Open Banking Trends Marketers Should Watch in 2026

Evidence current to: 28 July 2026

Open banking is moving from an initial regulatory remedy towards a more complicated mixture of regulated access, commercial payment schemes, open finance policy and broader smart data infrastructure.

That does not mean every announced initiative is law, or available at scale. Across 2025 and 2026 some developments reached implementation, some remained commercial initiatives, and others were still consultations or legislative proposals sitting in a queue.

For the durable definition, use cases and legal limitations, read our guide to open banking for marketers. This article covers what materially changed and what marketing, customer experience, product, data and compliance leaders should monitor next.

Where I cite a published source it is numbered and listed at the end with a live link. Where I am reading the market rather than a document, I say so.

What changed since the previous edition

• The UK Payments Initiative moved commercial variable recurring payments closer to an operating scheme model ^[1].
• The FCA and Payment Systems Regulator set out a temporary competition law enforcement position on UKPI’s proposed centralised access fee ^[2], in a prioritisation statement limited to Phase 1 and Wave 1 of the scheme ^[3].
• HM Treasury published a three year Payments Forward Plan ^[4].
• The UK Government published its Smart Data Strategy ^[5].
• The FCA published a staged open finance roadmap extending to 2030 ^[6].
• HM Treasury opened a consultation on modernising payment services regulation, which closes on 6 October 2026 ^[7].
• The Council of the European Union and European Parliament reached a provisional political agreement on the PSD3 and Payment Services Regulation package ^[8].
• The European procedures had not, by 28 July 2026, completed final adoption ^[9][10].
• Open Banking Limited published Standard version 4.0.1 ^[11].
• Industry reporting indicated more than 19 million active open banking user connections and more than 40 million open banking payments per month in the UK, although that figure needs several caveats set out below ^[12].

The direction is towards commercialisation and broader data sharing. The legal, governance and pricing models remain partly unsettled.

Scope and evidence date

This analysis covers developments materially relevant to UK and European open banking, open finance and payment initiation between 2025 and 28 July 2026.

The status labels used below mean:

• In force: legally effective.
• Adopted: final approval has occurred, although application may begin later.
• Provisional agreement: political agreement exists, but formal legal adoption remains outstanding.
• Proposed: a legislative proposal is still in the legislative process.
• Consultation: views are being sought; the contents are not final rules.
• Policy roadmap: an official direction and timetable, not legislation.
• Commercial or industry initiative: a scheme or standard developed by market participants rather than enacted law.

UK regulatory and commercial developments

Development	Date	Status on 28 July 2026	Why it matters
FCA and PSR access fee statement [2][3]	20 January 2026	Temporary enforcement prioritisation position, limited to Phase 1 and Wave 1	Gave UKPI greater certainty to develop a centralised commercial VRP access fee model. It is not a general competition law approval
Payments Forward Plan [4]	26 February 2026	Official policy plan	Sets a coordinated three year regulatory roadmap across 2026, 2027 and 2028
Smart Data Strategy [5]	26 March 2026	Government strategy under enabling legislation	Establishes a broader direction for interoperable smart data schemes
FCA open finance roadmap [6]	14 April 2026	Regulatory policy roadmap	Sets staged work from use case prioritisation in 2026 towards scaling between 2028 and 2030
UKPI announcement [1]	2 June 2026	Industry led commercial scheme initiative	Moves commercial VRPs beyond policy discussion towards scheme development
Modernising Payment Services Regulation [7]	14 July 2026	Open HM Treasury consultation, closing 6 October 2026	Seeks views on adapting regulation for open banking and other payment innovations
Long term open banking framework [1]	Consultation expected by the end of 2026	Not yet adopted	The FCA has said the consultation is subject to expected legislation providing new powers

The UKPI announcement is commercially important. It is not evidence that commercial VRPs are universally available. The FCA described it as an industry led scheme intended to give people more choice in recurring payments, and said it wanted competition among commercial open banking schemes ^[1].

The long term regulatory framework also remained unfinished. The FCA said it will consult on a long term regulatory framework by the end of 2026, expressly subject to legislation expected to give it new powers ^[1]. That is a future regulatory step, not a rule in force.

European PSD3 and Payment Services Regulation status

The European Commission proposed a revised Payment Services Directive and a directly applicable Payment Services Regulation in June 2023.

On 27 November 2025 the Council and European Parliament announced a provisional political agreement on the package. The Council described proposed measures including stronger anti fraud requirements, increased fee transparency, fraud information sharing and account name checks ^[8].

A provisional political agreement is not adopted law.

