Is Ukraine about to join the open banking race? – Lexology
On 12 November 2020, the Ukrainian Parliament published a draft payment services law (available in Ukrainian), that was prepared with the Ukrainian central bank (NBU). Among other things, the draft law would implement a regulatory framework for open banking similar to the EUs PSD2 (Directive 2015/2366). PSD2 requires banks to share data from their clients payment accounts free of charge with third party providers (TPPs) without any underlying commercial agreement thereby allowing TPPs to offer new payment services to consumers.
Paul Rohan, in his book PSD2 in Plain English has suggested that in practical terms, open banking requires banks to build and publish an Application Programming Interface (API). An API permits a piece of software to read data from the system of the API publisher (in this case, a bank). Therefore, to comply with PSD2, a bank will publish an API, similar to publishing a website, and disclose relevant payment account data to all eligible TPPs.
Is the API economy an entirely new phenomenon in Ukraine?
Publication of APIs was not invented by the authors of PSD2; they were in use before the adoption of PSD2. For instance, many Ukrainian banks publish their own APIs to enable collaboration with the API developers community. In fact, according to one of the largest Ukrainian banks, it was the first bank globally to make a public API available for developers in September 2009, that is used today by approximately 5,000 API developers and clients in both Ukraine and abroad. Moreover, a number of banks publish a partner API, which is available to partner companies to facilitate commercial projects. In Paul Rohans view, a partner API is a stepping stone for a bank to offer a public API.
But the key difference between then and now is that before PSD2, the sharing of account data (i.e., publishing APIs) was not mandatory. In Ukraine, this particular aspect of PSD2 was the subject of much debate and controversy between the NBU and market participants. It was not clear until the publication of the draft law last November whether this requirement would be included in the text as opposed to a discretionary option.
It now looks like the Ukraine is to join those countries wanting to boost their digital economies by way of regulatory intervention Article 54 of the draft law makes it mandatory for banks to share data with TPPs. As result, the Ukraine will join those jurisdictions pursuing the regulatory intervention path. In particular, it may be allocated to a subgroup of countries (e.g., Albania and Northern Macedonia) that implement PSD2 under their existing association agreements with the EU and its Member States. Another group of jurisdictions have non-regulatory initiatives coordinated by market participants without the intervention of the state (e.g. USA, Nigeria etc.). The chart below shows the dynamics in this space, however, as this is a dynamic scenario new jurisdictions may appear on this map as we speak.
Standardization of APIs
It is curious that Paul Rohan compares APIs with an electricity wall socket, which is an interface with an electricity supply, with predictable patterns of opening in the wall sockets, so producers of electric appliances know what to expect. Likewise, APIs are useful in this context because it is not straightforward to pull data from a third party system (i.e., from banks numerous information systems). A standard API can make the operation of a TPP easier in the sense that it need not worry about how to access data, but rather focus on building the service it offers to the consumer. In other words, API developers should know what to expect, in terms of API features, when developing software and avoid reinventing the wheel each time they want to obtain data from a particular bank.
PSD2 itself did not address this issue. Rather, it instructed the European Banking Authority to develop the requirements for common and secure open standards of communication (RTSs), i.e., only technical framework conditions with no interface standard. To help fill this gap of a common standard, a number of market initiatives have emerged in EU, including a group of European banks and payment service providers, the Berlin Group, whose API framework is called NextGenPSD2. Similarly, the draft Ukrainian law envisages that the NBU will adopt data security and communication requirements concerning end users, banks and TPPs when accessing consumers accounts. Apparently, the question of an API standard is about to emerge.
The NBU have indicated that (i) the open banking launch may be feasible in Ukraine in 2022 and (ii) that it would launch a market stakeholders working group shortly to consult on the issue of API standardization. It seems that one of the options to move this initiative forward might be to leverage existing market experience of tech savvy banks in developing an API economy.
