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Beyond Open Banking: Are E-Invoicing, Open Finance and Business Wallets Creating a New Trusted Financial Ecosystem?

Writer: Steve Britton
Steve Britton
Oct 8
5 min read
CloudConnect infographic on Beyond Open Banking, showing trusted data flow linking identity, transactions, finance and payments.

From E-Invoices to Trusted Data

I set out to write a six-part series about invoices. I've ended up writing about trust. Because the more I looked at what's happening around Accounts Payable, the clearer it became that AP is just one part of something much bigger, and that deserved one more article.


Open Banking is evolving into Open Finance. Europe is moving towards structured e-invoicing and digital reporting. AI is learning not just to analyse information but to act on it. And the European Commission is developing the European Business Wallet, a trusted digital identity that lets businesses identify themselves and exchange verified information across Europe.


Viewed separately, these look like unrelated initiatives. I don't think they are. I believe we're seeing the building blocks of a trusted digital financial ecosystem.


Open Banking was only the beginning

Open Banking let businesses securely share payment-account data and opened the door to account-to-account payments. Open Finance takes that principle much further, extending data sharing into credit, mortgages, pensions and insurance, with an FCA roadmap running to 2030 and SME lending an early priority.


One line in the FCA's recent work immediately caught my attention: Open Finance will develop as an ecosystem rather than a set of isolated use cases, and its value comes not from accessing more data, but from combining and structuring trusted data to improve decisions. That's remarkably close to the argument I've been making throughout this series.


So where does trusted business data come from?

This is where e-invoicing becomes far more strategic than we usually give it credit for. We tend to treat it as compliance: France's mandate, Germany's requirements, the UK's move towards mandatory VAT e-invoicing, and the EU's ViDA reforms introducing Digital Reporting Requirements for cross-border B2B from July 2030.


But a structured e-invoice isn't just a digital PDF. It captures who sold what to whom, for how much, when, with what tax, currency, payment terms and PO references. That makes e-invoicing a genuine source of structured financial data, not just an AP automation tool.


But structured data isn't automatically Trusted Data

Arriving electronically doesn't make information financial truth. The format may be compliant and the supplier genuine, but Finance still needs to know whether it's the right legal entity, whether the goods arrived, whether the price matches, whether the bank account is trusted and whether it's a duplicate.


AI can understand, enrich, spot anomalies and increasingly act. But declarative controls must decide whether a transaction is permitted to proceed. Structured data, enriched, validated and controlled, becomes Trusted Data, and only then should it flow into the wider financial ecosystem.


Enter the European Business Wallet

In November 2025, the Commission proposed a Regulation establishing European Business Wallets. Businesses could use them to authenticate themselves, digitally sign and seal documents, exchange verified credentials and interact with businesses and public authorities across the EU. Technical work in 2026 is focusing on identity, trust, secure communication and interoperability.


That matters, because every financial transaction starts with one question: who am I dealing with?


There's an important caveat, though. A verified identity doesn't make every transaction valid, just as a structured invoice isn't automatically correct and AI output isn't automatically truth. Each layer answers a different question:


  • Identity: Who are you?

  • E-invoicing: What is the transaction?

  • Open Finance: What financial information can legitimately be accessed?

  • AI: What can we understand or recommend?

  • Declarative guard rails: What are we permitted to do?

  • Payment infrastructure: How does value move?


Put them together and something powerful emerges.


From Know Your Supplier to Know Your Transaction

Today, Finance establishes supplier identity, then separately validates each transaction. A connected ecosystem could create a continuous chain of trust: a verified business, an authorised representative, an authentic invoice, matching commercial data, satisfied controls, authorised payment, settlement and automatic reconciliation. That's not just knowing your supplier. It's knowing your transaction.


And AI raises a new question: who gave it authority to act? The FCA notes that as AI services start acting for businesses, financial infrastructure will need mechanisms for verification, delegation and accountability. Asking AI which invoices to pay today is easy. Letting it initiate those payments is something else entirely. Before that happens, organisations need to know who authorised the agent, within what limits, under which controls, who remains accountable, and whether every decision can be audited.

That is precisely why identity, Trusted Data and declarative controls matter so much.


Europe is assembling the pieces

I want to be careful here. The Business Wallet isn't an AP or e-invoicing platform, and Open Finance, ViDA and Business Wallets are separate initiatives. But the Commission itself describes e-invoicing, Business Wallets, digital identity and business registers as parts of a more cohesive ecosystem for data exchange and reporting.

So CFOs should start asking: what happens when these infrastructures begin to interoperate?


Throughout this series I've argued that AP is moving from documents to data, from data to Trusted Data, and from Trusted Data to decisions and payments. I'd now add one more step: from Trusted Data to a trusted financial ecosystem. One that reaches well beyond AP into working capital, credit, forecasting, supplier finance, tax, audit, fraud prevention and regulatory reporting.


Where Service Providers Fit In

The opportunity isn't to replace every system in that ecosystem. It's to connect them. Suppliers will still use different systems, businesses will still run multiple ERPs, countries will keep different mandates, and networks will coexist. What organisations need is an intelligent orchestration layer that receives, understands, enriches, validates and connects information, and ensures that what comes out can be trusted. The more autonomous Finance becomes, the more that matters.


The future isn't just Open Finance. It's Trusted Finance.

Open Banking connected us to the bank. Open Finance connects the wider ecosystem. E-invoicing creates structured transaction data, Business Wallets could provide trusted identity, and AI can increasingly act on all of it. But Trusted Data and declarative guard rails decide whether Finance should trust the outcome.


Which leaves what may be the most important question of this entire series: as Finance becomes more connected and autonomous, how do we ensure every identity, data point, decision and transaction can still be trusted?


Perhaps that's the challenge we should now be designing for.

To learn more about CloudConnect technology and services, explore our website and schedule a Free AP readiness Assessment.


Missed the previous blogs in the "Future of Accounts Payable" series?








Sources referenced in this article: 


🔹 FCA, Open finance roadmap: our vision for a smart data future (April 2026) https://www.fca.org.uk/publications/corporate-documents/open-finance-roadmap 


🔹 European Commission, Proposal for a Regulation on the establishment of European Business Wallets (November 2025) https://digital-strategy.ec.europa.eu/en/library/proposal-regulation-establishment-european-business-wallets 


🔹 European Commission, VAT in the Digital Age (ViDA) https://taxation-customs.ec.europa.eu/taxation/vat/vat-digital-age-vida_en


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