Open Finance: Strategic Insights for Mid-Size Brokers in the UAE

R Philip • November 13, 2025

Key Points


  • Research suggests Open Finance in the UAE is advancing, with regulations including open insurance, impacting the sector significantly.
  • It seems likely that insurance will participate by sharing data via APIs, enhancing innovation and customer services.
  • The evidence leans toward new ventures, customers, brokers, and insurers facing both opportunities and challenges, like data security and competition.


Where to Start and Continue


For a mid-sized broker with say AED 40 million+ in revenue and growing fast, the smartest place to start is by understanding the UAE's Open Finance regulations and assessing your current technology. Focus on integrating with the centralized API hub to comply and access shared data. Continue by forming strategic partnerships with tech providers to leverage Open Finance for innovative services, improving customer experiences and staying competitive.


Tech Partners Ahead of the Curve


Look at Perfios for Open Finance solutions tailored for insurers, and Ozone API and Raidiam for their experience in global Open Finance implementations, including in the UAE. Local insurtechs like Click2Secure Me, Democrance, and Sehteq also offer innovative solutions that could be beneficial.


Insurers' Readiness to Collaborate


It seems likely that insurers are preparing to collaborate, as the Open Finance Regulation mandates participation, and the Financial Infrastructure Transformation Programme is 85% complete. While readiness may vary, many are likely integrating with the centralized platform, though some might still be catching up.


Introduction


Open Finance, encompassing both open banking and open insurance, is reshaping the financial services landscape in the UAE. As of June 19, 2025, the Central Bank of the UAE (CBUAE) has implemented a comprehensive Open Finance Framework, part of the Financial Infrastructure Transformation Programme (FIT), which is 85% complete. This note provides detailed insights for a mid-sized insurance broker, drawing on experience from advanced markets like the UK, US, and EU to navigate this transformative landscape.


Regulatory and Market Context


The Open Finance Regulation, issued on June 27, 2024, establishes a framework for cross-sectoral data sharing and transaction initiation, including insurance.


It mandates that all CBUAE licensees, including insurance companies and brokers, provide API access to accredited third parties, with phased implementation starting with banks and insurers by June 2024, aiming for majority customer access by 2025 and full integration by 2026.


Al Etihad Payments, in partnership with Core42, Ozone API, and Raidiam, operates the centralized API hub, Nebras Open Finance, approved in December 2024, to facilitate secure data sharing .


Strategic Starting Point for Mid-Sized Brokers


Given a "mid-size" revenue, the smartest place to start is by understanding the specific requirements of the Open Finance Regulation and assessing your current technological capabilities. This involves evaluating your systems for API integration, data management, and compliance readiness.


Focus on integrating with the centralized API hub to ensure compliance and access shared data, which can enhance risk assessment and customer offerings. Continue by developing a strategic plan that includes forming partnerships with technology providers or fintechs to leverage Open Finance for innovative services, such as personalized insurance products or embedded finance solutions.


Drawing from the UK, where brokers have adapted to Open Banking by enhancing digital capabilities, prioritize client education to build trust and adoption .


Technology Partners and Platforms Ahead of the Curve


Several tech partners and platforms are leading in the UAE's Open Finance space, particularly for insurance:


  • Perfios: Offers Open Finance solutions specifically for insurers, including tools for personalizing premiums, better risk assessment, and reducing fraud. They are empanelled by the CBUAE as an official system integrator, ensuring compliance.


  • Ozone API and Raidiam: Both provide technology for Open Finance implementations, with global experience. Ozone API offers a standards-compliant open API platform, while Raidiam provides API access management for secure data sharing, having supported Open Finance in Brazil.


  • Local Insurtechs: Companies like Click2Secure Me, Democrance, and Sehteq are disrupting the insurance industry with digital transformation, digital sales platforms, and technology-driven health insurance, respectively, offering potential for innovative partnerships .


Insurers' Readiness to Collaborate


The Open Finance Regulation mandates that insurance companies (national and foreign branches) provide API access by June 2024, with the FIT Programme at 85% completion as of January 2025, indicating significant progress . While specific readiness varies, the centralized platform, Nebras Open Finance, suggests insurers are integrating, as evidenced by the phased rollout.


