Case study · Fintech

Building a fintech platform for UAE Open Finance: consent, security and a single hub

A UAE fintech had built its product on screen scraping and one-off bank integrations. The Central Bank's Open Finance framework offered a regulated, standardised alternative through a central API hub. The goal was to re-platform around consent and secure APIs without stalling the product roadmap.

Case studyFintech · UAESumanta Mukhopadhyay9 min read
#uae#security#architecture#platform
CASE STUDY · CASE STUDY · FINTECH28 Oct 2026 · 22:50 GST
At a glance
SectorFintech · UAE
My roleFractional CTO and solution architect
EngagementArchitecture, delivery leadership and assurance
ScopeConsent, API integration, security profile, data handling, observability
What changed
  • One integration path to participating institutions instead of per-bank connectors
  • Consent captured, displayed and revocable in the product, with an audit trail
  • Security aligned to a recognised financial-grade API profile
  • A data model that keeps only what each feature needs
Open Finance API hubOAuth 2.0 and OpenID ConnectFAPI 2.0 security profileConsent serviceEvent busTokenised data storeKubernetesOpenTelemetry

Anonymised composite. Client names, identifying details and confidential figures are withheld; public facts are cited in the references.

The situation

A fintech serving customers in the UAE offered budgeting and cash-flow insights built on account data. Getting that data had meant a patchwork: screen scraping for some banks, bilateral integrations with others, and manual statement uploads as a fallback. Each connection broke differently, security reviews were difficult to pass, and the approach had no future as regulation matured.

The Central Bank of the UAE's Open Finance Regulation changed the picture by establishing a regulated framework for open finance services1. The question for leadership was how to move onto it cleanly, while continuing to ship features.

What had to be true

  • One integration path through the regulated framework, replacing scraping and bespoke connectors.
  • Consent as a product feature: customers see what they shared, with whom, for how long, and can revoke it.
  • Financial-grade security that a bank's or regulator's reviewer would recognise.
  • Data minimisation: store only what each feature needs, for as long as it needs it.
  • Clear regulatory boundaries, including where free zone permissions do and do not apply.

The framework is described as having three parts: a trust framework, an API hub and common infrastructure services2. Commentary highlights that the API hub is operated by a Central Bank subsidiary, Nebras, as a single gateway between providers and licensed institutions, that participation is mandatory for licensees in respect of in-scope products, and that DFSA or FSRA permissions in the financial free zones do not by themselves grant access to the onshore hub3.

Architecture

Customer
Mobile appinsights and actionsConsent centreview, renew, revoke
Product
Insights servicescategorisation, forecastsNotificationsevent-drivenSupport toolsno raw data access
Open finance
Consent servicepurpose, scope, expiryHub connectorFAPI-grade clientToken vaultkeys in HSM or KMS
Data
Minimal data storeper-feature fieldsEvent busaccount and consent eventsRetention jobsdelete on expiry
Assurance
Audit logconsent and accessObservabilitytraces per API callConformance testssecurity profile
Consent and the hub connector sit at the centre; product services never see credentials or more data than they need.

The data flow, end to end

  1. ChooseCustomer picks a feature and sees exactly what data it needs and why
  2. ConsentConsent created with purpose, scope and expiry; customer authenticates with their institution
  3. TokenAccess tokens stored in the vault, bound to the client and never exposed to product services
  4. FetchHub connector retrieves only consented data through the API hub
  5. MinimiseOnly fields the feature needs are stored; the rest is discarded
  6. ExpireOn revocation or expiry, access stops and stored data is deleted
Every step is tied back to a consent record, so the audit trail answers "why did we have this data?"

The hard part: security that reviewers recognise

Financial APIs attract determined attackers, and generic OAuth setups leave room for token theft and replay. The OpenID Foundation's FAPI 2.0 security profile defines a hardened profile of OAuth 2.0 and OpenID Connect for exactly these APIs; its security profile and attacker model were approved as final specifications, and conformance tests and certification are available45. Building to a recognised profile meant security discussions with partners started from a shared baseline rather than a custom design.

  • Sender-constrained tokens and strong client authentication, so a stolen token alone is not enough.
  • Keys held in a key management service or hardware security module, never in application configuration.
  • Conformance testing in CI against the profile, run before every release of the connector.
  • Product services given no direct access to tokens or the hub; they consume events and minimised data.

In open finance, consent is not a checkbox. It is the primary key of the whole data model: every token, fetch and stored field should trace back to one.

How it ran

Product
  1. Map features to data needs
  2. Design consent journeys
  3. Retire scraping flows
Engineering
  1. Consent service and vault
  2. Hub connector to profile
  3. Retention and audit
Compliance
  1. Licensing and scope
  2. Policies and records
  3. Regulator engagement
Licensing, product and engineering moved together; none could finish without the others.
Phase 1Frame
  • Regulatory scope
  • Data needs per feature
  • Target architecture
Phase 2Foundations
  • Consent service
  • Token vault and keys
  • Audit and observability
Phase 3Connect
  • Hub connector
  • Conformance testing
  • Pilot feature
Phase 4Migrate
  • Move features over
  • Retire scraping
  • Delete legacy data
Consent and security foundations before the first live call through the hub.

Key decisions and trade-offs

DecisionAlternativeWhy
Integrate through the regulated hubKeep bilateral and scraped connectionsOne standard path, a regulated basis and fewer breakages
Consent service as a core domainConsent flags on user recordsPurpose, scope, expiry and revocation need their own model
Build to FAPI 2.0Generic OAuth setupRecognised baseline for financial APIs, with conformance tests
Minimise at ingestionStore everything, filter laterLess risk, simpler retention and easier privacy answers
Tokens isolated from product servicesServices call the hub directlySmaller attack surface and one place to audit

What I'd do again, and differently

Again: treat consent as the centre of the data model and build to a recognised security profile from the start. Differently: settle the licensing and regulatory perimeter before detailed design, especially the onshore and free zone question. It shaped which institutions and products were reachable more than any technical choice. Related reading: UAE PDPL and AI architecture and idempotent payment pipelines.

If you're building fintech products in the UAE, the fractional CTO in the UAE page explains how I work, or analyse your challenge and bring the result to a call.

References
  1. 1
  2. 2
    UAE Open Finance Regulation (briefing)Clifford Chance · May 2024
  3. 3
    UAE open finance (guide)Pinsent Masons Out-Law
  4. 4
  5. 5
    FAPI Working GroupOpenID Foundation
FAQ

Common questions

What is the UAE Open Finance framework?

A Central Bank of the UAE regulation that sets up open finance through a trust framework, a central API hub and common infrastructure services, so licensed institutions and third-party providers exchange data and initiate services through standardised, consented APIs.

Do fintechs connect to each bank separately?

Commentary on the framework highlights its centralised API hub, operated by a Central Bank subsidiary, as a single gateway between third-party providers and licensed institutions, rather than separate bilateral integrations.

What is FAPI 2.0?

A financial-grade API security profile for OAuth 2.0 and OpenID Connect from the OpenID Foundation. Its security profile and attacker model were approved as final specifications in February 2025, with conformance tests and certification available.

Keep reading

Related

Open to advisory, fractional CTO & select builds

Let's talk about what you're building.

The fastest route is a free 30-minute call. Prefer to write? Send a message and I'll reply personally within two business days.

Start a conversation

How would you like to reach me?

Book a 30-min callFastest. Pick any open slot on my calendar.→ Write in GmailOpens a pre-filled draft in your browser.→ Use my email appOutlook, Apple Mail or your default client.→

I reply personally within two business days. Time zones from the Americas and Europe to the Middle East and Asia-Pacific.