Instrument	Jurisdiction	Procedure	Current status	In force?
Proposed revised Payment Services Directive, commonly called PSD3	European Union	2023/0209(COD)	Awaiting the Council’s first reading position [9]	No
Proposed Payment Services Regulation	European Union	2023/0210(COD)	Awaiting the Council’s first reading position [10]	No
Existing PSD2 framework	EU and national implementations	Directive (EU) 2015/2366	Remains the existing legislative foundation pending replacement	Yes, subject to applicable national and EU arrangements

Both procedure files record a most recent key event of 5 May 2026: approval in committee of the text agreed at early second reading interinstitutional negotiations ^[9][10]. That is a meaningful step, and it is worth being precise about what it means. The text is agreed and has cleared committee. The procedure is not complete, no final instrument has been adopted, and nothing has entered into force.

Marketing and product teams should not build compliance plans on the assumption that the agreed wording is final. Final legal texts, publication dates, application periods, delegated measures and national implementation of the directive will determine the practical obligations.

Open finance and smart data developments

The UK roadmap

The FCA’s April 2026 open finance roadmap sets out an indicative path to 2030. Its 2026 priorities include identifying high impact use cases, starting with lending to small and medium sized enterprises and improving consumer access to mortgages, alongside evidence gathering and assessment of consumer, competition and market effects. A later phase is headed explicitly as scale and deliver, covering 2028 to 2030 ^[6].

These are policy intentions. They are not current rights to obtain pensions, insurance, mortgage, savings or investment data.

For marketers the practical implication is to keep four things separate:

• an open banking capability available today
• an experimental open finance use case
• a future scheme dependent on rules and standards
• a broad strategic forecast

The UK Smart Data Strategy

The Department for Business and Trade published its Smart Data Strategy on 26 March 2026, issued as Smart Data 2035.

The strategy states that the government now has powers to require firms to participate in smart data schemes, under the Data (Use and Access) Act 2025 ^[5].

Those powers create a foundation. They do not by themselves activate a particular scheme, define its participants, settle commercial terms, authorise marketing reuse, or establish a common customer experience standard across sectors. Individual schemes will need their own design, rules, governance and implementation.

The EU financial data access proposal

The European Commission’s proposed Framework for Financial Data Access, commonly called FIDA, is intended to establish rights and obligations for customer directed financial data sharing beyond payment accounts. The Commission’s timeline records the legislative proposal on 28 June 2023 ^[13].

The European Parliament procedure file for 2023/0205(COD) records the proposal as awaiting Parliament’s position at first reading, with a most recent key event of 18 December 2024 ^[14]. It is not adopted and not in force.

That date is the finding. Nineteen months with no recorded movement on the file is a materially different situation from the PSD3 package, which cleared committee in May 2026. FIDA should be monitored separately from PSD3 and the proposed Payment Services Regulation. They are connected parts of the EU’s financial data and payments agenda, they are not one instrument, and they are visibly progressing at different speeds.

Variable recurring payments

Variable recurring payments allow a customer to authorise an approved provider to initiate a series of payments within agreed parameters. Open Banking Limited describes VRPs as operating within customer defined parameters covering the amount to be taken over a given time period, with the end date of the permission agreed upfront ^[15].

The UK’s initial mandated VRP use case focused on sweeping money between accounts belonging to the same customer. Commercial VRPs extend the concept to payments to other organisations.

What changed in 2026

The significant developments were commercial and regulatory rather than a universal mandate.

The FCA announced the UK Payments Initiative on 2 June 2026 as an industry led scheme intended to advance commercial VRPs ^[1].

Earlier, on 20 January 2026, the FCA and PSR published a prioritisation statement saying they will not at this time prioritise investigations under Chapter I in relation to UKPI’s proposed pricing arrangements ^[2][3].

The scope of that position is much narrower than it is usually reported, and the detail matters:

• it concerns enforcement prioritisation, not compliance
• it applies only to Phase 1 and Wave 1 of UKPI’s commercial VRP scheme, with Phase 2 and Wave 2 expressly outside it ^[3]
• the relevant use cases are the lower risk categories: regulated financial services, regulated utilities, and local and central government ^[3]
• it may be reconsidered if circumstances or information change
• it runs until the anticipated long term framework is in place or until July 2027, whichever is earlier ^[3]

Anyone planning against commercial VRPs on the strength of a headline about regulators approving open banking pricing is planning against something that does not exist yet.

What marketers should evaluate

Commercial VRPs may affect subscription sign up, recurring billing, payment method choice, customer control over mandates, failed payment recovery, cancellation, refund and dispute processes, merchant payment costs, reconciliation and payment communications.

The temptation will be to treat a new payment rail as a campaign tactic. It is worth resisting, and there is a reason beyond compliance to resist it.