However, drawing from EU experiences, some insurers may lag due to legacy systems, and collaboration might still be in early stages, with potential for increased activity as deadlines approach. For brokers, engaging with insurers to understand their timelines and capabilities is crucial.


Investment Requirements


The investment for a mid-sized broker to comply with Open Finance includes technology upgrades, data security, partnerships, staff training, and client education.


Based on general API integration costs, initial investment is estimated at hundreds of thousands of Dirhams with ongoing annual costs, considering maintenance and updates. Using SaaS solutions like FINX Comply, which offers cost-friendly compliance, can mitigate expenses .


In the UK, banks spent significant amounts on Open Banking compliance, but for brokers, costs are proportionally lower, especially with centralized infrastructure reducing development needs. Actual costs depend on current systems and chosen partners, so consulting with tech providers is recommended.


Comparative Analysis with Advanced Markets


Drawing from the UK, US, and EU, Open Finance has driven innovation but required substantial investment. In the UK, brokers have adapted by enhancing digital capabilities, while in the EU, the Financial Data Access (FIDA) framework highlights operational efficiencies and customer experience improvements, though with challenges like data sensitivity. These lessons suggest that while costs are significant, strategic partnerships and SaaS solutions can optimize investment for UAE brokers.


Actionable Recommendations


  • Assess Current Capabilities: Evaluate technology and data management for Open Finance compliance, investing in API integration and data security.
  • Develop Partnerships: Collaborate with Perfios, Ozone API, Raidiam, or local insurtechs to enhance digital offerings, exploring embedded insurance or data analytics.
  • Enhance Data Security: Ensure compliance with UAE data protection regulations, implementing robust cybersecurity measures.
  • Educate Clients: Inform clients about Open Finance benefits, such as personalized products, and provide transparency on data usage.
  • Stay Informed: Monitor regulatory developments and participate in industry forums to stay ahead.
  • Explore New Business Models: Consider embedded insurance, partnerships with non-traditional players, and new revenue streams like data analytics.


Conclusion


Open Finance in the UAE offers significant opportunities for mid-sized insurance brokers to innovate and enhance customer services, but requires strategic investment and collaboration. By leveraging technology partners and learning from advanced markets, brokers can navigate this landscape, delivering value to clients and maintaining competitive edge.


