4. OECD Questionnaire findings
This chapter presents the results of the OECD FinTech market questionnaire, which had an approximately 20% response rate (a quarter of the total FinTech sector). Results are likely to be skewed towards firms in their early stages or with pain points and can be interpreted as an upper bound on the hurdles the Czech FinTech face. The answers highlight the crucial role of data for financial innovation in the Czech Republic and the importance of inter-institutional collaboration between FinTechs, the regulator and financial intermediaries. Regulation is perceived as the key challenge, followed by access to market and funding. There is also a potential new risk to the system, such as the concentration on new dominant and unregulated payers.
In June 2022, the OECD launched an online open questionnaire on FinTech activity in the Czech Republic. Twenty-four FinTech companies (17 individual answers and 7 FinTechs operating under the aegis of FinTech Hub) provided detailed responses to this Questionnaire as of 5 October 2022, out of a total of c.100 Czech FinTech companies’ universe. These companies are headquartered in the Czech Republic or in the Slovak Republic, and 42% of these FinTechs target only the Czech market (Figure 4.1).
In terms of geography of operations, more than half of the respondent FinTech headquarters are located in the Czech Republic, but equally, half of responding FinTechs have operations on a pan-European level (Figure 4.1). Passporting rights enable FinTech firms that are authorised in any EU or EEA state to freely trade in the Czech Republic (as in any other member state) following notification of the host authorities (see Section 4.1). These passports are the foundation of the EU single market for financial services. The possibility of foreign non-EU FinTech companies benefitting from a relatively lower regulatory burden and of prey firms establishing in the Czech market is a possible concern to Czech authorities, given potential risks to customer safety and investor protection.
Source: Based on a sample of 24 responses (17 individual responses and 7 answers through FinTech Hub) by Czech FinTechs to the OECD Questionnaire.
The majority of firms that answered the questionnaire operate in the payments and electronic money services provision (Figure 4.2).
Source: Based on a sample of 24 responses by Czech FinTechs to the OECD Questionnaire.
The majority of the firms responding to the questionnaire are in the seed stage of their lifecycle (Figure 4.3). Firms in the seed and early stages usually are the ones that benefit the most from the collaboration and interaction with industry mentors and government officials (World Bank, 2022[1]), in order to navigate regulatory requirements and to learn from veteran experiences.
Source: Based on a sample of 24 responses by Czech FinTechs to the OECD Questionnaire.
Access to data is critical for FinTechs and data is at the core of most FinTech activity (e.g. artificial intelligence business models in trading; lending; blockchain-based uses in finance (OECD, 2021[2]). FinTechs are technology-native and combine the agility of start-ups with data processing and crunching abilities. Indeed, more than 60% of respondents to the OECD Questionnaire stated that access to both financial and non-financial data is beneficial to their business development. The two firms that answered that more data is not necessarily beneficial to their business development work in providing security solutions to digital applications and on online invoicing (Figure 4.4).
Source: Based on a sample of 24 responses by Czech FinTechs to the OECD Questionnaire.
As stated in the previous paragraph, data collection, processing and analytics play a key role in FinTech innovations that increasingly rely on data availability for their business models. Unequal access to data and potential dominance in the sourcing of big data by few large players could reduce the capacity of smaller players to compete in the market for FinTech innovation-based products/services (OECD, 2021[2]). In fact, the strength and nature of competitive advantages created by advances in innovative technologies such as artificial intelligence, could potentially harm the operations of efficient and competitive markets if consumers’ ability to make informed decisions is constrained by high concentrations amongst market providers (Mnuchin and Phillips, 2018[3]). To that end, greater availability of data can be conducive to the development of start-up companies with possible beneficial impact on competitive conditions in financial markets.
The OECD survey shows that most innovations used by respondent Czech FinTechs evolve around data, data sharing and data usage for the development of products and services. In particular, 88% of firms use APIs to access data, more than half of respondent firms use big data and 63% of firms use cloud computing – all evolving around data at the core of their business model. Other digital technologies used include distributed ledger technologies (DLTs) (33% of respondents) and digital ID services (25% of respondent firms) (Figure 4.5).
