Building a borderless data economy: Mifundo’s take on the EU’s future data strategy

At Mifundo, we know that the free flow of data across borders is a matter of fairness, inclusion and competitiveness. That’s why we strongly welcome the European Commission’s ongoing work on a European Data Union Strategy and we’re proud to have submitted our contribution to the recent call for evidence available here. This future Strategy, expected to take the form of a Communication later in 2025, offers a key opportunity to reshape how Europe manages and governs data across Member States and in its engagement with the wider world.

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In this article, we share why this initiative matters to us, what principles we believe should underpin the new strategy and how Mifundo’s own work aligns with the EU’s goals.

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A fragmented market in need of cohesion

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The EU’s internal market promises free movement not just of goods and people, but also of services and data. And yet, fragmentation persists. Each Member State still has its own approach to credit data access, customer identification, reporting rules and digital compliance. These differences make it hard for firms like ours to deliver cross-border services and even harder for consumers to access them.

At Mifundo, we see this play out every day. Whether it is a cross-border worker applying for a mortgage or an expat trying to get a personal loan in their new home country, the challenge is always the same - their credit history doesn’t travel with them. They are treated as unknown and often uncreditworthy because national data systems don’t speak to one another. That’s why we support the Commission’s push for a coordinated, EU-level approach to data governance. Fragmentation creates inefficiencies, increases costs and puts both consumers and innovators at a disadvantage. A more unified framework could help unlock real economies of scale, increase trust and enable fair competition across Europe.

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Stimulating investment in Data and AI

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The Commission has identified investment and data availability as a key area for the new strategy. This includes improving access to strategic datasets such as financial and public sector data and supporting voluntary data-sharing initiatives that boost innovation in areas like generative AI and responsible finance.

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This is absolutely in line with our experience. At Mifundo, access to structured, high-quality and interoperable datasets from credit registers, banks and public bodies is essential for building scalable, AI-powered services. Yet today, many of these data assets are difficult (or impossible) to access in practice, especially for cross-border use.

We support proposals to:

• Fund initiatives that promote voluntary and trusted data-sharing partnerships
• Standardise data formats and APIs to improve interoperability
• Align new measures with existing frameworks like the Data Act and Open Finance

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Importantly, any new mechanism should complement rather than replace existing private-sector initiatives. Mifundo already acts as a secure, compliant bridge between data sources and users, making financial identity portable across the EU. Regulation should empower this kind of infrastructure, not duplicate it.

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Simplifying the rules and the tools

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Another priority identified in the consultation is simplification. That means reducing legal overlaps, streamlining reporting obligations and making it easier, especially for SMEs and startups, to navigate EU and national rules. We strongly agree. As a cross-border fintech, Mifundo encounters daily challenges linked to divergent national regulations on credit scoring, customer due diligence and data usage. These aren’t just frustrating. They slow down innovation and limit access to responsible financial services.

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We’re particularly supportive of proposals to:

• Harmonise relevant laws (like GDPR, the Mortgage and Consumer Credit Directives and the DGA)
• Promote automated compliance tools (such as plug-and-play APIs)
• Enable regulatory sandboxes and testing environments for cross-border services
• Explore digital-by-default reporting systems to reduce administrative burdens

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Mifundo already integrates AI-based compliance modules that adapt to local requirements. But a more joined-up framework would enable us and many others, to scale these tools faster, reaching more consumers and making the Single Market work better in practice.

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Thinking globally: A smarter international data strategy

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The upcoming strategy also aims to strengthen the EU’s role on the global data stage. Europe’s competitiveness depends on cross-border data flows and a coherent external approach can help avoid regulatory fragmentation, build trust and support trade.

We welcome the Commission’s commitment to developing an international data strategy that reflects European values such as trust, proportionality and fairness while enabling smoother data exchanges with the rest of the world.

This should include:

• Protecting the export of EU-generated data under clear, risk-based rules
• Encouraging the import of strategic data into the EU to support innovation
• Promoting mutual recognition of digital identity and compliance mechanisms
• Aligning internal policy with the EU’s external digital trade agenda

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Mifundo’s own platform makes credit data portable not only within the EU but also in interactions with international lenders, always based on user consent, transparency and GDPR compliance. We see great potential for a European strategy that enables secure contractual data sharing across jurisdictions while maintaining clear protections for individuals.

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Smart regulation for a smarter economy

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One of the most important messages we shared in our response is this: regulation should be proportionate, innovation-friendly and tech-neutral. Too often small firms are treated the same as large incumbents or asked to jump through overlapping regulatory hoops. This stifles innovation and deters new entrants, especially in sensitive sectors like finance.

We join others in calling for a regulatory approach that:

• Avoids duplicative licensing requirements
• Focuses on outcomes, not tools
• Supports the role of trusted intermediaries, like Mifundo, that already deliver cross-border, compliant services
• Builds incentives for market-led solutions, not mandatory centralisation

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In our case, we securely connect credit bureaus, banks and public sources across the EU. This enables fairer, more accurate credit decisions and gives people control over their financial identity regardless of where they live or work. That’s exactly the kind of outcome the EU should encourage.

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What’s next?

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The European Commission will finalise the Data Union Strategy later this year and we hope that the contributions of innovators like Mifundo will help shape its direction.

We believe this strategy can deliver real change if it:

• Promotes scalable, private-sector-led data infrastructure
• Reduces compliance burdens, especially for cross-border services
• Encourages voluntary, secure data sharing under user control
• Supports smart international engagement that protects EU values while promoting openness

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Europe has the opportunity to lead in building a trusted, competitive and borderless data economy.

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