Key Citations




By R Philip May 26, 2026
Why Enterprise ChatGPT Wrappers Are Failing ...And Why the Next Market Belongs to AI Operating Layers A quiet problem is spreading through enterprise technology. Nearly half of enterprise GenAI users are reportedly accessing AI tools through personal or unmanaged accounts. Netskope’s 2026 Cloud and Threat Report puts the figure at 47% . For boards, CIOs, CISOs, regulators, and M&A advisors, that number should land hard. It means a large share of AI activity inside companies is invisible to IT. It is outside approved governance and may be bypassing data controls. And in regulated sectors, it may already be creating liabilities that have not been priced. This is a cybersecurity issue and it is an architecture issue. Over the past two years, many companies have tried to solve enterprise AI adoption with what is effectively a ChatGPT wrapper . Take a consumer-style AI interface. Put enterprise login on top. Add a usage policy. Maybe connect it to a few internal documents. Call it a secure enterprise AI platform. That approach has been useful as a first step. But it is now reaching its limit. The problem is clearest in industries where governance is not optional: banking, wealth management, insurance, law, healthcare, government, sovereign entities, and M&A-heavy sectors . These firms do not just need access to AI. They need controlled AI execution. They need audit trails. They need role-based access. They need data residency. They need workflow governance. They need defensible records of who asked what, what data was used, what output was produced, and what decision followed. A generic AI chat interface cannot carry that burden. The next phase of enterprise AI is not about better wrappers. It is about the rise of the AI operating layer . The Three Structural Failures of Enterprise ChatGPT Wrappers 1. AI adoption is moving faster than governance Employees are not waiting for enterprise AI strategy documents. They are already using ChatGPT, Claude, Gemini, Perplexity, Copilot, vertical AI tools, meeting assistants, coding agents, research agents, and document automation tools. Lenovo’s 2026 research reportedly found that 70% of employees use AI tools at least a few times a week , while 80% expect their AI usage to increase over the next year. At the same time, Salesforce’s 2026 Workforce AI Survey reportedly found that only 18% of organizations have formal AI security policies . That gap is the real story. Enterprise AI usage is becoming normal but enterprise AI governance is still catching up. Productiv’s 2026 analysis reportedly found that the average enterprise discovers 14 distinct AI tools in active use during audits, while IT is aware of only four or five. This is how shadow AI becomes institutional. Not because employees are malicious and not because IT is asleep. But because AI solves immediate work problems faster than enterprise policy can respond. People use the tool that helps them finish the work. If the approved path is slower, weaker, or harder to access, they route around it. That is the core governance failure. You do not stop shadow AI with a policy PDF. You stop it by making the sanctioned AI environment better than the workaround. 2. Wrappers do not understand the operating environment ChatGPT-style tools are powerful for individual productivity. They are less useful when the enterprise problem is not “generate an answer,” but “execute a controlled workflow.” That distinction matters. A banker does not simply need an AI model to summarize a document. They need AI that respects deal-team permissions, data-room boundaries, approval chains, MNPI restrictions, and audit requirements. A law firm does not simply need AI to draft a clause. It needs AI that knows the client, matter, jurisdiction, precedent bank, privilege boundaries, and review workflow. A healthcare provider does not simply need AI to answer clinical questions. It needs AI that operates within patient privacy rules, escalation protocols, clinical governance, and defensible record-keeping. An insurance broker does not simply need AI to write an email. It needs AI that can handle quotations, renewals, endorsements, claims documentation, compliance checks, carrier communication, and client servicing workflows. This is where enterprise wrappers break down. They may provide a safer chat box. But they often do not provide a governed operating system for work. They struggle with: Role-based access at team, client, function, or transaction level Full audit trails for regulated workflows Workflow-specific approvals Data residency and sovereign cloud requirements Integration with systems of record Clear ownership of AI-generated outputs Evidence trails for regulators, auditors, and deal diligence teams Separation between casual productivity use and controlled business execution In regulated environments, this is not a minor limitation. It is the difference between a productivity tool and enterprise-grade infrastructure. A chat interface was not designed to run banking operations, legal workflows, healthcare decisions, insurance processes, or M&A diligence. It was designed to converse and that is not enough. 3. The regulatory floor is rising Enterprise AI risk is no longer theoretical. Gartner has estimated that a large share of enterprise AI projects fail to move beyond pilots. The reasons are usually familiar: weak governance, unclear ownership, poor integration, lack of measurable ROI, and limited trust in outputs. The regulatory pressure is also increasing. The EU AI Act introduces higher obligations for high-risk AI systems, with enforcement milestones beginning in 2026. Penalties can reach material levels for large companies. IBM’s Cost of a Data Breach research has also highlighted the financial cost of breaches involving shadow AI and unmanaged technology environments. For the GCC, this matters even more. The UAE, Saudi Arabia, Qatar, and other Gulf markets are investing heavily in AI infrastructure, sovereign cloud, digital government, open finance, data governance, and national AI strategies. That creates a different kind of enterprise AI market. The region is not simply asking: “How do we give employees access to AI?” It is asking: “How do we deploy AI in a way that is secure, sovereign, auditable, compliant, and economically useful?” That question cannot be answered with another wrapper. It requires an AI operating layer. What Comes Next: The AI Operating Layer The next wave of enterprise AI will not be defined by prettier chat interfaces. It will be defined by infrastructure. An