On August 21st, the CFPB released an Advance Notice of Proposed Rulemaking (ANPR) on Section 1033. As part of the series of questions raised, the CFPB included a whole section on evaluating the optimal approach to the assessment of fees to defray the costs incurred by a “covered person” in responding to a customer driven request.
With this move, the conversation about API monetization shifted from theory to practice. JPMorgan Chase took a head start on this, signaling their intention to start charging for data access, and recently reached a new data access agreement with Plaid, which includes a pricing structure. In parallel, the Bank Policy Institute is calling for a “fair exchange” between data aggregators and banks.
Institutions of every size now face a pressing question: how will they approach API monetization?
The drivers are clear. Infrastructure and operational costs continue to rise as API traffic scales into billions of calls and more third-parties are seeking direct access to consumer data. For financial institutions, this creates both opportunity and risk. On the benefit side, monetization could mean recouping costs, ensuring the correct controls are in place for secure data access, and improving trust with partners.
But there are also risks. Regulatory scrutiny, slower innovation, and pushback from third parties (the Financial Technology Association recently urged the Trump administration to oppose “exorbitant” consumer data access fees) are real challenges for any monetization strategy.
Large financial institutions may already have pieces of the infrastructure and governance required, but regional and smaller institutions also face this reality, often not having the base API infrastructure in place yet.
Monetizing data access may or may not be the path for every financial institution. However, those considering it should understand the following key capabilities.
Financial institutions require reliable APIs that third parties can connect to and use to securely retrieve consent-driven consumer data.
Without consistency, scalability, and security, charging for access is not on the table. Reliability builds confidence with both regulators and third parties. It demonstrates that institutions can provide reliable and secure connectivity at scale.
Reliability isn’t just about uptime—it’s about resilience, proactive monitoring, and having the processes in place to handle surges in demand or unexpected disruptions.
Ultimately, a strong foundation of reliability sets the stage for any monetization strategy to succeed.
Financial institutions must answer a core strategic question: what is the goal of monetization? Most may see it as cost recovery, while others may explore revenue streams.
Defining the pricing philosophies and the corresponding billing constructs will set the stage for the rest of the solution design.
Answering these questions will influence the data, logs, and events that need to be tracked and metered to create the bills.
|
Pricing model |
Description / use cases |
|
Freemium |
Free access to basic data; charge for premium (e.g., enriched, categorized, non-covered data) |
|
SLA-based premium |
Price varies by SLA tier (e.g., uptime, latency). Useful when third parties have different service expectations |
|
Per API call |
Charge per API request. Best of unpredictable or ad-hoc usage |
|
Tiered subscription |
Fixed fee based on usage thresholds (e.g., calls/month); higher tiers reduce unit cost |
|
Data access license |
Flat quarterly/annual fee for unlimited or capped access |
|
Revenue share / value-based |
Fee tied to % of revenue generated from data-enabled services provided by the third-party (e.g., embedded finance) |
|
Per end-user |
Charge per consumer whose data is accessed |
|
Transactional |
Charge per successful transaction on behalf of the third-party. Best for “write” capabilities (e.g., payment initiation) |
|
T-1 Data |
Differential pricing for real-time vs. prior-day (T-1) data |
Pricing models are one piece of the equation; contracts are the other. Pricing terms will be negotiated and likely aligned to volume commitments. This will have an influence on how bills are generated.
Exceptions happen at the contract level, but exceptions have to be handled without undermining consistency.
Measurement is critical.
To operationalize API monetization, financial institutions (or their service providers) must meter API usage with enough detail to support the chosen pricing models.
This often means logging billions of calls, tracking endpoint usage, and capturing attributes like frequency, data categories, and third-party identity.
If billing on active connections, then the institution needs a mechanism to log API utilization for each of their user/third-party combo, and the ability to track usage changes.
If billing is based on the type of data retrieved, then the institution needs to keep a log of the type of data retrieved with each API call.
These logs and events need to be processed and stored in an auditable way. Financial institutions can see hundreds of millions, if not billions, of API calls in a single month and processing that amount of data is not a simple task.
Raw data alone is insufficient. It must be processed through data pipelines and likely enriched for billing relevance. Institutions need the ability to aggregate and normalize API usage events so that it can be tied to pricing models and contracts.
Without robust metering and processing, monetization will not be possible.
Turning the processed logs and events into invoices requires orchestrating information from multiple sources:
The expected output is a set of invoices that can be sent to the corresponding third-parties.