See the original post:
Is Ukraine about to join the open banking race? - Lexology
- Fibre optic drones: The terrifying new weapon changing the war in Ukraine - BBC - May 28th, 2025 [May 28th, 2025]
- Ukraine Demands Russia Present Peace Plan Immediately Instead Of Waiting For Talks Next Week - Radio Free Europe/Radio Liberty - May 28th, 2025 [May 28th, 2025]
- In Oklahoma, Role-Playing Battles Borrow From the Russia-Ukraine War - The New York Times - May 28th, 2025 [May 28th, 2025]
- Ukraine and Russia set to meet for new round of talks in Istanbul - The Washington Post - May 28th, 2025 [May 28th, 2025]
- Germany and Ukraine to jointly develop new long-range weapons as U.N. experts accuse Russia of war crimes - CBS News - May 28th, 2025 [May 28th, 2025]
- Trump gives Putin 2 weeks for action on Ukraine as relationship frays - politico.eu - May 28th, 2025 [May 28th, 2025]
- Vladimir Putin issues his conditions for ending the war in Ukraine - New York Post - May 28th, 2025 [May 28th, 2025]
- Trump attacks Putin over Ukraine onslaught but will he impose consequences? - ABC News - May 28th, 2025 [May 28th, 2025]
- Russia proposes to hold next talks with Ukraine in Istanbul on June 2 - Reuters - May 28th, 2025 [May 28th, 2025]
- Germany and Ukraine sign 5B deal on long-range weapons cooperation - politico.eu - May 28th, 2025 [May 28th, 2025]
- Ukraine braces for expected Russian summer offensive in the east - The Washington Post - May 28th, 2025 [May 28th, 2025]
- Ukraine-Russia war: Germany to make long-range missiles with Ukraine and gives 5bn more in military aid as it happened - The Guardian - May 28th, 2025 [May 28th, 2025]
- Trump says Putin 'playing with fire' as US weighs new sanctions over Ukraine - France 24 - May 28th, 2025 [May 28th, 2025]
- Russia says Ukraine, backed by Europe, is trying to wreck peace talks - Reuters - May 28th, 2025 [May 28th, 2025]
- Putin Wants End to NATO Expansion, Sanctions Relief for Peace in Ukraine Reuters - The Moscow Times - May 28th, 2025 [May 28th, 2025]
- Trumps frustration with Putin boils over with no Ukraine peace deal in sight - The Washington Post - May 28th, 2025 [May 28th, 2025]
- Russia's advance in Ukraine's north east may be bid to create 'buffer zone' - BBC - May 28th, 2025 [May 28th, 2025]
- Trump warns Putin he is playing with fire after Russian attack on Ukraine - The Guardian - May 28th, 2025 [May 28th, 2025]
- Trump holds off on sanctions to push Ukraine-Russia peace efforts - The Kyiv Independent - May 28th, 2025 [May 28th, 2025]
- Russia Bombards Ukraine With One of Largest Air Assaults of the War - The New York Times - May 28th, 2025 [May 28th, 2025]
- Russia Defies Trump With Largest-Ever Drone-and-Missile Attack on Ukraine - WSJ - May 28th, 2025 [May 28th, 2025]
- US and Russia clash over intensifying Ukraine war - USA Today - May 28th, 2025 [May 28th, 2025]
- Russia proposed new date and location for peace talks with Ukraine, Medinsky says - The Kyiv Independent - May 28th, 2025 [May 28th, 2025]
- Trump says he will call Putin, then Zelenskyy, on Monday to push for Ukraine ceasefire - AP News - May 17th, 2025 [May 17th, 2025]
- Trump and Putin Say They Will Discuss Ukraine Peace Proposals on Monday - The New York Times - May 17th, 2025 [May 17th, 2025]
- The chilling moment in Russia-Ukraine peace talks - as Putin makes mockery of Trump's efforts to end war - Sky News - May 17th, 2025 [May 17th, 2025]
