SAMA's Open Banking framework is the most significant regulatory shift in Saudi banking since the introduction of SARIE. Most banks are treating it as a compliance exercise—minimum viable APIs, narrow scope, defensive posture. That's a mistake.
The banks that treat Open Banking as compliance will meet the deadline. The banks that treat it as strategy will win the next decade.
What most banks are doing
Building the minimum required APIs. Account information services. Payment initiation. Fund confirmation. Tick the box. Meet the deadline. Move on.
This approach satisfies the regulator but misses the opportunity. It's like building a highway and then only allowing one car at a time.
What the opportunity actually is
Open Banking is the foundation for ecosystem banking. The same APIs that satisfy SAMA requirements can enable:
Banking-as-a-Service (BaaS). Allowing fintechs to embed banking services into their products. Deposits, payments, and lending available through API—not through a branch.
Embedded finance. Banking services integrated into non-banking customer journeys. Buy-now-pay-later at checkout. Insurance at the point of purchase. Investment at the point of salary deposit.
Data monetization. With proper consent management, aggregated financial data becomes a product. Credit scoring, spending analytics, financial wellness tools—all built on top of Open Banking APIs.
Partner ecosystems. Third-party providers building on your platform create network effects. The more partners, the more valuable the platform. The more valuable the platform, the more partners.
What this requires organizationally
The technology is the easy part. What's hard is the organizational readiness:
Who owns the Open Banking platform as a product? Who owns the partner ecosystem? Who owns the consent management framework? Who is accountable for TPP onboarding, SLA enforcement, and dispute resolution?
If these questions don't have clear answers, the bank isn't ready for Open Banking—regardless of how good the APIs are.
This is where I focus. Not just building APIs that meet SAMA's technical requirements, but building the organizational structure, governance, and operating model that turns Open Banking from a compliance cost into a strategic asset.