Open banking in Ukraine: a new stage

Ukraine has moved to a new stage in the process of implementing open banking, as on 11 August the National Bank of Ukraine (NBU) published on its official website the approved Open Banking Concept and the introduction plan.

The regulator's experts worked on the document jointly with working groups of market participants, including banks, non-bank financial institutions, payment providers, payment systems, IT companies and other organisations that believe that open banking will have a significant impact on their business and want to be ahead of the curve.  One of the most active and numerous groups that has been involved in the process and is currently working on the development of standards and specifications is the OpenApiGroup.

According to the published document, by the end of 2023, together with the working groups, it is planned to develop the first version of the technical specifications, and in the 2nd quarter of 2024, to conduct testing for a limited set of APi and identify possible gaps and areas for documentation improvement. No later than in the 3rd quarter of 2025, the NBU will conduct a pilot on a product environment with a limited number of participants and launch the innovation for the entire market by 1st August 2025 (from this date, banks and non-banks with accounts will have to open interfaces and share customer information with certified TPP providers with their consent), as well as support the new payment infrastructure and other interactions provided for in the specification.

At the same time, the NBU plans to develop general approaches to supervising market participants in the process of interaction within the framework of open banking, consumer protection, IT security, and personal data protection, and will compile and update the regulatory framework necessary for the implementation of open banking.

It is worth noting that the Berlin Group standards were used as a basis for developing the technical specification. Starting with the adoption of the Law of Ukraine "On Payment Services" in 2021, which marked the beginning of the introduction of open banking, Ukrainian experts have been studying European experience, engaging foreign experts, and analysing which models are more suitable for our market.  On the one hand, our approaches should be compatible with the European payments market, and on the other hand, they should take into account local features. It was also important to take  into consideration the weaknesses that were identified after the introduction of open banking in Europe and to levelling them when developing our concept.

In this way, given that most market solutions are developed on the basis of an open API structure, the introduction of open banking is a logical lstep that will transform the payment market, stimulate the development of fintechs, increase competition among payment market participants, open up new opportunities for the development and scaling of the ecosystem, while the regulator (NBU) will ensure a high level of user rights protection and data security.