The implementation of the open finance system in Colombia: transition towards an open data ecosystem

By Daniel Peña Valenzuela, Partner at Peña Mancero Abogados

Introduction

Decree 368 of 2026 introduced in Colombia the Mandatory Open Finance System, conceived as an institutional and technological transformation mechanism within the financial sector. This system constitutes the first step towards a broader model of data exchange, aimed at fostering innovation, competition, and financial inclusion. The main challenges lie in: (i) achieving a gradual implementation that ensures technical interoperability, (ii) safeguarding financial consumer protection, and (iii) preserving prudential stability, while building a trust-based ecosystem around data as a public resource.

1. Building the Open Finance System

The system is based on a hybrid model of mandatory and voluntary participation, accompanied by differentiated timelines according to the category of data. The implementation sequence foresees an initial six‑month phase for the definition of technical standards, followed by a twelve‑month period for the establishment of the Participants’ Directory and monitoring indicators. Effective access to information will be enforceable twelve months after the issuance of each standard, allowing entities to develop technical and operational capacities before assuming the obligations provided. The model will be mandatory for entities supervised by the Financial Superintendence, which must share information under the express authorization of clients. This scheme relies on a data governance system based on informed consent, an interoperable infrastructure supported by application programming interfaces, and periodic supervisory mechanisms. The creation of a Participants’ Directory and quarterly monitoring indicators seeks to ensure that the incorporation of new actors occurs without redesigning the system. Implementation also requires companies to strengthen their management of digital payments, insofar as open finance represents the next stage of sectoral development. The inclusion of the financial sector from the design phase reflects the intention to avoid regulatory lag and to adapt the system to the specificities of each subsector, such as cooperatives or insurers. In this context, any citizen will be able to authorize in seconds the use of their information to access better credit, insurance, or investment products, without physical procedures or additional certificates.

2. The Transition towards Open Data

Beyond open finance, the ultimate objective is to move towards an Open Data model involving heterogeneous sectors such as telecommunications, health, public services, and tax databases. Coordination among actors with different levels of digitalization and supervisory frameworks constitutes one of the main regulatory challenges. Building trust in information exchange becomes indispensable, especially regarding the progressive incorporation of non‑supervised providers such as fintech and insurtech, whose participation must avoid regulatory arbitrage. The balance between prudential stability and competitive openness requires a reinterpretation of regulation as a driver of innovation, beyond its traditional risk‑limiting function. The true purpose of the system demands the consolidation of an Open Data ecosystem integrating the financial, insurance, solidarity, and other sectors. This ecosystem must generate real value for citizens, facilitating access to credit, insurance, and investment products under more favorable and transparent conditions. In particular, the aim is to expand credit coverage, which remains low—between 35% and 40% of the adult population—highlighting the need to deepen financial inclusion in the country.

Conclusions

The Open Finance System represents a milestone in Colombian public policy, establishing the foundations for a model of information exchange that seeks to democratize access to financial services and promote innovation. Its gradual implementation and interoperable technical design are significant advances, but success will depend on institutional capacity to manage the transition towards Open Data. Trust‑building, intersectoral coordination, and consumer protection are necessary conditions for the system to fulfill its purpose of inclusion and competition. Ultimately, the challenge is not only regulatory or technological, but cultural: recognizing data as a public good and a driver of sustainable development. Information openness must be understood as a public policy tool which, far from being an end in itself, is oriented towards transforming the relationship between citizens and the financial system, expanding access opportunities and strengthening transparency in the digital economy.