The proposal aims to clearly regulate access to, sharing and use of personal financial data. By facilitating access to data, the Commission wants to promote innovation and data-based business models in the EU financial sector. These ambitions are inevitably in tension with the fundamental rights to data protection and privacy, which take precedence over purely economic interests.

In AK’s view, a better balance between the interests of the data economy and those of consumers is needed. Among other things, AK is calling for a separate legislative act that sets precise limits for the use of financial and behavioural data for the purposes of assessing and forecasting creditworthiness. It would be desirable to have precise sector-specific requirements that go beyond the general principles of the GDPR, for example with regard to information and consent rights, purpose limitation, data security and advertising prohibitions.