- I was U.S. ambassador to Ukraine. I resigned because of Trump's foreign policy. | Opinion - Detroit Free Press - May 17th, 2025 [May 17th, 2025]
- Trump and Putin to talk about possible ceasefire between Ukraine and Russia - MSNBC News - May 17th, 2025 [May 17th, 2025]
- Russia says Ukraine talks yielded a prisoner swap deal and an agreement to keep talking - Reuters - May 17th, 2025 [May 17th, 2025]
- The Kremlin fixes conditions for new Ukraine talks, Trump to speak with Putin on Monday - France 24 - May 17th, 2025 [May 17th, 2025]
- As political theater took center stage in Turkey, the war went on in Ukraine. Kyiv has few options - AP News - May 17th, 2025 [May 17th, 2025]
- Zelensky insists he will only join Ukraine-Russia talks in Turkey this week if Putin is present - CNN - May 17th, 2025 [May 17th, 2025]
- A day of confusion and chaos as Russia and Ukraine agree to first direct talks in 3 years - CNN - May 17th, 2025 [May 17th, 2025]
- Russia and Ukraine far apart on ceasefire in first meeting in 3 years - Axios - May 17th, 2025 [May 17th, 2025]
- US says Trump and Putin needed for breakthrough in Ukraine talks - BBC - May 17th, 2025 [May 17th, 2025]
- Trump says Ukraine-Russia peace 'not going to happen' without Putin meet - ABC News - May 17th, 2025 [May 17th, 2025]
- Former US ambassador to Ukraine says she resigned because of Trump's foreign policy - Reuters - May 17th, 2025 [May 17th, 2025]
- Ukraine war latest: Russia 'demands five Ukrainian regions' in talks; father, mother and daughter 'among nine killed' in bus strike - Sky News - May 17th, 2025 [May 17th, 2025]
- Russia and Ukraine are due to meet. But with Putin a no-show, confusion reigns. Heres what we know - CNN - May 17th, 2025 [May 17th, 2025]
- Ukraine-Russia war latest: Trump will speak with Putin on Monday - The Telegraph - May 17th, 2025 [May 17th, 2025]
- New head of Russian land forces distinguished himself in Ukraine - Reuters - May 17th, 2025 [May 17th, 2025]
- Trumps Ukraine Policy Pressured the Victim, Former Ambassador Says - The New York Times - May 17th, 2025 [May 17th, 2025]
- Putin Still Holds All the Cards in Ukraine, With No Reason to Fold - Bloomberg - May 17th, 2025 [May 17th, 2025]
- Kremlin says a Putin-Trump meeting on Ukraine is essential but needs advance preparation and must yield results - Reuters - May 17th, 2025 [May 17th, 2025]
- Vatican could be a venue for Russia-Ukraine talks, Rubio says, after pope renews an offer to help - AP News - May 17th, 2025 [May 17th, 2025]
- Trump 'starting to doubt' that Ukraine will reach deal with Russia - Reuters - May 11th, 2025 [May 11th, 2025]
- Ukraine in maps: Tracking the war with Russia - BBC - May 11th, 2025 [May 11th, 2025]
- Ukraine: What Trump does next is key - and he could go either way - BBC - May 11th, 2025 [May 11th, 2025]
- Turkey ready to host Russia-Ukraine peace talks, Erdogan tells Putin - Reuters - May 11th, 2025 [May 11th, 2025]
- Never again war: Pope Leo calls for peace in Ukraine in first Sunday address - The Guardian - May 11th, 2025 [May 11th, 2025]
- Trump urges Ukraine to meet with Russia in Turkey to negotiate a possible end to the bloodbath - The Hill - May 11th, 2025 [May 11th, 2025]
- Never again war! Pope Leo calls for peace in Ukraine and Gaza in first Vatican address since his election - CNN - May 11th, 2025 [May 11th, 2025]
- Pope Leo XIV calls for peace in Gaza and Ukraine in his first Sunday address as pontiff - PBS - May 11th, 2025 [May 11th, 2025]
