Open banking arrived in the Gulf later than in Europe, and it arrived with more ambition. SAMA's framework and the CBUAE's open finance regulation extend beyond payments and accounts into lending, insurance and investment data, and they set timelines that most institutions are now working to meet.
The prevailing response has been to treat the obligation as a technology project: expose the mandated APIs, pass the conformance tests, move on. That is a defensible minimum. It is also a strategic mistake.
The API you expose to satisfy the regulator is the same API a competitor will use to reach your customers.
What incumbents actually have
Regional banks hold something the challengers do not: deep, trusted relationships with customers who have complex needs, from family businesses to high-net-worth individuals to public-sector employees. Open finance lets those relationships be served through partners and platforms the bank does not own, at a cost of acquisition the branch model cannot match.
Three strategic postures
Comply. Meet the regulation, protect the core, accept some erosion at the margins. Appropriate for institutions with other priorities, but it cedes the initiative.
Distribute. Use open APIs to embed the bank's products in the platforms where customers already are: property portals, employer payroll, e-commerce and super-apps. This is where the most immediate revenue sits.
Orchestrate. Become the platform that aggregates a customer's financial life across institutions. Ambitious, expensive and only realistic for a handful of institutions with the brand and the technology to carry it.
The governance that makes it possible
Whichever posture is chosen, the enablers are the same: a partner model with clear commercial terms, consent and data governance that satisfies the regulator and the customer, an API product function that treats developers as customers, and a risk framework for third parties that goes beyond the annual questionnaire.
The banks that win the next decade of GCC retail and SME banking will be the ones that decided, early, that open finance was a distribution strategy. The regulation simply removed the excuse not to.
