The Best Time to Build on Bank Data
Open banking is live. AI makes building cheap. The window is now.
Something just changed
On 1 December 2025, New Zealand's Consumer Data Right went live. For the first time, bank data and bank-initiated payments started becoming available to third-party developers through authenticated APIs, with customer consent.
That might sound like a regulatory footnote. It's not. The industry has been talking about this for years. What's missing isn't awareness. It's builders.
This matters because it changes what a small team can build, and how fast they can build it. First, some context on why I care, and the obvious conflict of interest.
Ten years for the "easy" part
I'm the founder and CEO of Akahu, an open banking platform in New Zealand. We provide the APIs that let developers access bank account data and initiate payments across the major NZ banks we support.
It took ten years to get here.
When I started, there was no Consumer Data Right. No authenticated bank APIs. No open banking framework. We had to reverse-engineer access to bank data, building and maintaining connections without any support from the banks themselves. It was painstaking work. The whole time, proper bank-authenticated access was "coming soon." It was always coming soon.
Had I known it would take a decade, I never would have started. That's the honest truth.
But the hard part is now largely done. The infrastructure exists. The regulatory framework is live. The bank connections exist. What took us ten years and a team of engineers to build, a developer can now start experimenting with in a weekend.
That's not a small change. That's a different universe.
Also, yes, this is self-serving. I built part of the infrastructure and now I'm telling people to build on top of it. But that doesn't make the underlying point any less true. If you care about building products around money, the cost and complexity of getting started just collapsed.
What you can actually access
Through Akahu, developers can now access account information, balances and transactions across the major NZ banks we support. They can also initiate payments to NZ bank accounts with authenticated, consented access.
That's also where the distinction between open banking in theory and building a product in practice starts to matter. Direct open banking access gives you the raw bank data. That's useful, but raw data still leaves a lot of work to do. Different banks structure things differently. Transaction descriptions are messy. And the bank data layer doesn't do the work of categorising transactions for the product you're trying to build.
Part of Akahu's value is cleaning that up across banks, normalising it, and enriching and categorising the transaction data so developers can spend more of their time building the product on top. The raw access matters. Making it usable matters just as much.
Historically, this data sat inside the customer's own bank. Think about what that means. Every financial product, every budgeting app, every lending decision, every business tool that touches money, all of it has been built on incomplete information. Your bank sees your accounts with them. Very few products see the full picture. Now they can.
I saw a version of this up close during my time in Xero's bank feeds team, where I got a first-hand view of how hard bank data access used to be before CDR. One of the reasons Xero became so valuable to small businesses was that it got bank transaction data flowing into the product. Without that overnight bank data, it's a very different proposition. Reconciliation is harder. The product is less useful. The habit is weaker.
That's the part worth paying attention to. For a long time, access to that data was a moat in itself. You had to negotiate for it, stitch it together, and maintain it. Now that access is becoming more available. That doesn't mean the moat disappears. It means the moat moves up the stack, into the product you build on top of the data.
Bank without being a bank
Here's how I think about the opportunity. You can now build products that sit on top of bank data and become the primary relationship a customer has with their finances, without being a bank. You're not taking deposits. You're not trying to become a regulated bank from day one. That is a radically easier place to start. It does not mean trust, consent, privacy, and compliance suddenly stop mattering. It means the rails are more open than they were before.
You're not replacing banks. Banks are great at holding money, settling payments, and managing risk. They also carry constraints most startups don't, which makes it harder to build focused software for narrow use cases quickly. They've had the customer data for decades and, in many cases, delivered broad generic experiences rather than products people love.
The application layer, the products that actually help people and businesses make better decisions with their money, is wide open. And for the first time, anyone can build it.
I don't want to limit what "bank without being a bank" means. It could be a personal finance tool that actually sees your full picture across every account. A lending product that uses transaction data as one input instead of relying only on blunt credit signals. A business cashflow tool that forecasts from actual bank feeds, not spreadsheets. A Pay by Bank checkout that bypasses card schemes entirely.
If I were looking for whitespace, I'd start with problems where money movement is central but the software is still awful:
- Cashflow forecasting for small businesses that live close to the edge - Vertical software for accountants, mortgage advisers, property managers, and payroll providers - Consumer products that help people avoid fees, smooth income, or automate savings using real transaction patterns
The point is that the data is there and the permission model exists. What gets built on top of it is up to builders.
The convergence
This would be interesting on its own. But it's landing at the same time as something else.
I wrote a few weeks ago about New Zealand's three-year window, the argument that AI-native companies built from scratch will outcompete legacy businesses that try to retrofit AI into existing structures. The advantage goes to whoever builds clean, not whoever adopts fastest.
Open banking is a specific, tangible version of that argument.
