusted hub for the financial sector. It focuses on digital and sustainable transformation, supporting innovative projects by startups and helping major groups identify trends. By bringing together finance industry players, Finance Innovation fosters partnerships and…

Consultation response

ASSOCIAZIONE NAZIONALE CONSULENTI FINANZIARI, 30 Oct 2023

We are basically satisfied with the proposal for a regulation presented by the Commission. However, we consider it appropriate to specify in the Regulation, in a clear manner, that is permissible the compensation for data retention by the data holders, and that it is not instead permissible to…

Consultation response

Free Insurance Data Initiative, 30 Oct 2023

Sehr geehrte Damen und Herren, anbei übersenden wir unsere Stellungnahme zum Verordnungsentwurf "Framework for Financial Data Access". Wir freuen uns über die entsprechende Berücksichtigung. Gerne stehen wir bei Rückfragen auch persönlich zur Verfügung! Mit freundlichen Grüße Julius Kretz (Vorstand…

Consultation response

Media Scope Group OÜ, 26 Sept 2023

Please kindly find the position paper attached.

Portuguese consumer group demands unified dashboards and data safeguards

Associação Portuguesa para a Defesa do Consumidor, 16 Aug 2023

DECO calls for guidelines on credit scoring and stricter safeguards against using sensitive personal data. They also recommend standardized or single dashboards to prevent consumer confusion when managing data permissions.
Consumers gain stronger privacy protections and more intuitive tools for managing their financial data sharing.
Financial firms lose the ability to exploit sensitive personal data for profiling and pricing.

Consultation response

YUTA - national association of travel agencies in Serbia, 2 Aug 2022

Covid - 19 crises explicitly has shown the fragllity of the business processes in many sectors . The one of the most sensitive, certainly, has been the tourism ecosystem (not just because it is composed from traveling, hosting, selling, marketing and organization & logistic processes, but also…

Consultation response

Global Institute for Structure relevance, Anonymity and Decentralisation i.G., 1 Jul 2022

I think it is the wrong way to soften data protection regulations more and more and at the same time to complicate the handling for the user for legal compliance. I refer to the GISAD statement on the Digital Euro at…