Serbia’s Open Banking market is technically ready today, but strategically unbalanced. This is confirmed by the bank maturity analysis in the fields of PSD2 regulation and Open Banking development, conducted through a joint initiative of Vista Peak Consulting and ICT Hub and based on structured surveys and direct communication with profiled banks, both large systemic institutions and agile digital players. In this way, we got a clear and consistent insight into the current standing of the market and dominant patterns of thinking.
This research was not created as an academic exercise nor as another regulation checklist, but as a starting point for understanding where the market stands today and where the realistic chances for the next advancements are. The goal was to see how the banks perceive Open Banking, not just through technical implementation, but also through a business, strategic, and ecosystemic context.
The findings point to common challenges but also to clear opportunities opening for banks ready to step out of minimum-compliance frameworks and start to view Open Banking as a tool for advancement, differentiation, and partnership.
Where are we today?
PSD2 is largely complete as a regulatory task. API’s exist. The documentation exists. Consent and Strong Customer Authentication (SCA) will most probably function well.
But in practice, Open Banking is still mostly seen as a compliance topic rather than a business tool. The following consequence is that API infrastructure often remains an expense that has no further use as a strategic asset.
Implementations are usually “functionally sufficient”; they meet regulatory requirements, but they are not optimized for developing an ecosystem, partnerships or new products. Even with technically more advanced banks we see a clear divide: the technology exists, but clear use-cases, monetization models and market differentiation are not defined.
Another important insight: different perspectives within the same bank. One of the most noticeable findings of the research is that Open Banking maturity is often seen from different perspectives within the same company. Perspectives of IT, business and compliance sectors are naturally different, not just in current situation assessment, but also in understanding priorities and potentials.
This additionally confirms how much internal coordination is key for the transition from technical implementation to the strategic phase. Without a unified narrative and a clear ownership structure, Open Banking remains “somebody else’s business” instead of a development tool.
At the same time, the survey responses clearly show typical market patterns: challenger banks are quicker but have limited capacity, while large banks have more resources but also slower decision-making dynamics.
This does not represent a market weakness, but to the contrary it opens room for smart partnerships and eco-system models. Why is „minimum compliance“ becoming a strategic risk? A bank that looks at PSD2 as a completed obligation is at risk of positioning itself exclusively as an infrastructural provider without any control over the final relations with the client or without a clear monetization of its own data and capacities.
The next phase is not new regulations.
The next phase is strategic selection. In the Open Banking environment, every bank will have to select whether it wants to be:
- a platform,
- a partner in a wider ecosystem,
- or a utility that other players will monetize.
In practice, the lack of such a choice means the market will eventually make that decision for the bank.
What happens next?
The real potential of Open Banking lies in turning existing technical capacities into concrete business scenarios like:
- embedded finance models,
- SME and micro-business services,
- Data-driven scoring and personalization,
- Larger Open Finance ecosystems.
That is exactly why this research was created as an introduction to the next phase and a conversation about how Open Banking can serve as a foundation for embedded finance services that create measurable value for banks, their partners, and end users.
PSD2 was the beginning. Open Banking is a strategic decision. Embedded finance is the opportunity.
Authors: Jelena Đurović and Nevena Milić
