The Gap Between Regulation and Law
The BSP has proven itself as a forward-thinking regulator. Circular No. 1122 provided the technical framework for Open Finance as early as 2021. However, a circular is not a statute. To ensure the longevity and enforceability of the Open Finance ecosystem, the Philippines needs legislation. That legislation is House Bill No. 9149.
Inside the Open Finance and Consumer Data Empowerment Act
House Bill No. 9149, filed in 2025, seeks to establish the country’s first comprehensive legal framework for consumer-directed financial data sharing. Its core provisions are designed to empower the individual while holding institutions accountable.
The 24-Month Data Window
A critical component of the bill is the limitation of data access to a maximum of 24 months for credit evaluation purposes. This provision is a masterstroke in balancing the need for comprehensive credit assessment with the consumer’s right to data privacy. It ensures that a borrower’s financial past is not used against them indefinitely.
Creating the Consumer Data Commission
To oversee this new ecosystem, the bill proposes the creation of a Consumer Data Commission under the Office of the President. This body would be responsible for accrediting financial institutions, mediating disputes, and enforcing data privacy standards.
The Industry Response: Fintech Alliance Support
The Fintech Alliance Philippines has thrown its weight behind the bill. Trustees argue that HB 9149 will bridge the gap between how Filipinos actually participate in the digital economy—through e-wallets and digital payments—and how formal institutions assess their creditworthiness.
The Road Ahead: From Bill to Reality
As of mid-2026, the bill is under deliberation in the House Committee on Banks and Financial Intermediaries. Its passage is not guaranteed, but the momentum is undeniable. If enacted, House Bill 9149 will transform the Philippines from a follower in fintech regulation to a global leader in consumer-centric financial data governance.