Across ten years of watching loyalty structures, the companies that got what they actually wanted from loyalty were consistently the ones billing customers monthly. The payment itself created an incentive no points scheme replicated, because a customer who is paying feels they should be buying from you. That is a genuine effect and it cuts both ways. A recurring payment arrangement changes the relationship, not just the settlement method, and a customer who does not fully understand the mandate they agreed to will eventually understand it at the worst possible moment. Make the mandate, the limits, the frequency, the cancellation process and the merchant identity legible at the point of authorisation.

A lower nominal transaction price also proves nothing about total cost. Integration, fraud controls, reconciliation, support and scheme fees all belong in the comparison.

Payment initiation developments

Payment initiation has moved from a specialist alternative towards higher volume use in selected UK contexts.

The FCA reported in December 2025 that open banking payments had grown by 53% year on year, citing latest industry figures ^[16]. Two caveats belong with that number. The FCA does not state which periods are being compared, and it attributes the figure to industry data rather than presenting it as its own measurement. It is directional evidence. It is not a universal merchant growth rate, and it is not proof that payment initiation improves conversion for any particular checkout.

Payment initiation is most relevant where the customer proposition is clear: paying an invoice, funding an account, settling a bill, making a high value bank payment, or authorising an appropriate recurring arrangement.

Treat it as part of the product and checkout experience rather than an acquisition mechanism. Useful measures include eligible session coverage, payment method selection, authentication completion, failure by bank and device, time to complete, repeat selection, refund completion, fraud and scam reports, support contacts, and incremental completion against an appropriate control.

Adoption and active use evidence

Open Banking Limited reported in July 2026 that UK open banking supported more than 19 million active user connections and more than 40 million payments per month ^[12].

These figures need more care than they usually get, and the report itself is the reason why.

The published figures are internally inconsistent and undated

The June 2026 edition of the fraud monitor states in its introduction that there are over 18 million user connections. Its final page, and the accompanying summary published on 8 July 2026, both say over 19 million active user connections ^[12]. Neither figure carries an as at date. The payments figure is presented as a current monthly rate with no reference month identified, footnoted to a separate monthly performance update ^[12].

This is the clearest illustration I can offer of a rule that applies to every number in this article. No single statistic is the misleading one. Looking at any statistic in isolation is what misleads. A figure quoted without its definition, its date and its population is not evidence, however official the source, and this one is currently circulating in three different forms from one document.

If you quote it, quote the metric name, the publication date, and the fact that the report is not internally consistent about it.

Connections are not people

One person can hold several connected accounts, use more than one open banking provider, keep separate personal and business connections, and create connections for different services.

More than 19 million active user connections cannot be rewritten as 19 million individual UK consumers. It is a different unit.

Payment volume is not merchant adoption

A monthly payment count does not reveal the number of unique payers, merchant coverage, transaction value, repeat concentration, consumer satisfaction, payment success by use case, incremental conversion, or profitability.

The reporting body has an interest

Open Banking Limited is the UK implementation and standards body. Its operational data is useful primary industry evidence and it is not independent research.

The same report states that its fraud analysis draws on submissions from account providers representing more than 60% of open banking payment volumes, covering the period from March 2024 to March 2026 ^[12]. That period applies to the fraud submissions, not to the connection and payment figures above. Include the population and the period whenever the fraud rates are quoted.

Consent and customer experience developments

No development identified in the primary sources for 2025 or 2026 created a general marketing consent through open banking.

Three separate permission questions remain relevant:

1. What has the customer authorised the provider to do through the open banking service?
2. What lawful basis supports each personal data processing purpose?
3. Do separate direct marketing rules permit a promotional communication?

A VRP mandate is also not a marketing consent. It defines payment authority within agreed parameters and nothing more.

Standard version 4.0.1

Open Banking Limited published version 4.0.1 of the UK Open Banking Standard on 1 April 2026 ^[11].

OBL described it as a targeted update and expressly not a major release. It included changes across technical specifications, Customer Experience Guidelines and Operational Guidelines, with refinements relating to international payment data and sweeping VRPs, and it introduced cryptoassets, coded CRYP, as a transaction risk indicator ^[11].

The conclusion to draw is not that the customer experience model was replaced. It is that implementation teams should check whether their screens, data handling and technical mappings remain aligned with the clarified standard.

Avoid outdated consent period claims

The primary sources do not establish a single universal reauthorisation period that can safely be stated across account information services, payment initiation, VRPs, jurisdictions and marketing use.

Requirements differ by service and may change through standards or regulation. Any implementation should verify current regulatory requirements, the relevant standard version, the provider’s permission model, reconfirmation and authentication requirements, what happens when access expires or is withdrawn, and whether retained data can still be used for the stated purpose.

API and security standard developments

Version 4.0.1 focused on clarification and consistency rather than a wholesale technical redesign ^[11].

Marketing leaders do not need to manage individual API fields, but they should care about the downstream effects: changes in available information, authentication and redirection behaviour, error handling, payment or connection completion, fraud controls, analytics continuity, and how any of it gets explained to customers.

