Open banking payments have moved from a fintech curiosity to a mainstream deposit and withdrawal channel across regulated iGaming markets. As adoption accelerates through 2025, operators are discovering that access to this channel comes with a clearly defined set of expectations from both regulators and the banks and payment initiation service providers that sit behind it.
Why Open Banking Attracts Regulatory Attention
Unlike card payments, where the card scheme sits between the operator and the customer's bank, open banking routes payments directly through a regulated payment initiation service provider. That directness brings speed and lower friction, but it also places a sharper compliance obligation on the operator. Regulators in the UK, Netherlands, Sweden and other mature markets treat open banking gambling transactions as a high-risk payment category, meaning the due-diligence bar is measurably higher than for standard e-commerce.
The core concern is straightforward: if a customer can move funds from their current account to a gambling wallet in seconds, there is less time for traditional friction-based safeguards to intervene. Regulators expect operators to compensate for that speed with stronger upfront controls rather than relying on downstream monitoring alone.
What Regulators Want to See From Operators
Source of Funds Verification
Open banking actually creates an opportunity here rather than just an obligation. Because the payment flow confirms the customer's bank account ownership at point of initiation, operators can use that data signal as one input into a lightweight source-of-funds check. Regulators expect this capability to be used, not ignored. A customer depositing at elevated frequency or volume should trigger a documented review that references the account data the operator now has access to.
Affordability Frameworks
The UK Gambling Commission's affordability guidance, reinforced through 2024 and still active as of this publication, explicitly names open banking as an acceptable method for operators to conduct frictionless financial checks on customers above defined deposit thresholds. Operators in GB-regulated markets should already have a pathway that offers customers the option to share account data rather than submit manual documents. Failure to build this into the payment journey is a missed regulatory expectation, not a neutral choice.
Segregation and Dispute Handling
Regulators and banking partners both require clear evidence that customer funds are segregated and that the operator has a documented dispute and refund process specific to open banking transactions. Unlike chargebacks on card payments, open banking disputes follow a different resolution path. Operators must demonstrate they understand this distinction and have internal procedures that reflect it.
What Banking Partners and PISPs Require
Payment initiation service providers and the banks that underpin them run their own due-diligence process before onboarding a gambling operator. This process has become considerably more rigorous since 2023. The following are the areas banking partners consistently scrutinise:
- Licensing documentation: A current licence from the relevant regulator, with no outstanding enforcement actions, is a baseline requirement. Some PISPs will request a licence history covering the previous three years.
- AML and KYC policy documentation: Banking partners want to see written policies, not just verbal assurances. Policies should address open banking specifically, not just generic card payment flows.
- Transaction monitoring architecture: Banks expect operators to have automated transaction monitoring capable of flagging structuring behaviour and velocity anomalies in real time.
- Responsible gambling controls: Deposit limits, cooling-off periods and self-exclusion integration are increasingly contractual requirements in PISP partnership agreements, not just regulatory obligations.
- Business continuity and fraud response plans: Banking partners want documented procedures for responding to account takeover fraud and for communicating incidents within a defined timeframe.
Practical Steps for Operators Entering This Channel
Operators preparing to launch or expand open banking payments should approach the process as a compliance project first and a product project second. That means involving your MLRO and compliance team before your payments team finalises any PISP contract. The documentation that regulators and banking partners request overlaps significantly, so building a shared compliance pack early reduces duplication and speeds up onboarding timelines.
Operators that treat open banking as just another deposit method will find themselves unprepared for the due-diligence demands. Those that treat it as a regulated service with its own compliance footprint will onboard faster and retain their banking relationships longer.
Governance also matters. Assign ownership of the open banking compliance relationship internally, whether that sits with your MLRO, your CFO or a dedicated payments risk function. Banking partners and regulators both respond better to operators who can demonstrate a named, accountable contact with documented oversight responsibilities.
The Outlook for 2025 and Beyond
Regulatory expectations around open banking in gambling are still solidifying. The European Banking Authority has signalled further guidance on PSD2 and gambling intersections, and national regulators are watching UK implementation closely. Operators who build compliant, well-documented open banking processes now will be better positioned when those additional requirements arrive, rather than having to retrofit controls into a payment channel already in production.