Source: Based on a sample of 24 responses by Czech FinTechs to the OECD Questionnaire.
Incumbent firms usually have costly legacy and potentially obsolete infrastructure and rather inefficient processes associated to such infrastructure, which, combined with cultural reluctance for change may prevent or slow down in-house FinTech innovation. The definition of what a bank is, is being called into question. Moreover, the speed of adoption of digital technologies and FinTech products and services by customers, and the marked acceleration in the demand for such products, particularly since the COVID-19 pandemic, is driving incumbent co-operation with FinTechs.
Access to data is one part of the needs of FinTechs that can be satisfied by such co-operation with incumbent financial institutions. As many start-ups are in the seed stage (Figure 4.3), they can benefit from monetary investment and expertise from co-operation with incumbents or investment by incumbents in their capital. This expertise comes from the knowledge of the business and the ecosystem, and the network effects add to the possible upside of such co-operation.
As FinTechs operate with third-party data, interdependences are created with data and digital service providers that might pose new risks to the system, such as the concentration on new dominant unregulated players. BigTechs, for example, increasingly leverage their free access to vast amounts of customer data that feed into artificial intelligence-driven models to provide financial services, their deployment of AI raises issues around data privacy and concerns over ways in which the collection, storage and use of personal data may be exploited for commercial gain. These practices could disadvantage customers, such as through discriminatory practices related to credit availability and pricing (OECD, 2021[2]).
The vast majority of respondents to the questionnaire highlighted the importance of accessing financial data for their business (88%), and more than 50% highlighted the need to access personal data, which serves for the personalisation of products and services, along with non-financial data (55%), potentially spurring the financial inclusion of underbanked customers (Figure 4.6).
APIs are the most frequent form of tool allowing for data accessibility by FinTechs (88%), along with aggregators and special purchases from specialised firms (58%). Screen scraping (own data production) is also a frequent form of data gathering, used by 42% of respondents to the questionnaire (RHS of Figure 4.6).
Source: Based on a sample of 24 responses by Czech FinTechs to the OECD Questionnaire.
When it comes to FinTechs sharing their own data, 83% of respondents reported that they do not share data beyond what is required by law, for different reasons. For larger firms, data is part of their key inputs; for early-stage firms, data is not part of their monetisation case yet.
Even when it comes to data sharing secured by formal regulatory arrangements and frameworks, data accessibility is not guaranteed. More than 46% of firms responding to the OECD Questionnaire have had problems accessing customer data from financial intermediaries. There are technical and strategic reasons explaining the problems: respondents reported that external APIs do not function properly in many cases, while others claimed that banks should be required by law to digitally sign documents.
There is a role for policy makers to reduce barriers to market entry by limiting abusive dominant practices that impede competition and create risks of market concentration with detrimental impact on financial consumers, as well as systemic risk. At a minimum, existing frameworks for data sharing arrangements should be promoted and their correct implementation safeguarded.
Financial regulation existing across the board for financial services safeguards market integrity, consumer protection and promotes financial stability (OECD, 2021[2]). From the industry standpoint, it provides for legal certainty that allows companies with innovative business models to develop and grow. At the same time, regulatory compliance is usually perceived by young start-up firms as a hurdle, given the associated cost and time commitment (World Bank, 2022[1]; OECD, 2020[4]) although it is unanimously agreed that regulation is essential to keep customers safe and to preserve the stability of the system. According to the findings of the OECD questionnaire, the most important reported hurdles to FinTech innovations in the Czech Republic are related to regulation: lack of regulatory clarity (67%), red tape (63%), licensing and supervisory requirements (58%), followed by entry barriers (54% of respondents) (Figure 4.7). Procedures for starting a business are more burdensome and time consuming than in most other OECD economies and the Czech Republic ranks 134th in the 2020 Doing Business survey for the “starting a business” indicator (World Bank, 2020[5]). According to the OECD 2020 Czech Survey, resolving commercial disputes (“enforcing contracts”) takes longer than on average in the OECD, and is more costly to businesses (OECD, 2020[4]).
