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Managing consent in Embedded Finance

When banks and other financial institutions make their products available via non-banks, we call that Embedded Finance. Think, for example, of a retailer offering financing for people buying goods; or a budgeting app gathering bank transactions to help you categorize and understand your spending patterns. The finance – the money management – has been embedded into the retailer or the budgeting experience.

This last example falls under the Data Exchange category of Embedded Finance , and it’s often also called Open Banking. In many countries this active data exchange is actually mandated by law, with specific Open Banking standards encoded into law for all financial institutions. As of this blog post, there are approximately 37 countries with such laws already in place or currently being worked on.

In an Embedded Finance scheme there are three main players: The financial institution offering their products and services, a third party provider (TPP) making use of those products or services, and an end user who is a customer of the financial institution and is interacting with the TPP.

The most important ingredient for these schemes is consumer trust. If a consumer does not trust that their data will be safely shared with a third party, and that they can easily understand the terms they have agreed to and stop sharing their data whenever they want to, consumers will simply not participate. When a consumer agrees for their data to be shared, this is called consent.

What components do I need for a successful Embedded Finance solution?

Banks’ products and services are made available to other parties via APIs, thus a fundamental component is an API Management platform. An API Management Platform lets you design, secure, analyze, and scale APIs anywhere with visibility and control.

Also, we need a component to manage consents given by end users. Consent Management refers not only to the capability of checking whether a certain action by a third party (eg: access an end user’s account balance) is valid according to the consent granted by the end user to that TPP,  but also the availability of tools for end users to check existing consents, modify them or revoke them, as well as tools for financial institutions to perform similar actions on behalf of their customers.

Finally, we need an Identity Platform capable of authenticating an end user and establishing their identity.

A Google Cloud based embedded finance solution uses Apigee as the API management platform, Identity Platform or your own identity platform of choice, and a consent management service (CMS).  Google Cloud has partnered with two leading providers in the consent management space: Clarip and CloudEntity.

How do these components work together?

The main roles and responsibilities of each of the three components are quite clear, but there is a certain degree of flexibility on how to orchestrate the interactions between the components, and which component performs which function when there is an overlap of functionality between them.

Google Cloud has tested the following interaction patterns:

Interaction Pattern #1: Apigee as the main orchestrator

In this interaction pattern, Apigee interacts with both the consent management service and the identity platform, coordinating end user authentication with the identity platform, and authorization and consent with the consent management service. Apigee acts as the “broker” between users, their identity, and their consent.

Interaction Pattern #2: The consent management service abstracts the identity platform.

In this case, the consent management service manages all the interactions with the identity management platform, and the identity platform acts as the “broker”. Apigee only interacts with the consent service.

The three components share a common pool of client apps and end users. One of the components is typically designated as the source of truth for these entities, while the other components that need to know about these entities synchronize that information from the source of truth. 

The identity platform is typically the source of truth for end user identities and the consent management component will synchronize that information by pulling it from the identity platform. 

The consent management service is the source of truth for user opt-in and current consent status. Apigee will either check with the service the validity of a consent every time a request comes through, or to make it more efficient, it will validate the main attributes of the consent based on information stored in Apigee. To maintain consistency, the consent management service should tell Apigee to invalidate any tokens associated with a consent when it is revoked via other means (for example, if an end user revoked consent from a consent dashboard).

For client apps, either Apigee or the consent management component can act as the source of truth, with the other component synchronizing the information. In the context of Open Banking in particular, standards often mandate that financial institutions support Dynamic Client Registration. This means having endpoints that new clients can use to register themselves as clients for the Open Banking APIs. In this case, the synchronization of clients can easily be incorporated into Dynamic Client Registration.

Let’s look now into more detail about how the three components interact. There are two user journeys that are particularly relevant:


This is the beginning of the typical consumer client journey, when an end user starts using a third party app that requires access to that user’s data. The third party app needs to authenticate itself, and request authorization to access the user’s data. This will trigger the authentication of the end user and consent granting: Consent granting being the process of, the user authorizing the operations the app will execute on their behalf, and establishing the list of accounts on which these operations will be performed. The authorization is represented by an access token, which the app will need to include in all subsequent requests.

This is quite a complex journey with many steps involved in order to make this as secure as possible. To make it easier to understand, we will simplify some of the steps (apologies in advance to you OIDC/FAPI experts out there!).

At a high level, these are the steps involved in this user journey:

End user starts using an app

The app requests permission to access user’s data

The identity platform (IdP) authenticates the end user

The consent management service obtains consent from end user

An access token is issued for the app, encapsulating the authorized permissions, accounts, etc. A refresh token is also issued – the access token normally has a short life (measured in minutes), but the app can use the refresh token, which typically lasts much longer (days or months), in order to obtain a new access token without the need of going through the end user authentication/authorization/consent process again.

