Written submission from Open Banking Limited (PRO0158)

Open Banking Limited Response

Business and Trade Committee Inquiry: Priorities for 2026

Summary

Open Banking Limited (OBL) welcomes the opportunity to respond to the Business and Trade Committee’s call for evidence on its 2026 priorities. Our response focuses on how the UK’s Smart Data agenda, rooted in the success of open banking, can stimulate economic growth, improve productivity, and enhance the UK’s global competitiveness.

As the UK’s first Smart Data scheme, open banking has established a series of horizontal ‘building blocks’, which include common technical standards, consent frameworks, and trust services, that can be applied across sectors to propel efficiency and interoperability. These building blocks offer a proven model that can be applied to Smart Data schemes in other economic sectors, and indeed could achieve interoperability between these schemes.

As the Government renews its focus on economic growth and innovation, open banking - and further Smart Data schemes - should be recognised as core national priorities for 2026 and beyond. Together, they can help open new markets and deliver tangible benefits for consumers, businesses, and the broader economy, whilst promoting the UK as a hub of digital innovation.

In essence, prioritising a Smart Data-driven economy can:

• Help achieve the Government’s pro-growth agenda
• Help increase productivity for SMEs
• Help improve financial inclusion

And to achieve this, we recommend the Government should:

• Deliver a Smart Data framework at pace
• Maintain interoperability as a guiding principle
• Establish relevant central coordinating interface bodies
• Embed trust and consent frameworks.

About Open Banking Limited 

OBL is the implementation entity described in the Retail Banking Market Investigation Order 2017 (the Order), tasked with building the UK’s world-leading Open Banking Standard and industry guidelines to help drive competition, innovation and transparency in UK retail banking.  

In nearly eight years, open banking has contributed £4.1 billion to the economy, driven inward investment and created nearly 5,000 highly skilled digital jobs[1]. The ecosystem has also delivered significant consumer and business benefits. We now see over 16 million user connections of open banking and more than 33 million account-to-account (A2A) payments monthly (as of October 2025[2]).

Response

Pro-growth reforms and investment

Open banking is a catalyst for the Government’s pro-growth agenda, and this has been recognised in multiple strategy documents such as HMT’s ‘Financial Services Growth and Competitiveness Strategy’, ‘Financial Inclusion Strategy’, and the ‘National Payments Vision’. Open banking gives consumers and businesses greater control and visibility of their data and enables trusted third parties to use that data to provide better, cheaper and more efficient services.

Open banking has shown that when a clear legal mandate, consistent trust frameworks, and a standardised technical approach are combined, innovation flourishes. These are precisely the conditions that create confidence for private investment and stimulate new markets. Open banking has created a new ecosystem of fintechs[3], and the same approach for Smart Data could unlock new value across other sectors of the economy, if supported by clear strategic direction.

Scaling open banking’s approach beyond financial services would accelerate private investment and support growth in strategically important industries. The Department for Business and Trade estimates that personal data mobility could add £28 billion to UK GDP, with the wider Smart Data economy valued at £10 billion over the next decade[4]. By applying open banking’s proven model to other sectors, such as energy, wider financial services products, and homebuying, the UK can strengthen competition and deliver the data infrastructure needed for a modern and efficient economy.

Productivity growth

Smart Data directly addresses the UK’s long-standing productivity challenge by reducing friction, automating processes and unlocking smarter decision-making for firms.

Open banking already delivers measurable productivity benefits:

• Open banking payments may lower transaction costs and help improve cash flow. HMRC collected £12 billion in account-to-account transactions between February 2024 and January 2025, reducing administrative overheads and payment errors[5].
• Data portability allows SMEs to share financial records securely with lenders, improving credit assessment and unlocking access to finance more quickly.
• Open banking APIs enable cloud-based accounting and real-time financial visibility, freeing businesses from manual data handling and supporting better planning.

By extending these capabilities, Smart Data can amplify productivity gains across the economy. For example, interoperable, cross-sectoral Smart Data schemes could connect financial data with utilities, energy, or transport datasets, enabling automated tariff switching, help with accurate ESG reporting or integrated carbon measurement. This could help businesses save time, reduce costs and meet sustainability goals simultaneously.

Beyond productivity, Smart Data can play a vital role in supporting the Government’s regional growth ambitions. By lowering barriers for SMEs to access and use digital markets, it enables place-based economic development and helps ensure the benefits of innovation are shared more evenly across the UK. It also provides a practical mechanism for turning national growth policy into local impact. By giving consumers and businesses access to tailored, data-driven services, Smart Data can improve planning processes and promote a more inclusive pattern of economic growth across every region.

Better regulation and business confidence

Confidence and predictability are central to business investment decisions. Open banking’s success shows how the right regulatory model can create a trusted and stable foundation for innovation.

Smart Data fosters this by embedding trust and consent as cornerstones of design. Consumers remain in control of what data they share, with whom and for what purpose. A trust framework comprising accredited directories, secure APIs, and fraud-prevention standards ensures data sharing is consistent and safe. These features are critical to fostering user confidence and business participation in an increasingly digital economy.

By establishing a single, enforceable standard and governance body, the Government could simplify compliance, remove duplication, and provide a level playing field for both incumbents and innovators. Trust is further strengthened through the integration of digital verification services, a capability explicitly supported by the Data (Use and Access) Act 2025. This could enhance security, streamline onboarding and reduce fraud losses, with potential savings of over £600 million per year[6]. This not only improves consumer confidence but reduces operational risk and costs across the wider economy.

Conclusion

The UK’s early success in open banking demonstrates how Smart Data can act as a structural lever for growth, productivity and competitiveness. With the right legislative foundation, consistent governance and partnership between government and industry, Smart Data can underpin a new era of confident, competitive and data-driven growth across the UK economy.

To realise its full potential, we recommend the Government should:

1. Deliver the Smart Data framework at pace, finalising secondary legislation and setting out a long-term roadmap for implementation. We are looking forward to DBT’s Smart Data Strategy in early 2026, and we suggest that a prescriptive roadmap is produced, building on the previous version published in 2024[7], with a clear plan for how new schemes will be prioritised, governed and funded. This will offer businesses the clarity and confidence to invest in our fintechs.
2. Maintain interoperability as a guiding principle, ensuring new Smart Data schemes build on, or take inspiration from, open banking’s standards and governance to avoid duplication and inefficiency.
3. Establish relevant central coordinating interface bodies, with a clear remit, mandate and sustainable funding model - to oversee cross-sector standards, promote innovation and drive delivery.
4. Embed trust and consent frameworks across all Smart Data schemes to sustain user confidence and SME productivity through use cases that unlock finance, automate payments and streamline reporting.