The FCA’s Open Finance Roadmap Is Really Promising, but the UK Has Ground to Make Up

The FCA published its Open Finance Roadmap last month. For regulators and central banks worldwide, it’s worth reading carefully.

Not because the UK leads the world in open finance right now. It doesn’t. But because the document is an honest, structured attempt to close a gap that has been opening up between the UK and some of its peers, and it articulates the work required with more clarity than most regulatory publications manage.

The vision is credible. The economic targets are specific and outline the huge potential of the opportunity. The roadmap is concrete. But this is still a plan, not a result. And the countries watching from ahead of the UK in the open finance race will be paying close attention to whether the delivery matches the ambition.

Where the UK actually stands

The UK led the way with regulated open banking. The standard built here between 2017 and 2021 became the reference point for markets across the world, from Brazil to Saudi Arabia to Australia. That founding role still carries real weight.

But open finance is a different competition, and the starting positions are not the same.

Brazil’s open finance framework, launched in 2021, already covers banking, insurance, pension, and investment data. Pix, its instant payment infrastructure, now has over 155 million users and has become the country’s dominant payment method. Brazil didn’t debate the infrastructure question. It built certain components centrally, moved fast, and scaled.

The UAE has taken a similarly decisive approach, but gone even further with a market enabling central infrastructure. Its centralised API Hub gave financial institutions shared infrastructure from the outset, rather than leaving each bank to build its own connectivity layer. The result is faster adoption and lower fragmentation across the market.

Australia’s Consumer Data Right (CDR) went further than open banking from the start: a cross-sector data portability framework covering banking, energy, and telecommunications, with a design intended to extend across the economy. It is the most ambitious attempt yet to build the kind of joined-up smart data infrastructure that the FCA’s roadmap now aspires to.

Against that backdrop, the UK’s roadmap is a catch-up document as much as it is a leadership statement. The government’s goal of being a world leader in open finance is an ambition, not yet a description of where things stand.

What the roadmap actually proposes

The FCA has set out a phased plan to 2030:

2026: Prioritisation. A PolicySprint in Q2 will build industry consensus on use cases. A taskforce will develop a Prioritisation and Real-world Insights Selection Matrix (PRISM) by Q3, mapping use cases against their impact on consumer outcomes, competition, growth, and innovation. A TechSprint in Q4 will test infrastructure requirements. A discussion paper on the first open finance scheme will be published in Q4.

2027: Design and coordination. The FCA will work with the Treasury on the regulatory framework, test proposed scheme structures, and engage industry and consumer groups.

2028–2030: Scaling up. Launching schemes with governance, interoperability, and consumer protection standards in place.

The priority use cases are SME lending and mortgages, selected because the evidence from 2025 TechSprints is clearest there, and the gap between what open banking currently enables and what’s actually needed is most visible.

The economic case, if delivery follows, is significant. McKinsey estimates open finance could contribute 1–1.5% of UK GDP by 2030. Open Banking Limited and EY put the combined annual impact of open banking and open finance at £7.4 billion within five years. Smart data schemes across homebuying, trade, retail, and energy could add £9.6 billion annually to GDP by 2043.

Those numbers are not aspirational decorations. They are the standard against which delivery will be judged.

The infrastructure question is the central one

The most important acknowledgement in the FCA roadmap is also the one that carries the most risk if it isn’t acted on decisively.

Fragmented infrastructure is named as a key barrier to open finance delivery. The document is honest about it: the UK lacks the centralised investment in shared infrastructure that would support interoperability, oversight, and long-term adoption. The FCA is commissioning research into architecture and technology infrastructure models, including both centralised and decentralised approaches.

That research is necessary. But for regulators elsewhere watching this process, the lesson from markets that are already ahead is clear: shared infrastructure is not a technical detail to resolve after the policy framework is agreed. It is a policy decision in its own right, and it needs to be made early.

Brazil and the UAE made that decision at the start. The result is measurably faster adoption, lower costs for participants, and less fragmentation across the ecosystem. Australia’s CDR was designed with cross-sector data portability as a founding principle, not an aspiration.

The UK is now commissioning the research that some of its peers have already acted on. The roadmap is right to treat infrastructure as a central question. The risk is that it takes until 2027 or 2028 before the architecture decisions are made, by which point the gap widens further.

For any regulator designing a new open finance framework today: don’t treat shared infrastructure as something to revisit once the policy framework is settled. Build it into the design from the start. The markets that did are ahead. The markets that didn’t are still catching up.

What would success look like?

The FCA’s roadmap is more honest than most about what open finance actually requires: clear governance, interoperability, consumer protection, and a commercial model that gives firms a genuine reason to participate beyond minimum compliance.

The proof will be in delivery. Specifically:

Whether the Q4 2026 discussion paper addresses the commercial model question seriously, not just the data access question. Markets where firms have no clear incentive to invest beyond compliance tend to get compliance-level investment.

Whether the infrastructure architecture decisions are made decisively in 2027, rather than deferred again.

Whether the use cases prioritised by PRISM actually result in working schemes by 2028 to 2030, rather than further consultation rounds.

The FCA has done something valuable by publishing a roadmap this concrete. The milestones are specific enough to be tracked and held to account. That accountability is itself meaningful.

But the countries that are already ahead in open finance didn’t get there by publishing good roadmaps. They got there by building shared infrastructure early, moving quickly to live implementations, and treating the commercial model as a design question rather than an afterthought.

The UK has the foundations, the expertise, and now a credible plan. Whether this roadmap gets the UK back to the front of the pack depends entirely on whether those promises are delivered on.

“The infrastructure question is where I’d push hardest on this roadmap. As you move beyond day-to-day banking, the dynamics change significantly. The biggest banks have millions of users opening their apps every day, and they’ve embedded consent flows into experiences people already trust. But open finance brings in insurers, pension providers, investment platforms — many with smaller budgets and far less digital presence. A decentralised infrastructure approach that a tier-one bank could absorb would be crippling for a broader set of smaller providers. And with more players comes more complexity in the trust framework, which makes shared, centralised infrastructure even more important, not less. Specifically the key infrastructure includes centralised API hubs, centralised consent solutions and a shared trust framework.

But infrastructure isn’t the only gap. What I don’t yet see clearly in the roadmap is the regulatory scope question: which players are in, covering which products, by when. Until that’s answered, firms can’t make real investment decisions; everything stays contingent. And then there’s commercialisation. We learned this the hard way with open banking: if you don’t build balanced incentives from day one, progress is slow and hard-fought. The roadmap acknowledges this as a barrier but doesn’t treat it as a foundational design principle. How open finance gets funded and delivered at scale is still an open question. Good intentions and engagement processes don’t answer it.”

— Huw Davies, CEO and Co-Founder, Ozone API

Ozone API’s founding team built the UK Open Banking Standard and now powers open finance infrastructure for banks, PSPs, and regulators across 30+ markets. Get in touch to discuss what the FCA roadmap means for your market.