Source: Based on a sample of 24 responses by Czech FinTechs to the OECD Questionnaire. More than one answer is possible.
For 11% of the respondents, finding a retaining talent seems to be a concern, and could be related to the fact that these companies employ innovative technologies and mechanisms that require specialised skillsets by highly skilled employees. Nevertheless, when it comes to digitalisation skills, the Czech Republic is clustered in the group of OECD countries characterised by the highest skills proficiency (OECD, 2020[4]; Citibank, 2022[6]). On the other hand, in 2020, the European Commission suggested in its country report that although the Czech authorities are committed to the development and integration of new digital technologies, such effort is hampered by persistently low skills levels. For example, the Czech Republic still lags behind frontier Member States in terms of research and patent activities in this area (European Commission, 2020[7]).
Access to funding is one of the most commonly impediments to entrepreneurship across many OECD and developing economies (OECD, 2015[8]) and a reported challenge to Czech FinTech development (Figure 4.7). Overall, SMEs financing gaps may stem from an overreliance on the bank credit intermediation channel, which may be constraint particularly in times of stress. Lack of awareness about alternative funding sources and a reluctance of founders and entrepreneurs to relinquish ownership in exchange for equity financing are additional challenges. When it comes to market debt financing, SMEs have substantial structural disadvantages in obtaining such financing compared to large corporates given deal sizes and related economics of small transactions and disproportionate costs associated with such issuances (Nassr and Wehinger, 2015[9]). The European Commission has also recommended support towards SMEs by making greater use of financial instruments to ensure liquidity support, reducing the administrative burden, and ensuring access to finance for innovative firms (European Commission, 2020[7]).
In the case of the Czech Republic, the ease of getting credit is above the regional average and reflects strength of legal rights and depth of credit information. The coverage of credit information by the credit bureau is very high, but there is limited availability of credit information by credit registries. A recent action that supported accessibility of credit was the adoption of a new legal regime on secured transactions that allows the registration of receivables at the collateral registry and permits out-of-court enforcement of collateral (World Bank, 2020[5]). The dominance of the banking sector in the Czech financial system may also underline the ease of getting credit. However, equity and non-bank debt markets remain underdeveloped (see Section 5.1.3) and may hinder the development of FinTechs and the entire start-up ecosystem.
FinTech respondents signal as additional challenges the issues of access to market and business development. Regulatory sandboxes are one of the policy tools used to assist companies in overcoming the challenges on market access, as by creating an open dialogue between the regulator and the firm, they provide agility to the supervisory and regulatory framework ( (World Bank, 2020[10]) (World Bank, 2020[11])). Indeed, regulatory sandboxes are beneficial to both parties: they allow innovators to test on a small scale their products, services and delivery mechanisms (as evidenced by the United Kingdom experience), while providing the regulator with intelligence on developments, trends and emerging risks ( (Bromberg, Godwin and Ramsay, 2017[12]; Kalifa, 2021[13]), (World Bank, 2020[10]), (World Bank, 2020[11])).
Licensing also appears to be cumbersome for Czech FinTechs responding to the OECD Questionnaire: 40% of FinTech firms answered that they had to request a license more than once before successfully acquiring one. This figure is even higher if one considers the fact that 53% of the FinTechs responding to the Questionnaire are operating in non-regulated sectors and likely represent part of the “No” in this question. Indeed, the number of procedures required to start a business is twice as many as on average in OECD countries and the time required to complete each procedure is 2.6 times greater than the peer group (OECD, 2020[4]).
The reported cumbersome licensing process adds to FinTechs’ perception of regulatory burden described above. There may be a need to clarify processes for licensing and authorisation and/or to educate new market entrants around applicable regulatory frameworks, particularly in areas of FinTech innovation, in order to address some of the reported impediments to FinTech development. It could also be noted that, interestingly, most Czech FinTechs operate in non-regulated sectors; the perceived burden of regulation evidenced by the OECD Questionnaire could perhaps further incentivise FinTechs to develop activity in non-regulated sectors so as to avoid such burden.