The way these steps are orchestrated varies depending on the interaction pattern among the components.

Pattern #1: Apigee orchestrates all interactions
When the client requests permission, Apigee will record the request and then redirect the client app to the IdP login page. Once the end user logs in, the IdP will return an authorization code to the callback URL that Apigee registered in the IdP configuration.

Apigee will then redirect the client app to the Consent Management service, so that the consent form is displayed. Once the user grants consent, selects the desired permissions, and selects the accounts it will apply to, the Consent Management Service will update Apigee with the status of the consent, via a callback Apigee registered in the consent configuration.

Now that the end user has authenticated and granted consent, Apigee can now issue an authorization code, and associate all the necessary information, for instance, details about the consent, the authorization code issued by the Identity Platform (IdP), the identification of the end user in the IdP, etc. Apigee will return this authorization code to the client app via a callback endpoint that the app provided when registering with Apigee.

The app will then exchange the authorization code for an access token. Apigee will obtain an access token from the IdP, abd update the status of the consent before issuing an access token to the client.

Pattern #2: The Consent Management Service is the center of the Architecture
In Pattern #2, Apigee will only communicate with the Consent Management Service, which acts as an authorization server for the app and will also coordinate all interaction with the IdP.

When the client requests permission, Apigee will forward the request to the CMS. The CMS will record the request and then redirect the client app to the IdP login page. Once the end user logs in, the IdP will return an authorization code to the callback the CMS registered in the IdP configuration.

The CMS then displays the consent form. Once the user approves the consent and selects the desired permissions and accounts it will apply to, the Consent Management Service will return an authorization code to Apigee, via a callback Apigee registered in the CMS configuration.

From now on, the flow is the same as explained above. Apigee will issue an authorization code, associate all the necessary information and will return this authorization code to the client app via a callback endpoint. The app will then exchange the authorization code for an access token. Apigee will obtain an access token from the CMS, before issuing an access token to the client.

Let’s now look at the other relevant user journey:

Access shared data 

Once the third party app has been authorized, it will then start requesting that end user’s data. For instance, it may request the list of accounts or the balance of a particular account. 

When that request goes through, a series of checks need to be performed: Is this third party app still authorized? Has it been granted the right permission for the operation being requested? Is the account involved included in the list of accounts authorized by the end user? Apigee can perform all these checks by inspecting the access token presented by the third party app. 

There is, however, one other check which cannot be done simply by inspecting the token. Imagine for a moment that in-between the user granting consent and the app requesting the user’s data, the end user decided to revoke that consent. This could be done by other means than the app itself, for instance by checking all consents granted to all apps in a consent dashboard accessible via other channels such as an “Internet Banking” site. When the app requests the user data, the token is still valid, however the consent has already been revoked. Therefore, in this user journey, Apigee will check with the Consent Management service to check if the consent is still valid. This adds a bit of overhead, which can be minimized by other means. For instance, one popular optimization is to make sure that the Consent Management service asks Apigee to revoke any access or refresh tokens associated with a given consent when that consent is revoked via other channels. If that guardrail is in place, then Apigee can determine if a request should be allowed simply by validating the access token and using the consent information stored alongside the token.

The following diagram summarizes the interactions required between Apigee and the Consent Management component. The interaction is essentially the same in both interaction patterns.

What’s next?

In this article we have described how Apigee, a Consent Management service, and an Identity Platform are the fundamental ingredients of a successful and secure Embedded Finance solution. We have also looked at how these components interact with each other to keep user consent consistent and available. Both interaction patterns described are valid and have been proven to work. So which one may be right for you? The answer ultimately depends on your particular requirements, the choice of consent management service, and your choice of identity platform. As a rule of thumb, if you have multiple application experiences, identity systems, and sources of consent, an Apigee-centric architecture is a great solution. If you are looking at a Consent Management service in the context of an Open Banking implementation mandated by a centralized authority (eg: Open Banking Brazil, Consumer Data Standards in Australia), CloudEntity is a good choice for consent management, as their product is also Certified Financial-grade API (FAPI) OpenID Provider, with profiles for the various Open Banking standards. CloudEntity integrates with Apigee using Pattern #2. 

For more details on both Clarip and CloudEntity’s offerings and how their particular solution works with GCP please check:

Clarip: Universal Consent Management Platform – GDPR

CloudEntity: Certified OpenBanking  & Consent (UK, Brazil and Australia) at scale

For more details on Apigee API Management, see

You can also learn about our solutions for retail banking or contact sales.

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