FCA's open finance roadmap

The FCA’s 2026 programme is front-loaded, with a Policy Sprint in Q2, a PRISM taskforce report by Q3 and a discussion paper on the first scheme in Q4. Firms that participate in these processes – particularly the Policy Sprint and targeted engagement sessions – will have a direct opportunity to influence the scope of data-sharing obligations, liability models and the design of the first scheme. By 2027, the FCA intends to be working with the Treasury on the regulatory framework itself. Waiting until consultation stage may be too late to effect meaningful change. That said, the Roadmap targets Open Finance-based services coming to market only in 2029/2030 – a timeline that, given the pace of change in financial services and technology, many in the industry consider too slow.

Open finance would broaden access to customer data currently held by established firms, potentially lowering barriers to entry and increasing pricing pressure in areas such as SME lending, mortgages and insurance switching. For retail banks and large lenders, this means new fintech entrants could compete on a more level playing field. Firms should be assessing where their competitive position depends on proprietary data access and developing strategies to compete on service quality, trust and product innovation.

The FCA has identified technical and operational barriers – including latency, cost and lack of shared infrastructure – as key challenges. Firms should be auditing their data architecture to assess readiness for standardised, API-driven data sharing at scale. Consent management frameworks will also need to be robust, granular and auditable, particularly given the FCA's emphasis on secure, consent-based data sharing and its collaboration with the Digital Regulation Cooperation Forum on Consumer Duty and data protection interactions. Firms that treat this as a future compliance exercise rather than a current infrastructure priority risk significant remediation costs later.

Open finance does not sit in isolation. The Data (Use and Access) Act 2025 gives the Government powers to introduce smart data schemes across sectors, and the FCA is already collaborating with the energy sector on using banking data for social tariff assessments. For banks, this means data-sharing obligations may extend beyond financial services. However, it also creates commercial opportunities: firms that build interoperable data-sharing capabilities early could position themselves as infrastructure providers or trusted intermediaries across the wider smart data ecosystem.

The FCA has signalled that open finance will accelerate its shift towards outcomes-based, data-driven regulation. In practice, this means the FCA will use open finance data to monitor consumer outcomes and identify issues earlier - giving it greater supervisory reach with less reliance on detailed rulebooks. For firms, this is a double-edged sword: while it may reduce prescriptive compliance burdens over time, it also means firms will need to demonstrate good outcomes through data rather than simply evidencing process compliance. Governance frameworks, MI reporting and board-level oversight of consumer outcomes will need to evolve accordingly. However, there is a legitimate industry concern that data schemes should not be developed primarily to facilitate closer regulatory oversight of firms or to address theoretical consumer protection objectives that have not been tested as something consumers would want or trust. Firms should engage actively to ensure that the regulatory framework remains proportionate and justified by reference to identified market shortcomings.

The FCA recognises the vital role SMEs play in supporting UK economic growth and has prioritised exploring how open finance can improve their access to lending. Open finance could enable fintech firms to aggregate real-time transaction data and wider financial information – going beyond what is currently possible under open banking – to build a more accurate picture of a business's cash flow and creditworthiness. This could lead to faster lending decisions, reduced rejection rates and more efficient capital allocation. The FCA has already conducted TechSprints on SME lending, with participating firms developing solutions such as reusable data packages for loan applications and AI-assisted business planning tools.

The FCA sees open finance as a means of harnessing new technologies to change the way advice and sales are delivered in the mortgage market. Use cases include open finance-powered mortgage dashboards that combine data from multiple sources – including current accounts, savings accounts and market interest rate data – to provide consumers with personalised insights on affordability and overpayment strategies. The FCA has conducted TechSprints on mortgages, with firms exploring AI-enhanced affordability assessment tools, and a Policy Sprint on mortgages is planned for Q2 2026. The FCA also intends to collaborate with the Government's smart data scheme on reforming homebuying.

Beyond the initial priorities, the roadmap highlights several further areas where open finance could deliver significant benefits. In investments, open finance could enable consumers to connect data across multiple accounts to receive more tailored, suitability-assessed advice. In debt management, enhanced data sharing could help consumers in financial difficulty gain real-time insights into their finances and take practical steps to improve their position. In insurance, open finance could increase switching rates and improve pricing through greater data availability. The FCA's PRISM taskforce, due to report by Q3 2026, will systematically assess the impact of future use cases on consumer outcomes, competition, growth and innovation, and is expected to shape the sequencing of further schemes beyond 2027.