Every step taken by the billing engine must be transparent and auditable so that when dispute arises, issues can be investigated.
For third parties, transparency matters. Partners need access to dashboards that show real-time usage, billing history, and dispute resolution options.
A good experience reduces friction, builds trust, and increases efficiency.
For a successful API monetization program, a lot must be done right. Financial institutions can look at internal capabilities or they can turn to trusted partners to help them.
A true API monetization platform must combine flexibility with scale. A financial institution should seek several key solution capabilities in order to support the monetization of their APIs.
During the initial setup, financial institutions should be able to configure two interdependent parts of their monetization solution.
First, they should be able to configure pricing models, define offerings (e.g., per data category, account type), and set the corresponding rate cards for each offering that align with their pricing goals.
Second, the metering and processing capabilities are equally important. The institution should be able to set the required integration with likely multiple data sources (logs, events, and additional data needed to process any bills), rule engines to define chargeable events, and data pipelines to handle high-volume flows.
Beyond the initial setup, the platform must support ongoing account management. Each payee (i.e., the third parties accessing data) may be subject to custom pricing and/or negotiated terms, all of which would have to be handled as exceptions to the rate cards. The system must allow for these variations while maintaining consistency in the processing logic.
The billing process itself requires precision in calculating charges, generating invoices, and distributing them reliably.
For each third-party payee, the billing process needs to be set on the required schedule (e.g., monthly). The API monetization platform should be able to compute the respective bills of each payee, considering their current usage and the potential exceptions to their terms.
Once the bill is calculated, the system should be able to generate the corresponding invoice (typically in a PDF format) that provides the appropriate level of details.
This invoice needs to be sent out to the correct third-party contact.
And this has to be consistently repeated on schedule.
Payment collection and reconciliation close the loop.
As part of the invoice sent out to the third party, the financial institution might want to add payment instructions.
They may want to include different payment options and logic to determine which payment mechanism is most appropriate for the invoice. This is another capability that the monetization solution should provide.
For instance, if the invoice is small, the institution might accept payments from a credit card. If it’s a larger amount, they might require payment through bank rails to avoid excess processing fees.
It’s only a matter of time before third parties start raising questions. Providing them with a robust portal to access data related to their usage of a financial institution’s APIs is a first step towards reducing the risk of disputes.
Clear real-time and monthly reports on how APIs are used, which of the third-party’s applications is retrieving data, what kind of data, etc. provides the required level of transparency to build trust. The reports should align to the metering dimensions that are used in the pricing models.
In addition to usage reports, this third-party portal should also provide easy access to current and past bills. A third-party operator should be able to reconcile their invoices with the usage data reported. Of course, in the background, all of this should be backed up by clear auditable logs that trace events from the source, through the billing engine, all the way to the invoice.
And if all of that is not sufficient to resolve questions, then a simple mechanism to reach out to support or dispute an invoice can be used to address any issues.
This should provide a high-level view of the key capabilities necessary for a robust API monetization platform. Without these core capabilities, efforts risk stalling under operational complexity.
For institutions starting on this journey, a phased action plan is the most effective path.
First and foremost, any institution has to make the strategic decision whether to go forward with API monetization or not. A clear, documented strategy is required before discussing any functional capabilities.
Then, step two is ensuring the reliability of APIs. Without this foundation, downstream monetization is not possible.
Next, financial institutions should define their pricing strategy, clarifying what their primary goal is. Institutions must drive internal alignment, ensuring stakeholders across finance, compliance, technology, and product are on the same page.
With a strategy in place, attention shifts to building measurement capabilities—logging API usage, creating data pipelines, and ensuring data accuracy to support billing. Only then should billing systems and frameworks be stood up, creating the infrastructure for invoicing.
The conversation about API monetization has reached a tipping point. Industry leaders are already planning to charge for access.
Capabilities, not ideology, will determine success. Institutions that build reliable APIs, define clear pricing strategies, and invest in measurement, billing, and partner support will be best positioned to thrive.
At Akoya, we have invested in building a secure, reliable API infrastructure and a broad network of connections to simplify these challenges for financial institutions.
Whether you are at the beginning of your journey or looking to scale, Akoya can help accelerate readiness and ensure you deliver value to your institution, your partners, and your customers.
Contact us to learn more about our Open Finance Solution and how we can support your API Monetization Platform program.
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