Colombia is taking a significant step forward towards a mandatory Open Finance system, marking a new era of financial accessibility and inclusivity. The country’s financial sector is poised for transformation as Section e) of Article 88 of Law 2294 of 2023, which the Superintendent of the SFC has indicated will be officially published in the next few weeks, mandates the Ministry of Finance and Public Credit to create tools and programmes that will expand access to financial services and credit.
The objective of the decree, which will establish a mandatory participation framework for all public and private entities holding relevant financial data, is to enhance the availability of financial data to better assess individuals’ financial profiles, facilitating more inclusive and effective financial solutions.
The scope of data sharing includes standardised personal, semi-private and public financial information, encompassing deposits, credit, insurance and investment products. A minimum requirement is the provision of transactional histories spanning at least 12 months for deposit products, ensuring a solid foundation for financial analysis. Robust data protection and cybersecurity measures will be essential to safeguard consumer information in this mandatory sharing system.
A wide range of financial entities fall under the regulatory scope of the decree, including banking establishments, financing companies, financial cooperatives, companies specialising in electronic deposits and payments, trust companies, stock brokerage firms, investment management firms, pension and severance fund management companies and insurance entities. Additionally, entities operating under special financial regimes, as outlined in Part Ten of Decree 663 of 1993 and Special Official Institutions recognised as credit establishments in their founding legislation, are also included. Unlike in other jurisdictions, the Colombian framework does not segment participants by asset volume or customer base, ensuring a level playing field across financial institutions.
The governance of the Open Finance system will be spearheaded by the Colombian Financial Superintendence (SFC), which will lead a public-private governance model. This approach aims to establish standards that promote interoperability, security and innovation. Technical standards will be defined through working groups consisting of industry experts to ensure a seamless and efficient ecosystem. Entities participating in Open Finance may charge fees to recover infrastructure costs; however, these charges must be objective and must not create barriers to competition. A reciprocity principle will also be in place, requiring third-party recipients that process financial data to contribute their data back into the system, ensuring equitable participation across stakeholders.
For financial institutions, this decree brings both challenges and opportunities. It reduces barriers to market entry, fostering enhanced competition and requiring institutions to modernise their infrastructure to comply with standardised API requirements and secure data exchanges. At the same time, financial institutions will gain access to a broader pool of shared financial data, enabling them to offer more personalised and competitive financial products and services.
For third-party recipients, the decree presents an opportunity to innovate and develop tailored financial solutions that improve customer experiences. However, they must also meet technical and security standards to participate in the ecosystem effectively, which may pose initial hurdles for some organisations.
The decree outlines a phased implementation plan. Within 12 months of its publication, the Colombian Financial Superintendence must establish a schedule to standardise the specified information. Banking entities will be required to comply within six months of the publication of these standards, while other entities will have 12 months to align with the new framework. Additionally, a participant directory must be launched by the SFC within 12 months to ensure transparency and accountability among stakeholders.
To prepare for the new regulatory landscape, financial institutions must focus on infrastructure modernisation, ensuring their IT systems are equipped for API interoperability and cybersecurity compliance in line with the new standards. Active participation in governance working groups will be crucial to help shape the technical framework and ensure alignment with industry needs. Institutions must also prioritise compliance readiness by engaging with regulatory bodies for verification and registration and aligning their data practices with transparency and data protection regulations. Furthermore, training initiatives should be implemented to equip staff with the necessary knowledge on the technical and legal aspects of the new Open Finance system.
The implementation of this decree offers substantial market opportunities. Increased financial inclusion is a key benefit, as access to diverse data sources enables more accurate credit profiling and the development of tailored financial products. The regulatory framework also fosters innovation by encouraging competition and facilitating the emergence of new financial services such as account aggregation and payment initiation. A more competitive and transparent financial ecosystem is expected to drive economic efficiency and consumer trust, contributing to Colombia’s broader economic growth.
While these benefits are promising, careful planning and coordination will be necessary to ensure a smooth transition. It is clear that we are now entering a new era of data-driven finance and Open Finance represents the new normal. This transformation is inevitable and the decree provides the necessary regulatory perimeter for innovation to flourish in a trusted and structured manner.
Financial entities will need to assess the required technological investments and compliance efforts, balancing innovation with practical implementation. Additionally, developing standardised technical requirements that balance inclusivity, security and competition remains a complex task. Ensuring seamless interoperability among participants will be another critical challenge. Consumer education will also play a vital role as many individuals and businesses may not yet fully understand the benefits or risks associated with Open Finance. Without adequate awareness and trust, adoption rates could be hindered. However, embracing these changes will enable financial institutions to position themselves at the forefront of innovation, creating a more dynamic, inclusive and competitive financial ecosystem in Colombia.
Once officially published in the government’s Diario Oficial, this decree will position Colombia as a leader in financial inclusion and innovation within Latin America. To maximise its benefits while mitigating challenges, financial institutions, third-party recipients and other stakeholders must begin preparing now. By aligning their strategies with the new regulatory requirements, they can ensure a smooth transition into the Open Finance era, fostering a more dynamic and accessible financial landscape in Colombia.
