Open finance promises more choice, control and value for people and SMEs, but only if implemented with clear policy goals. CGAP’s report, “Harnessing Open Finance for Competition and Financial Inclusion” (published in Competition Policy International, Aug 26, 2025), distils what matters into six policy levers: clear objectives, reciprocity, inclusivity, proportionality, pricing and governance. It sits alongside CGAP’s companion blog, “Six Ways Open Finance Can Drive Competition and Inclusion.” It’s a practical blueprint for policymakers who want competition and inclusion to translate into real-world outcomes, not just aspirations. This article builds on CGAP’s framework and adds the trust layer perspective we work on every day at Konsentus. Credit for the six-lever framework belongs to CGAP; the trust-layer interpretation and examples are the views of Konsentus.

What do we mean by the trust layer?

Policies define what good looks like; markets need mechanisms that make good demonstrable. A trust layer does three jobs, continuously and at scale:

1. Identity assurance: positively identify every data access request and confirm that the requester is authorised for the specific permission(s) they seek.
2. Consent integrity: ensure data access is based on a valid, current and appropriately scoped user/customer consent.
3. Auditable access: record and evidence that every access meets the scheme rules and regulation.

Mapping the trust layer to CGAP’s six levers

1. Clear objectives → measurable trust outcomes
   Levers are only credible when they can be measured. Beyond adoption volumes, open finance scheme operators can publish trust KPIs: reductions in access errors, time-to-connect for new entrants and complaint & dispute trends. These metrics focus attention on quality of access, not just quantity.
2. Reciprocity → symmetric trust checks
   If organisations benefit from access, they should meet equal obligations both accessing and sharing data under fair and consistent rules. Trust symmetry removes imbalance in the ecosystem, reduces asymmetries between incumbents and challengers, which builds confidence that data is exchanged on level terms.
3. Inclusivity → low-barrier onboarding
   Inclusion is a design choice. Shared onboarding gateways, template policies and assisted accreditation help Microfinance Institutions (MFIs), Savings and Credit Cooperatives (SACCOs) and community lenders participate without enterprise budgets; whilst the trust layer keeps risk controls consistent. Lowering the process cost of joining is as important as lowering the monetary cost.
4. Proportionality → risk-based access
   Controls should fit the use case and risk profile. Not every data request needs the same level of assurance; a calibrated, risk-based approach accelerates innovation while maintaining safety. Practically, that means tiered identity assurance, contextual consent checks and increased oversight as volumes and risk grow.
5. Pricing → transparency and predictability
   Opaque fee structures can exclude those innovators who can reach underserved users. Clear, tiered pricing for participation, coupled with published service levels, help smaller providers plan and invest. A trust layer supports this by exposing standardised logs and performance stats that justify pricing and identify where potentially subsidies can make sense for inclusion goals.
6. Governance → accountability and conformance
   Open finance is an ecosystem; governance must make performance visible. Public standards, uptime metrics, incident learnings and conformance dashboards turn governance into a feedback loop everyone can learn from. The trust layer provides the evidentiary backbone: indisputable records of who accessed what, when and on what basis.

What changes when the trust layer is implemented

• Faster, safer connections: New data users can connect quickly because identity and permission checks are standardised and automated.
• Lower participation barriers: Smaller providers can join with shared gateways and templated assurance; without compromising control.
• Better supervision: Scheme owners get consistent, machine-readable evidence of access decisions and outcomes, enabling proportionate oversight, enabling the scheme to publish performance metrics to deliver a transparent, open and trusted ecosystem.

How Konsentus helps

Our mission is simple: unlocking growth and innovation by enabling secure, seamless connections – at scale – between trusted parties in the open ecosystem. In practice, that means tools for real-time data-user identity and access management: verifying who’s asking, whether they’re authorised and whether a valid, current basis for access exists – every time. That’s how we deliver clarity and control in open finance and help markets operationalise CGAP’s six levers.

Conclusion

CGAP has given policymakers and market operators a clear set of levers for making open finance deliver on competition and inclusion. The next step is to translate those levers into daily operations with a trust layer that turns principles into permissions.

Let’s pilot a trust-layer approach in your market or scheme.
Get in touch to explore how identity assurance, consent integrity and auditable access can accelerate safe, inclusive growth.