⚠ Draft legislation: status as of 6 June 2026: FIDA is not law. This tool scores readiness against the European Commission proposal COM(2023) 360 (28 June 2023) and the Council General Approach (4 December 2024). Trilogue negotiations began April 2025 and were reported paused in early 2026; adoption timing, final scope, and all obligations below may change materially. If adopted, application is expected in phases starting roughly 24+ months after entry into force. Treat every determination as horizon planning, not a compliance conclusion: re-verify against the current legislative state before relying on any output.

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1 · Entity Profile & Role (draft Art. 2: scope)

Entity type

Intended role under FIDA

EU establishment / EU customers

2 · Customer Data Categories Held or Sought (draft Art. 2(1))

Mortgages, loans & credit

Credit agreements, balances, conditions: incl. data collected for creditworthiness assessment of firms.

Savings & non-payment accounts

Savings balances and conditions. (Payment account data stays under PSD2/PSR: excluded from FIDA.)

Investments in financial instruments

MiFID instruments, holdings and transactions, incl. insurance-based investment products (IBIPs).

Crypto-assets

Holdings/transactions in crypto-assets held via MiCA-regulated providers.

Pension rights

Occupational pension rights (IORP II) and pan-European personal pension products (PEPP).

Non-life insurance products

Non-life insurance data per the draft (life cover and consumer sickness/health data carved out).

Creditworthiness data (consumers)

Data collected as part of a consumer creditworthiness assessment: scope contested in trilogue; verify.

3 · Financial Data Sharing Scheme (FDSS) Readiness (draft Title IV / Art. 9–10)

FDSS membership strategy definedDraft requires holders & users to join a scheme governing data access: membership route identified Common data standards / dictionaries mappedIn-scope data mappable to scheme-level standardised formats and API specifications Compensation model assessedUnlike PSD2, the draft allows holders reasonable compensation for data access: pricing basis prepared Liability & dispute-resolution framework reviewedScheme-level contractual liability and dispute mechanism obligations understood Data-user authorisation path confirmedData users not otherwise authorised need FISP authorisation (draft Title VI): status checked

4 · Permission Dashboard Obligations (draft Art. 8)

Permission dashboard capability plannedHolders must give customers a dashboard to monitor and manage data permissions Real-time overview of granted permissionsDashboard shows each permission: data user, data categories, purpose, duration Withdrawal as easy as grantingOne-step permission withdrawal wired through to data-user notification Permission records retainedHistory of granted/withdrawn permissions kept for audit and customer review

5 · Technical & Data Access Readiness (draft Art. 5–6)

Continuous real-time access interface feasibleDraft requires making data available without undue delay, continuously, in real time Machine-readable, standardised formatsIn-scope data exportable in commonly used machine-readable formats Data quality & lineage controlsData made available matches what the holder uses internally: same quality obligation Customer authentication & secure access designAccess only with customer permission, securely authenticated

US CFPB §1033 ↔ EU FIDA: Structural Comparison (informational)

Dimension	US CFPB §1033	EU FIDA (draft)
Legal status	Final rule issued Oct 2024; subject to ongoing litigation/reconsideration: see T165 for current treatment	Proposal in trilogue (paused early 2026); not adopted
Data scope	Payment accounts, credit cards, and related consumer financial data	Broad open finance: credit, savings, investments, insurance, pensions, crypto (payment accounts stay under PSD2/PSR)
Who must share	Data providers (banks, card issuers) tiered by size	"Data holders" across nearly the whole financial sector
Who may access	Authorized third parties acting on consumer request	"Data users": regulated entities or authorised FISPs
Compensation	Fees to consumers/third parties for required access prohibited under the rule as issued	Reasonable compensation to data holders permitted via scheme
Scheme / standards body	Recognised standard-setting bodies (e.g. consensus standards)	Mandatory Financial Data Sharing Schemes (FDSS) with contractual frameworks
Consumer control	Authorization, revocation, 1-year reauthorization cadence (as issued)	Permission dashboards at every data holder
Related AINumbers tools	T165 · T166 · T167	This tool (T273: readiness scoring) · T360 (field-level data-scope mapping)

Sources: COM(2023) 360 final (28 Jun 2023); Council General Approach ST-16312/24 (4 Dec 2024); 12 CFR Part 1033 (Oct 2024). Both regimes are moving targets: re-verify before relying. Last reviewed: 2026-06-06.

EU FIDA / Open Finance Readiness Scorer