
When the Open-Banking API Fails: Liability Architecture for Gateway Downtime and Bad Data
Naomi BergmanOpen-banking rails turn interface uptime into consumer-outcome law — the contracts decide who pays when the pipe breaks and the data lies.
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Open-banking rails turn interface uptime into consumer-outcome law — the contracts decide who pays when the pipe breaks and the data lies.

The Federal Reserve completed the Fedwire ISO 20022 cutover in March 2025, and the structured data now flowing through US payment rails is a compliance instrument most programs have not finished reading.

NIST SP 800-207 abolished the trusted internal network in 2020; the access decisions that replaced it are legal artifacts with privacy consequences.

The Bank for International Settlements' March 26 paper puts data itself at the center of the AI-in-finance question — where compliance teams already live.

One is an attestation an auditor signs each year; the other is a certification a standards body stands behind — and financial diligence teams read the difference closely.