AI operating layer sits between employees, enterprise systems, data sources, foundation models, and business workflows. Its role is to manage how AI is used inside the organization. Not just who can access it. But what it can see. What it can do. Which workflow it is part of. Which approvals are required. Which systems it can touch. Which records must be kept. Which data must never leave the environment. A proper AI operating layer includes: Identity and access management Role-based and context-based permissions Data residency controls Enterprise knowledge retrieval Workflow routing Human approval checkpoints Audit logging Model governance Usage monitoring Cost controls Prompt and output records Integration with systems of record Policy enforcement by design This is where the enterprise AI market is heading. The winning question is no longer: “Which model are we using?” The better question is: “What operating layer governs how AI works across the business?” Why Shadow AI Is a Design Problem Most companies treat shadow AI as a compliance problem. That is incomplete. Shadow AI is usually a design problem. Employees use unapproved AI tools because the approved tools are either unavailable, clumsy, too restricted, or disconnected from real work. This is why bans rarely work for long. The Samsung case is instructive. After a reported data leakage incident involving ChatGPT use, the company initially restricted access. But the more durable answer was not just prohibition. It was the development of internal AI capability. That is the lesson for every enterprise. If the official AI environment is worse than the unofficial one, users will find a workaround. If the official AI environment is faster, safer, easier, and more useful, governance becomes natural. The goal is not to scare employees away from AI but it is to make the governed path the obvious path. The GCC Enterprise AI Opportunity The Gulf is not behind on AI. In many areas, it is ahead on capital allocation, infrastructure ambition, and executive urgency. McKinsey’s 2025 GCC AI research reportedly shows enterprise AI adoption rising sharply across the region. BCG’s 2025 AI maturity work also points to a growing class of GCC organizations that are moving beyond experimentation. The UAE and Saudi Arabia are especially important markets because they combine four forces: Strong national AI agendas Significant investment in digital infrastructure Regulated sectors with high compliance requirements Large enterprise and government buyers willing to modernize That combination creates a serious opportunity for AI operating infrastructure. The next GCC AI winners will not be the companies that run the most pilots. They will be the companies that turn AI into governed execution. This applies across: Banks Wealth managers Insurers Brokers Law firms Healthcare groups Logistics companies Government entities Family offices Investment firms M&A advisory environments Regulated technology businesses In these sectors, AI value does not come from giving everyone a chatbot. It comes from redesigning workflows around secure, auditable AI execution. Why This Matters for M&A and Enterprise Value AI governance is becoming a diligence issue. In M&A, buyers already assess revenue quality, customer concentration, cybersecurity, data privacy, software architecture, regulatory exposure, and operational maturity. AI exposure is becoming part of that same diligence map. A target company using unmanaged AI tools across sales, finance, legal, HR, product, and customer data may carry hidden risk. Questions buyers will increasingly ask include: What AI tools are used across the business? Which tools are approved? Which tools are unmanaged? What company data has been entered into external AI systems? Are prompts and outputs logged? Are regulated workflows using AI? Is there a human approval process? Are AI outputs used in customer-facing decisions? Is sensitive data protected? Are there data residency issues? Does the company have an AI governance policy? Is AI usage creating legal, regulatory, or contractual exposure? This matters because unmanaged AI can affect valuation. It can increase diligence friction. It can create indemnity demands. It can delay transactions. It can reduce buyer confidence. It can expose weak management controls. The inverse is also true. A company with a governed AI operating layer can present a stronger story: Better productivity Lower operating cost Stronger compliance Cleaner auditability Better data discipline More scalable workflows Reduced key-person dependency Higher confidence in operational maturity That is why AI governance is not just a technology issue. It is becoming an enterprise value issue. The Real AI Strategy Question The question for boards and leadership teams is no longer: “Should we allow AI?” That decision has already been made by employees. The better question is: “Do we have the architecture to govern AI at enterprise scale?” For regulated industries, the follow-up questions are even sharper: Can we prove what data AI accessed? Can we show who approved an AI-assisted decision? Can we enforce data residency requirements? Can we separate general productivity use from regulated workflows? Can we audit AI activity during a regulatory review or transaction diligence process? Can we prevent employees from using unmanaged AI when the official tool is not good enough? These are operating questions. Not model questions. Not chatbot questions. Not innovation theatre questions. The Bottom Line Enterprise ChatGPT wrappers helped companies start the AI journey. But they are not the destination. They are too shallow for regulated workflows. Too generic for enterprise operations. Too weak for audit-heavy environments. Too disconnected from systems of record. Too limited for sovereign data requirements. The next phase belongs to AI operating layers. Infrastructure that governs how AI interacts with people, data, systems, workflows, and decisions. For the GCC, this is a major opening. The region has capital, ambition, infrastructure, and executive urgency. What it now needs is disciplined AI deployment architecture. The winners will not be the firms with the most AI tools. They will be the firms that make AI usable, governed, auditable, and embedded into the way work actually gets done. That is where real enterprise value will be created.
By Futureu Strategy Group May 4, 2026
PRISM by Futureu Strategy Group is an enterprise AI platform with zero prompt engineering, full audit trails, and no vendor lock-in. See how it transforms every department.