TL;DR
Thorsten Meyer AI argues that a US-style conversational finance product cannot be copied into Europe without major regulatory work. The analysis says EU open-banking, open-finance and AI rules make account access a licensed and supervised activity, not a simple API connection.
Thorsten Meyer AI said Tuesday that OpenAI’s US personal-finance surface, launched May 15, 2026 through Plaid-connected account access, would face a different regulatory path in Europe because EU rules treat financial data access, consent and some AI uses as supervised activities.
The analysis says the US rollout relied on a private aggregation layer, with users connecting accounts through Plaid across more than 12,000 financial institutions. According to Thorsten Meyer AI, that model allowed read-only financial data access without a specific financial-services license for the conversational interface itself.
In the European Union, the same activity would be shaped by several regimes. PSD2 made account access a regulated activity in 2018. Its planned successors, the Payment Services Regulation and Third Payment Services Directive, reached provisional agreement on November 27, 2025, with final texts expected in the Official Journal in 2026 and core obligations expected across 2027, according to the source material.
The analysis also points to the EU’s planned Financial Data Access regulation, known as FIDA, which would extend open-finance access beyond payment accounts to areas including investments, pensions, insurance, mortgages and loans. Thorsten Meyer AI says FIDA would create a new licensed category, the Financial Information Service Provider, for firms handling that data. The proposal was still in trilogue as of April 2026, with operations likely around 2029 to 2030, according to the analysis.
Why It Matters
The finding matters because it frames Europe as a market where the core product is not only the chat interface, but the regulated structure underneath it. A company seeking to offer a similar service in the EU would need to solve licensing, consent management, API access, data-use limits and AI classification before the consumer-facing experience could operate at scale.
The analysis says this may favor banks, licensed fintechs, regulated data-access providers and firms already built around EU financial compliance. It may reduce the advantage held by US companies whose domestic products rely on private aggregation networks and faster product launches.
European open banking API integration tools
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Background
Open banking in Europe has been shaped by PSD2 since 2018, when account information services and payment initiation services were brought into a regulated framework. The next stage, PSD3 and PSR, is expected to tighten the rulebook and make API quality part of the regulated system, according to Thorsten Meyer AI.
FIDA would broaden that model into open finance, but its final shape remains unsettled. The source material says a contested data-access fee is one of the central issues. The EU AI Act adds another layer: AI systems used for credit scoring and creditworthiness assessment are classified as high-risk, with full obligations scheduled for August 2, 2026.
“The US conversational-finance surface is a product built on a permissionless substrate, and Europe does not have a permissionless substrate.”
— Thorsten Meyer AI
“In Europe, compliance is the architecture, and the conversational experience is the thin layer on top.”
— Thorsten Meyer AI
“The European version of the US surface is not the US surface with a GDPR banner.”
— Thorsten Meyer AI
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What Remains Unclear
Several details remain open. The final PSD3 and PSR texts had not yet appeared in the Official Journal in the source material. FIDA was still in trilogue as of April 2026, and its final timing, fee model and licensing requirements may change. It is also not clear how supervisors would classify a general-purpose AI system that uses a user’s full financial profile unless it directly performs credit scoring or creditworthiness assessment.
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What’s Next
The next milestones are the publication of final PSD3 and PSR texts, the progress of FIDA negotiations, and the August 2, 2026 start of full EU AI Act obligations for high-risk systems. Companies planning conversational finance tools in Europe will need to decide whether to seek licenses, partner with licensed providers or limit features to avoid regulated activity.
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Key Questions
What happened?
Thorsten Meyer AI published a May 26, 2026 analysis arguing that OpenAI’s US personal-finance surface cannot be copied directly into Europe because EU financial-data access is governed by licensing, consent and supervisory rules.
Why does the US model work differently?
The analysis says the US product can rely on private account aggregation through Plaid. In Europe, account data access falls under regulated open-banking rules, and wider financial data access is being built into the FIDA open-finance regime.
Does this mean OpenAI cannot launch finance tools in Europe?
No. The analysis does not say such tools are impossible. It says a European launch would likely require regulated partnerships, licensing work, consent systems and AI-risk classification before a broad product could operate.
What role does the EU AI Act play?
The EU AI Act treats AI used for credit scoring and creditworthiness assessment as high-risk. Thorsten Meyer AI says a financial assistant grounded in a user’s complete financial life could come close to that boundary, depending on what the system does.
What remains unclear?
The final form of FIDA, the timing of full open-finance operations, the data-access fee model and the treatment of general-purpose AI financial assistants by national supervisors remain unsettled.
Source: Thorsten Meyer AI
