Open Banking Consent Checklist

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Getting Open Banking Consent Right

Open banking is transforming how financial services work globally, and Nigeria is no exception. With the Central Bank of Nigeria (CBN) driving the Open Banking regulatory framework, fintechs, banks, and third-party providers are increasingly building services that access customer financial data through APIs. But at the heart of open banking lies a fundamental requirement: informed customer consent. Get consent wrong, and you face regulatory penalties, customer distrust, and potential data breach liability. The Open Banking Consent Checklist on ToolWard provides a structured framework for ensuring your consent mechanisms meet regulatory and best-practice standards.

Why Consent Is the Foundation of Open Banking

Open banking works by allowing third-party providers to access a customer's bank account data - transaction history, balances, payment initiation - through secure APIs, but only with the customer's explicit consent. This consent model is what distinguishes open banking from screen scraping or credential sharing, both of which are insecure and increasingly prohibited. Without proper consent mechanisms, the entire trust framework of open banking collapses.

The CBN's framework, along with international standards like the UK's Open Banking Implementation Entity (OBIE) and the EU's PSD2, establishes specific requirements for how consent must be obtained, what information must be disclosed, how consent can be revoked, and how long consent remains valid. This checklist consolidates these requirements into actionable items.

What the Checklist Covers

The checklist is organised into categories that mirror the consent lifecycle from initial request through ongoing management to revocation:

Pre-consent disclosure: Before a customer grants access, they must understand exactly what data will be accessed, who will access it, for what purpose, and for how long. The checklist verifies that your consent screen clearly identifies the data types being requested (account details, transaction history, balance information), names the third-party provider and data recipient, states the specific purpose (account aggregation, credit scoring, payment initiation), and specifies the consent duration.

Consent granularity: Best practice requires that customers can grant consent at a granular level rather than all-or-nothing. Can the customer allow access to transaction history but not balance information? Can they consent to read-only access without enabling payment initiation? The checklist evaluates whether your implementation offers appropriate granularity.

Authentication and verification: Consent must be authenticated through the customer's bank, not just the third-party app. This typically involves redirecting the customer to their bank's authentication page (similar to 3D Secure for card payments). The checklist covers strong customer authentication requirements and multi-factor verification standards.

Consent management: Once granted, customers must be able to view, modify, and revoke their consent at any time. The checklist verifies that your implementation includes a consent dashboard or management interface where customers can see all active consents, the data being shared, and a clear revocation mechanism.

Data handling and retention: Consent to access data does not mean consent to store it indefinitely. The checklist addresses data minimisation principles, retention policies, and what happens to collected data when consent is revoked or expires.

Regulatory Context in Nigeria

The CBN's Regulatory Framework for Open Banking in Nigeria establishes the rules of engagement for all participants. The Nigeria Data Protection Regulation (NDPR), now superseded by the Nigeria Data Protection Act (NDPA), adds additional requirements around personal data processing, consent, and data subject rights. Financial institutions and fintechs operating in Nigeria must comply with both frameworks simultaneously.

Non-compliance carries real consequences. The CBN has the authority to sanction banks and payment service providers, revoke licences, and impose financial penalties. Beyond regulatory risk, consent failures erode customer trust in a market where digital financial services adoption is still growing and trust is fragile.

Who Should Use This Checklist

Fintech product managers designing consent flows for banking integration features. Compliance officers at banks reviewing third-party access requests and consent mechanisms. Software developers implementing open banking APIs who need to ensure the consent layer meets requirements. Startup founders building financial products that will need to request customer banking data. Auditors evaluating open banking implementations for regulatory compliance.

The checklist functions as both a design guide for new implementations and an audit tool for existing ones. Work through each item, note where your implementation meets the requirement and where gaps exist, and use the results to prioritise your compliance roadmap.

The Open Banking Consent Checklist is free, runs in your browser, and does not require any login or data sharing. Your compliance assessment stays on your device. Use it to build open banking services that customers can trust.