Framework tracking
What the exposure draft proposes and what changes in the final version.
Open Finance Consent and Data Sharing Readiness
Open finance readiness is preparing the customer consent, data sharing governance and data protection an institution will need under BNM's proposed open finance framework. BNM has proposed an open finance framework built on customer consent to share data across the financial sector. We help institutions get the consent, governance and data protection side ready while the technical teams build the pipes.
Open Finance Readiness
What it is
A readiness engagement covering customer consent design, data sharing governance, third-party onboarding and data protection alignment for institutions preparing for open finance. It is a compliance and governance service, not API development.
Why organisations need it
BNM issued its Exposure Draft on Open Finance on 18 November 2025, with feedback closing on 1 March 2026, and industry reports point to a first batch of implementation proposed for 1 January 2027. The final framework has not been issued, so this is preparation, not compliance with final rules. The consent and governance decisions take longest and are hardest to change later.
What the engagement covers
Consent design
Consent capture, scope, duration, revocation and records.
Data sharing governance
Which data, to whom, on what basis, with what oversight.
Third-party onboarding
Due diligence and contracts for data recipients.
PDPA and MCIPD alignment
Notices, permitted disclosures and breach handling.
Customer communication
Explaining data sharing to customers plainly.
What the business gets out of it
Ahead of the rules
Decisions made early rather than rushed.
Consent that holds up
Records that prove what the customer agreed.
Fewer rework cycles
Governance settled before build.
Aligned with existing law
PDPA and BNM customer information rules respected.
Board clarity
Directors see the risk and the plan.
How it works
How the engagement runs
01
Briefing
Current proposals and implications.
02
Assessment
Current consent and data sharing practices.
03
Design
Consent and governance model.
04
Documentation
Policies, notices and contracts.
05
Update
Revisions when the final framework is issued.
Deliverables
What you receive
Readiness assessment
Current position against the proposals.
Consent model
Journeys, records and revocation.
Governance framework
Roles, approvals and oversight.
Third-party due diligence pack
Checklists and contract clauses.
Board paper
Position and plan.
Who it is for
Who this is built for
Industries
Company sizes
Departments
FAQ
FAQ
Not yet. BNM issued its Exposure Draft on Open Finance on 18 November 2025 and the final framework has not been published. That is why we treat this as readiness work: building the consent and governance foundations that take longest, without claiming compliance with rules that are not final.
Industry reporting points to a first batch of implementation proposed for 1 January 2027, but the final dates will be set by BNM when it issues the framework. Institutions in the first batch have little time once the rules are final, which is why consent design and governance are worth starting now.
No. We handle consent design, data sharing governance, third-party onboarding and data protection alignment. Your technology team or vendor builds the APIs and integration. The two workstreams run in parallel, and we give your technical team the consent and governance requirements their build has to meet.
Sharing customer data is processing of personal data, so PDPA consent, notice, disclosure and breach duties apply, alongside BNM's policy on customer information and permitted disclosures. Consent in particular has to be specific and understandable to the customer, which is a design decision rather than a technical one.
Unlikely. Consent records, governance structures and third-party onboarding are needed under any version of the framework, and they are the parts that take longest. When BNM issues the final framework we update the documents against it rather than starting again.