- Ukraine and European allies urge Putin to commit to 30-day ceasefire or face new sanctions - PBS - May 11th, 2025 [May 11th, 2025]
- Putin proposes direct peace talks with Ukraine after three years of war - CNBC - May 11th, 2025 [May 11th, 2025]
- Trump demands that Ukraine agrees to peace talks with Russia - The Times - May 11th, 2025 [May 11th, 2025]
- US and other allies of Ukraine pile pressure on Putin, threatening fresh sanctions if he refuses 30-day truce - CNN - May 11th, 2025 [May 11th, 2025]
- Europe Wants to Arm Ukraine, but Its Losing a Race Against Time - The New York Times - May 11th, 2025 [May 11th, 2025]
- Ukraine and its allies push for a 30-day ceasefire starting Monday - NBC News - May 11th, 2025 [May 11th, 2025]
- Ukraine ceasefire call is aimed at forcing Putin to reveal his war goals to Trump - CNN - May 11th, 2025 [May 11th, 2025]
- Ukraine and allies push for 30-day ceasefire that would begin on Monday, but Putin wants direct talks - CBS News - May 11th, 2025 [May 11th, 2025]
- Putin agrees to 'direct' talks with Ukraine, Zelensky offers to meet him personally - France 24 - May 11th, 2025 [May 11th, 2025]
- Pope Leo XIV calls for peace in Ukraine and Gaza in symbolically rich blessing on Mother's Day - AP News - May 11th, 2025 [May 11th, 2025]
- Russia's Putin proposes direct talks with Ukraine in Istanbul on May 15, 'without preconditions' - AP News - May 11th, 2025 [May 11th, 2025]
- European leaders tell Putin to agree to Ukraine ceasefire or face new sanctions - Reuters - May 11th, 2025 [May 11th, 2025]
- Hungary cancels meeting on national minorities with Ukraine over spying scandal - The Kyiv Independent - May 11th, 2025 [May 11th, 2025]
- Zelenskyy offers to meet Putin in Turkey - as Trump urges Ukraine to hold talks with Russia - Sky News - May 11th, 2025 [May 11th, 2025]
- Trump envoy relied on Kremlin interpreter in meetings with Putin to end war in Ukraine - NBC News - May 11th, 2025 [May 11th, 2025]
- Ukraine, allies want truce with Russia starting Monday - DW - May 11th, 2025 [May 11th, 2025]
- 'Have the meeting, now!' Trump urges Ukraine, Russia to hold direct talks - The Kyiv Independent - May 11th, 2025 [May 11th, 2025]
- US Secretary of State Rubio to attend NATO meeting on Ukraine-Russia - Reuters - May 11th, 2025 [May 11th, 2025]
- Ukraine 'ready to meet' Russia after Putin call for peace talks on Thursday, says Zelenskyy - Sky News - May 11th, 2025 [May 11th, 2025]
- Pope Leo XIV in first Sunday blessing calls for peace in Ukraine and Gaza: "Never again war" - CBS News - May 11th, 2025 [May 11th, 2025]
- Biden BBC interview: Trump appeasing Putin with pressure on Ukraine - BBC - May 11th, 2025 [May 11th, 2025]
- Putin is buying time in Ukraine, while planning to strike from three sides simultaneously - Euromaidan Press - May 11th, 2025 [May 11th, 2025]
- Trumps Ukraine ceasefire is slipping away - The Economist - April 16th, 2025 [April 16th, 2025]
- Truth, lies and the betrayal of Ukraine - Financial Times - April 16th, 2025 [April 16th, 2025]
- JD Vance offers message to Europe on security, Ukraine and Trump's tariffs in interview with U.K. outlet - CBS News - April 16th, 2025 [April 16th, 2025]
- 'Everybody's to blame': Trump accuses Zelenskyy of starting Russia's war on Ukraine - USA Today - April 16th, 2025 [April 16th, 2025]
- Zelensky urges Trump to visit Ukraine ahead of deal with Russia - BBC - April 16th, 2025 [April 16th, 2025]