Open banking

Open banking is a regulated framework that enables payment service users to access their online payment accounts and related data through third parties.

Payment service providers that maintain payment accounts are required to make them accessible through dedicated interfaces (APIs—Application Programming Interfaces, the preferred solution from a security perspective) or via direct access (Graphical User Interface).

The aim of open banking is the safe and controlled sharing of data on customers’ payment accounts, which increases competition in the area of ​​payments, supports innovation, improves customer experience, and enhances consumer protection in the digital financial environment.

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Legal framework

The legal basis for open banking is Directive (EU) 2015/2366 of the European Parliament and of the Council on payment services in the internal market (PSD2), which was transposed in the Slovak Republic by Act No. 492/2009 Coll. on payment services, as amended.

The legal framework is supplemented by Commission Delegated Regulation (EU) 2018/389 laying down regulatory technical standards on strong customer authentication and common and secure open communication interfaces.

In order to ensure a uniform interpretation and application of the PSD2 Directive, the European Banking Authority (EBA) has published several interpretative opinions (EBA/OP/2021/02, EBA/OP/2020/10, EBA-Op-2018-04).

In addition, the EBA publishes questions and answers through the Q&A tool to clarify ambiguities and also questions from application practice.

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Supervision of the National Bank of Slovakia

In response to supervisory findings, suggestions from application practice, and the rapidly changing environment in the provision of payment services, the NBS issued opinions on this matter in 2026 and in 2022, which specifically relate to market conditions in the Slovak Republic.

The opinions represent the legal opinion of the NBS, which is applied in the exercise of financial market supervision.

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Qualified TPP complaint

Neither the NBS nor other national supervisory authorities have access to API production environments and can identify some deficiencies only on the basis of questionnaires sent by the provider or complaints received by a third party. A third party that has a problem with the provider’s API may submit a qualified complaint to the NBS if:

• it has not been able to resolve the issue through bilateral communication with the bank, and
• there is a legal basis in EU legislation or the EBA interpretation mentioned above to eliminate the deficiency.

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