One of the loudest conversations happening in the financial services industry right now is for Open Banking regulation to be succeeded by a broader notion of “Open Finance”. At the same time, we’ve seen other industry developments develop at pace: OpenAI Operator, Manus, Browser Use and others have all publicly announced their efforts to bring AI to computer and browser automation.
With all this effort being put into automatically navigating websites and forms, it raises the question: is Open Finance becoming obsolete before it even launches? Regulators will face a fresh wave of challenges with the evolution from Open Banking to Open Finance, but they might not need to worry.
Understanding the magnitude of Open Finance regulation
Despite the relatively narrow scope of Open Banking, regulators have faced tremendous challenges. The EU’s PSD2 directive was introduced 10 years ago, and the compliance by the banks has been collectively facetious and performative. So much so that a successor was announced in the summer of 2023 to tackle the issue.
However, with the far broader range of services that Open Finance captures compared to the relatively simple transactional banking that Open Banking covers, regulators may have to tackle an even longer tail of non-compliance if approaching regulation in the same way.
Open Finance’s scope would stretch across a complex ecosystem of financial institutions, insurers and investment platforms. Defining a blanket API spec per product category – which is what was done with Open Banking – will present massive coordination difficulties, making implementation unfeasible. Even if we were to oversimplify finance down to lending and insurance, that’s already double the API spec requirements and double the legislative burden. In reality, it would be many more than two more standard APIs (e.g. splitting out active and passive investing, or life insurance and car insurance).
What’s more, Open Finance inevitably blows the doors wide open on the number of entities to regulate. Every large insurer, every small insurer, every mortgage provider, every term lender, every credit card issuer, every invoice financing firm – and that’s just the beginning. It’s a mountain of firms to bring into compliance and the long tail of laggards will be exceptionally long.
AI Agents are delivering the promise of Open Finance
However, the arrival of AI Agents, like Operator and Manus, means that Open Finance will come into existence regardless of whether the EU and UK can regulate it. These Agents promise to navigate websites as adeptly as humans; they’ll be able to log in, complete forms, submit applications, and retrieve data with precision and speed. This provides almost all of the answers to both the design and the implementation of Open Finance. Ultimately, the combination of intelligent control and the co-option of human-machine UIs by multi-modal LLMs unlocks many of the challenges with Open Finance.
Most financial institutions already have the APIs they need to perform Open Finance, so the issue is not the existence of the APIs, it’s the standardisation. Thanks to browser agents, no new API will need to be created. The agent interacts with the existing “private APIs” (i.e. non-open) through the UI layer. They just use the website, with no new standardisation layer required.
By that same logic, if a financial institution has a functioning website, they are already in compliance with this involuntary form of Open Finance. One of the key issues with PSD2 being addressed in PSD3 is that many “compliant” banks were facetiously providing public APIs with scope and performance inferior to their private equivalent. Financial institutions are incentivised to maintain a good website already. Agents will hit the website, so they’ll be hitting the most performant API: the private API. Everyone is at maximum viable compliance from the outset.
It further follows that agents will be able to access all functions related to financial products served digitally, including signup flows. Whereas in Open Banking, signup was left out, browser agents will be able to fill in all the text boxes and click all the buttons needed to progress through the signup process. If most of the consumer value of a loan is in the issuing, that will be captured by the agent and not left on the table.
Now is the time for financial firms to adapt
So how can financial institutions ready themselves for this new agentic world? Ultimately, the aim should be to make finance as agent-friendly as possible, ensuring agents can access all the information and call all the functions they need to interact with a product in feature-parity with human users.
At a very top level, this involves maintaining clean, navigable websites and avoiding tech that blocks agents. Forward-thinking institutions will adopt machine-readable structures to guide agents, reduce errors and enhance outcomes. Some more advanced firms may use protocols like the Model Context Protocol (MCP) for direct AI interaction, or develop in-house concierge agents for support and task completion at scale while staying compliant.
While these advancements don’t replace regulation for identity verification, fraud prevention, or credit risk, AI agents excel at tasks like navigating UI flows and submitting forms, where regulation often lags.
With the rise of agentic browser use, Open Finance will be the new default state. It’s not something that needs to be legislated for, and whether the bouncer lets the robot in will come down to forward-thinking executives and active participation in this new layer of the economy.
