Your data, your rights: Building full picture credit in the Philippines
For years, reformers have spoken of “Open Banking” and “Open Finance.” These are important ideas, but they sound technical and distant. What the Philippines truly needs is something clearer and more ambitious: What I call Full Picture Credit.
We need a system where a person’s creditworthiness is assessed not only through the existence of a bank account, credit card, or loan, but across the full range of their financial life. Responsibility and capacity to pay show up in many places: utility bills paid on time, prepaid mobile top-ups, subscription payments, remittance inflows, e-wallet transactions, gig platform earnings, loyalty programs, even rent payments. These everyday behaviors reflect financial discipline. They should count.
Imagine applying for a loan and being able, with your consent, to authorize the lender to access relevant financial data beyond traditional bank records, such as utility payments, mobile subscriptions, remittance history, e-wallet transactions, etc. Through secure application programming interfaces (APIs), the same technology that powers mobile apps, this data could be transmitted directly to financial institutions for credit evaluation.
With more complete information, lenders gain a fuller and more accurate view of an applicant’s financial behavior. For responsible borrowers, sharing more data could mean better outcomes: higher approval rates, larger loan amounts, and lower interest rates. Applying with limited information, by contrast, often leads to conservative credit decisions.
Without meaningful data sharing, lenders assess risk based on partial visibility. When individual risk cannot be measured accurately, pricing reflects the average risk of a broader pool. As a result, responsible payers effectively subsidize those whose risk profiles are unclear. Lenders price defensively. More granular data allows risk to be differentiated more precisely, so disciplined borrowers are not penalized by a system that cannot fully see them.
The Philippines has already laid much of the groundwork. In 2021, the Bangko Sentral ng Pilipinas (BSP) issued Circular No. 1122 adopting an Open Finance Framework built on consent-based data portability and inter-operability. In 2023, the BSP launched the Open Finance PH Pilot to explore API-enabled services and governance standards. The Securities and Exchange Commission (SEC) introduced regulatory sandbox mechanisms to encourage financial innovation. The Credit Information Corp. continues expanding access to credit data and strengthening reporting obligations.
These are critical building blocks. But they remain largely within traditional financial silos. Full Picture Credit means going further by recognizing alternative data that are evidence of responsible transacting and creditworthiness. In a modern digital economy, responsible non-bank behavior should matter.
The urgency is clear. According to the BSP’s 2024 Financial Inclusion Annual Report, 56% of Filipino adults now have an account, up from 29% in 2019. That is significant progress — but it still means roughly 44% remain unbanked. Of those with accounts, many rely on e-money rather than traditional banks, and most accounts are used primarily for payments rather than savings.
Globally, 76% of adults had an account in 2021, according to the World Bank’s Global Findex. The Philippines is catching up, but access to an account does not automatically translate into access to credit. Many Filipinos, especially informal workers and MSMEs, have steady incomes yet lack traditional credit histories. They are “thin file” borrowers: economically active but practically invisible to formal credit systems.
This is where alternative data becomes transformative and thankfully, international experience offers guidance.
In the United Kingdom, Open Banking allows consumers to authorize access to transaction histories for credit assessment. Lenders increasingly use cashflow-based underwriting to evaluate affordability in real time, particularly for thin-file borrowers. Open Banking has facilitated new market entrants and strengthened competition. Evidence shows meaningful entry effects and lower financing costs for certain borrowers, especially SMEs that benefit from improved data access.
Brazil has scaled this approach even further. Its Central Bank built a national Open Finance infrastructure designed to increase competition and improve credit allocation. Millions of consumers have provided consent for data sharing, enabling standardized exchange of account, credit, insurance, and investment data. The Central Bank reported average reductions in interest rates for borrowers whose scores improved with expanded data. Better information translated into better pricing.
Cambodia offers a different lesson. Through the National Bank of Cambodia’s Bakong digital payment system, millions of inter-operable digital transactions now occur daily. While alternative data is not yet fully integrated into credit scoring, the digitization of everyday payments creates the transaction records necessary for new credit models to emerge. Once payments become visible, they can become meaningful.
The connection between better credit data and financial literacy is crucial. When consumers can see that paying a utility bill on time strengthens their credit profile, financial literacy becomes tangible. Responsible behavior generates measurable benefits. This feedback loop reinforces budgeting, timely payment, and prudent subscription management.
Financial literacy is not just about knowledge. It is about visible consequences. If the system ignores responsible non-bank behavior, it discourages engagement. If it recognizes that behavior, it rewards discipline.
The Philippines is uniquely positioned for this reform. We are a mobile-first society. Mobile connections exceed the national population. Filipinos spend among the longest hours online globally, and most access the internet through mobile devices. E-wallet penetration is high. Remittances are increasingly digital. MSMEs transact through QR payments and online platforms. Every day, Filipinos generate rich digital financial footprints, yet most of this data remains unused in formal credit assessment.
Full Picture Credit would allow Filipinos, with explicit consent and strong safeguards, to share their broader financial footprint across regulated institutions. It would enable lenders to price risk more accurately, reduce overreliance on collateral, and compete for underserved borrowers. Most importantly, it would create a system where financial responsibility translates directly into financial mobility.
This reform aligns with the Philippines’ Data Privacy Act, modeled heavily on the EU’s General Data Protection Regulation. The law enshrines the rights of data subjects: the right to be informed, to access, to object, and, critically, the right to data portability. Full Picture Credit does not weaken these protections, rather it activates them. It gives Filipinos the practical ability to direct where their data goes and for what purpose.
This is not about forcing data to move. It is about empowering individuals to decide when and how their data works for them.
The Philippines has already built the regulatory scaffolding. The next step is to expand the spectrum of usable data in a safe, responsible, and inclusive manner.
If we want genuine financial inclusion, we must reform credit assessment to reflect how Filipinos actually live and transact. It is time to move beyond narrow banking reform and enable our citizens to exercise their data, their rights, for their credit.
This article reflects the personal opinion of the author and does not reflect the official stand of the Management Association of the Philippines or MAP.
Ira Paulo Pozon is the chair of the MAP Ease of Doing Business Committee. He is a senior partner at Pozon Recto Petrache and Laiz Law Offices. He previously served as the chief of staff and OIC director of the Better Regulations Office of the Anti-Red Tape Authority or ARTA. He is a Technology, Cyber, Sustainability and Risk Advisory Professional.