A traditional fintech trying to build on open banking data has to navigate existing codebases, existing product assumptions, existing teams, existing business models. They'll spend months in planning meetings and "discovery". By then, the window has moved.
A solo founder or a small team building AI-native from day one doesn't carry any of that weight. They can prototype in a weekend using their own bank data. They can have something working before a large company has finished writing the brief. AI agents are fundamentally changing how much a small team can do. Fewer people with the right tools can drive enormous economic impact. Open banking is where that thesis meets a specific, underserved market.
The data is available. The tools to build are better than they've ever been. The incumbents are structurally slow. This is a window, and it's open right now.
What I'd tell the version of me from ten years ago
If I were starting today instead of 2015, here's what I'd do differently. These are lessons that took me years to learn.
Understand your revenue model on day one. Not "we'll figure out monetisation later." Who is paying you, for solving what problem? I spent too long building something useful without being clear on the business model underneath it. A side project doesn't need revenue. A business does. Know which one you're building, and when you're ready to cross over.
Don't just solve your own problems. My starting point was scratching my own itch. That's a great way to find a real problem. It's a terrible place to stop. The thing you build for yourself is a prototype. The business comes from understanding who else has that problem and whether they'll pay to make it go away.
Distribution is the hard part, not the product. This is the one that gets most developers. AI has made building absurdly easy. You can ship a working product in a weekend. Finding customers is still hard. The best products I've seen in this space don't try to acquire customers directly. They partner with businesses that already own the customer relationship. Accounting firms, financial advisers, property managers, payroll providers. Build for their customers, distribute through them. That lesson hasn't changed in ten years.
Regulation is a moat, not just a hurdle. Most developers see financial regulation and run the other way. That's exactly why it's valuable. If you lean into the complexity of consent, data privacy, and financial compliance, you build something that's genuinely hard to copy. The easy stuff gets competed away. The hard stuff compounds.
Start with existing infrastructure. You don't need to build the rails. They exist. Every hour you spend rebuilding something that's already available is an hour you're not spending on the thing that makes your product different. Build on top. The value is in the application layer now.
Talk to customers before you write code. This one is harder than ever, because AI makes it so tempting to just build. You can have a working prototype before you've spoken to a single potential customer. Resist that urge. The fastest way to waste a month is to build something nobody wants. The fastest way to build something people want is to ask them first.
The NZ market is small, and that's a feature. You can get in front of a meaningful share of your market quickly. Try doing that in the US. Small market means fast feedback loops. You can test an idea, get real responses, and iterate in weeks. Use that. It's an advantage founders in larger markets would kill for.
Be honest about what's still hard. The rails existing doesn't mean the problem is solved. Consent flows still matter. Trust still matters. Distribution still matters. If you're expecting open banking to remove all the friction, you're going to be disappointed. It removes one category of friction. That's enough.
The real moat
Here's the thing most people miss about this opportunity.
Access to bank data is more available than it's ever been. Building products is, thanks to AI, getting steadily cheaper. So where's the defensibility?
The products that win won't just have a pretty UI or a clever demo. They'll solve a recurring problem well enough that users keep coming back. In doing that, they'll accumulate context. Every transaction categorised, every payment pattern recognised, every workflow completed, every business insight surfaced, all of it feeds back into a product that gets more useful over time. That's a moat that doesn't exist on day one. You earn it through retention.
Most banks probably won't build this. They have the data, but usually not the speed, focus, or incentive to turn that data into narrow, high-utility software. A competitor can copy your features more easily than they can copy your accumulated understanding of a customer's financial life.
Build the product that gets better with use. That's the thing that compounds.
Start this weekend
Here's the part where I'm supposed to wrap up with something grand about the future of financial services. Instead, I'll make it practical.
If you want to experiment, Akahu offers a personal app tier. You sign up, connect your own bank accounts, and start building with real data. Your data. No commercial agreement needed.
When you get stuck, the Akahu developer Slack has our team, Josh, David, Olly and Will, alongside a growing community of people building on open banking in New Zealand.
Build the thing you wish existed for your own finances. Show it to a few friends. If they want it too, you might have something. If they'd pay for it, you definitely do.
You don't need to quit your job. You don't need to raise money. Build it on nights and weekends until the idea proves itself.
Ten years ago, I had to reverse-engineer bank data, raise capital, and hire a team just to get started. You need an API key and a Slack invite. Don't take ten years.
I'm Ben Lynch, founder and CEO of Akahu and Dolla. I think about founders, AI, and what happens next from New Zealand. Say hello at ben@thinkdorepeat.ai.
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If this made you think, forward it to someone who'd enjoy it. Especially if they've got a side project idea they keep talking about but haven't started.