Source: Based on a sample of 24 responses by Czech FinTechs to the OECD Questionnaire.
The complex administrative procedure of establishment was also identified as one of the main obstacles for start-ups in the Czech Republic by the European Commission (European Commission, 2022[14]). Together with fast-changing legislation, complex administrative procedures are seen by the business sector as obstacles to investment, while the administrative burden is particularly problematic for start-ups in terms of licences and permits (European Commission, 2020[7]). The Commission therefore recommended that Czech Authorities remove the barriers hampering the development of a fully functioning innovation ecosystem (European Commission, 2019[15]).
As mentioned above, access to finance constitutes one of the challenges for FinTech companies in the Czech Republic. Based on the responses to the OECD Questionnaire, the main investment source for Czech FinTechs is personal resources (37% of respondents), which is consistent with start-up and SME companies deploying own funds and friends and family financing (Berger and Udell, 2003[16]). Czech entrepreneurs rely mainly on their own resources and seed capital (68% of companies secured seed capital from own sources while only 48% were able to find an investor in a recent industry survey) (Deloitte Česká Republika, 2022[17]). In particular, 14% of start-ups raised initial funding from family or relatives and friends, while 5% took a loan from a bank. The overall difficulty of finding an investor was assessed in that survey as 5.33 on a scale from 1-10.
Domestic Venture Capital (VC) funding appears to be the second most important funding source in the group of respondents (18%). When combined with international VCs, this source of funding becomes the most widely used in the group (33% combined VC). These responses reflect the increase in VC activity by domestic funds in the Czech Republic although there is still room to develop further VC funding in the country relative to the levels observed in the rest of Europe (see Section 4.4). Czech FinTechs are also looking for VC as their main investment source in the future (Figure 4.9).
It should be also noted that none of the FinTech firms responding to the OECD Questionnaire received funding from the public sector (local or national) (Figure 4.9).
Source: Based on a sample of 24 responses by Czech FinTechs to the OECD Questionnaire.
The majority of respondents have a neutral or favourable opinion of the Czech Republic as an easy place to raise investment (Figure 4.10). A caution note can be made on this assertion, as only FinTechs who have successfully raised funding for their innovation have answered the OECD Questionnaire, so there is a possible survival bias and sample selection bias in this exercise (Keogh and Johnson, 2021[18]).
Source: Based on a sample of 24 responses by Czech FinTechs to the OECD Questionnaire.
Another interesting observation of the responses to the OECD Questionnaire relates to the exit strategy of responding FinTechs: the majority of FinTechs report to be in the business in order to be acquired by incumbents or larger FinTechs/BigTechs (M&A accounting for more than 64% of the responses). Although this is understandable, it is not conducive to increased competition in the market for financial services and are subject to the terms of the acquisitions (Figure 4.11).
Source: Based on a sample of 24 responses by Czech FinTechs to the OECD Questionnaire.
More than 77% of respondents to the OECD Questionnaire believe that it would be beneficial to introduce a regulatory sandbox in the Czech Republic.
According to the OECD survey, 71% of respondent FinTechs would be interested in a sandbox with a focus on data, if it was to become available (Figure 4.12). Two-thirds of these would only be interested depending on the terms of such sandbox. This highlights the importance of a well-thought design and structure of any future sandbox arrangement. It also highlights a possible lack of clear understanding of what a sandbox involves from the FinTech side. This underscores the importance of – clear communication and the required educational effort that may need to be undertaken in such effort.
Source: Based on a sample of 24 responses by Czech FinTechs to the OECD Questionnaire.
Sandbox arrangements enable firms to test innovative financial products and services and develop business models that are based on the use of innovative technologies and mechanisms, subject to the specific rules applied by the supervisory authorities. Although sandboxes can involve the use of legally provided discretions by supervisory authorities, the baseline assumption for regulatory sandboxes is that firms are required to comply with all relevant rules applicable to the activity they are undertaking (BIS, 2018[19]). In addition, sandboxes do not entail the disapplication of regulatory requirements that must be applied as a result of EU law (ESMA, EBA and EIOPA, 2018[20]; Parenti, 2020[21]).
Regulatory sandboxes can foster innovation in the financial sector while allowing supervisors to observe and address emerging risks of the deployment of innovative technologies in finance, with benefits that extend to all stakeholders involved. They allow supervisors to enhance their understanding of innovative mechanisms deployed by FinTechs that may alter the risk profile of certain financial activities, which, in turn, may have a beneficial impact on the development of adequate policy responses to such innovations. Importantly, they reduce regulatory uncertainty for FinTechs and can help lower the perceived regulatory burden that has been observed in the OECD survey of FinTechs in the Czech Republic. In terms of funding, empirical evidence suggests a beneficial impact of sandbox participation for fundraising of companies, facilitating access to finance which has been highlighted as one of the most important impediments to the establishment and growth of SMEs in the Czech Republic and beyond (Cornelli et al., 2020[22]). Sandboxes can also promote competition, and allow for the development of new products and services, diversifying financial consumer offering and possibly promoting financial inclusion or other policy objectives, such as sustainability (FCA, 2022[23]).
When it comes to a data sandbox, this could conceptually involve a controlled environment on which FinTechs could test innovations on the basis of data sharing, data usage and business models that rely heavily on data. For example, the development, testing and validation of artificial intelligence-based products and of machine-learning-based models could be envisaged in a controlled environment of a data sandbox, or distributed ledger technology-based activity could be developed for the recording and analysis of large volumes of (unstructured) data. Indicatively, such data sandbox could provide real and synthetic datasets available through the sandbox or collected through API calls or could consist of an effort to collectively gather such datasets in co-operation with participating firms and depending on their needs.
Other noteworthy findings of the OECD Questionnaire suggest that the FinTech sector is largely male-dominated in the Czech Republic based on the survey sample. Although women are half of the country’s population, less than 25% of FinTech employees are females (Figure 4.13). The proportion of female ICT specialists is the second lowest in the EU after Hungary (EU 2022).
Bringing in more women could increase the productivity of firms and could also widen the set of possible solutions and innovations. One of the potentials of FinTechs is to bring financial services to underserved populations, and female customers are one of them (IDB, 2022[24]; CCAF, 2021[25]; Chen et al., 2021[26]; Loko and Yang, 2022[27]).
Source: Based on a sample of 24 responses by Czech FinTechs to the OECD Questionnaire.
In terms of expected impact of forthcoming regulations, PSD2 appears to have the most impact on FinTechs responding to the OECD survey, with AML also scoring high. This is very much consistent with the heavy reliance of the business models concerned on data and APIs, discussed above.
Source: Based on a sample of 24 responses by Czech FinTechs to the OECD Questionnaire.
In June 2022, Czech founders, an informal and non-profit platform of Czech start-up founders, published the results of a “Start-ups and state” survey performed in co-operation with Deloitte and the Confederation of Industry and Transport. The survey was based on responses by 156 company representatives and provides a perspective of the start-up situation in the Czech Republic.
According to the survey, there are three main obstacles in the Czech Republic identified by Czech start-ups: inadequate legal framework for employee share and stock option plans; hiring conditions for employees, including foreigners; and the need for a simplification of tax bureaucracy. Other problematic issues noted in the survey were what was noted as an unclear tax system, high employee costs and regulation of cryptocurrencies, particularly the possibility of financing through ICOs.
The survey also called for greater availability of grants for new jobs, as current grants set out conditions that are perceived as very difficult to be met by start-ups that are they are mostly operating in deficit in their first years of operation.
Importantly, one of the topics touched upon in the survey was the availability of public data for innovative product development, which 52% of respondents being dissatisfied. Another 66% of respondents further stating that they would like to use more public data or other sources for the development and testing of innovative products and services (including banking data for FinTech, open data for mobility, etc.)
Source: Czech Founders (2022[28]), Startupy a Stát, https://www.slideshare.net/VitHorky/startupy-a-stt-report-czech-founderspdf?from_action=save.
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