The OpenID Foundation published the final FAPI 2.0 Security Profile on 22 February 2025, describing it as an API security profile suitable for high security applications based on OAuth 2.0 ^[17].

Final publication is a standardisation development to monitor. It does not mean every UK or European implementation had adopted FAPI 2.0 by July 2026. Distinguish between a final international specification, adoption in a jurisdictional standard, a provider’s implementation, and completed certification or assurance.

Commercial sustainability and infrastructure economics

The original UK open banking remedy concentrated on secure access and competition. Broader commercial services now require answers to questions the remedy never had to ask: who pays for premium or commercial access, how fees are calculated, whether pricing is centralised or bilateral, how smaller providers participate, who funds standards and directory services, how liability is allocated, which service levels are guaranteed, how scheme rules are enforced, and whether payment savings reach merchants or customers.

The UKPI access fee discussion matters strategically for exactly this reason. It represents movement from a largely regulatory access model towards an explicit commercial scheme.

It is too early to state a general merchant saving. Economics will vary by payment type, transaction value, fraud exposure, integration route, provider, scheme fees, volume, reconciliation requirements, customer support and existing card arrangements. Ask for a total cost model rather than a transaction fee comparison.

There is a structural point underneath this that applies well beyond payments. A channel or rail whose economics depend on another organisation’s pricing and policy decisions is not a stable planning assumption, however good its current numbers look. Marketing teams have learned this repeatedly with platform owned channels, usually after building a business case on the good years. Commercial VRP pricing is set by a scheme that is still designing itself, and Phase 2 is not covered by the regulators’ current position at all.

What this means for marketers

The developments worth attention are the ones that change a customer facing proposition, or the evidence available to support it.

1. More payment choice. Commercial VRPs and payment initiation may give customers new ways to pay. The marketing task is to explain the option accurately and help customers choose it, not to hide mandate details to improve immediate completion.

2. Better defined service propositions. As open finance develops, firms may experiment with services involving mortgages, SME lending and broader financial information. Frame these as customer services with defined outcomes rather than data acquisition exercises.

3. Greater scrutiny of permissions. Growth raises the importance of understandable connection, renewal, disconnection and mandate management experiences.

4. More complex supplier economics. Access fees and commercial schemes change the business case. Procurement, product, finance and marketing should be working from the same total cost assumptions.

5. More demanding measurement. Rising payment volume makes testing easier. It does not remove the need for control groups, representative populations and clear metric definitions. It also does not make last year’s result permanent: behaviour and audience composition keep moving, so findings need re-establishing rather than filing.

6. Higher reputational stakes. Financial information can reveal or imply sensitive circumstances. Organisations that treat it as routine advertising data create privacy and fairness risks out of proportion to the benefit.

For implementation planning, see the open banking data implementation guide. For campaign and analytics governance, see open-banking personalisation and guardrails.

Developments that remain uncertain

Treat the following as monitoring items rather than established outcomes.

UK long term legislation. The FCA’s intended consultation depends on expected legislation. Timing, powers and final framework details may all change.

Commercial VRP coverage. UKPI is progress. Service coverage, participating providers, eligible sectors, price levels and customer adoption are all implementation questions, and the regulators’ current position covers only Phase 1 and Wave 1.

Competition among schemes. The FCA has expressed a preference for competition among commercial schemes ^[1]. The eventual market structure is unsettled.

PSD3 and the Payment Services Regulation. A provisional agreement exists and the text cleared committee on 5 May 2026. The final instruments were not adopted or in force on the evidence date.

FIDA. The proposal remained at awaiting Parliament’s first reading position, with no recorded key event since December 2024.

Open finance sequencing. The FCA roadmap identifies priorities and stages. It does not guarantee that every proposed use case will proceed or follow the indicative timetable.

Cross sector smart data interoperability. The UK strategy describes a long term direction. Actual interoperability depends on scheme design, standards, governance, identity, liability and commercial arrangements.

Consumer behaviour. Growth in connections or payments does not prove customers will prefer any particular new product, consent model or payment method.

One observation about how organisations actually monitor this, offered as market reading rather than evidence. In current conversations, almost nobody is tracking this category proactively. The trigger is external without exception: a competitor visibly does something, or a vendor puts a comparison report in front of them. The prevailing assumption is that being large, and having invested in the relevant capability at some point in the past, will be sufficient. In adjacent areas that assumption has not held, and I would not expect it to hold here either. Assign the monitoring below to named owners now, while it is cheap.

2026 monitoring checklist

Monitor	Evidence to look for	Internal owner
UK payment services legislation	Bill, enacted text, commencement provisions, official guidance	Legal and regulatory affairs
HM Treasury consultation	Response to consultation after it closes on 6 October 2026	Compliance and public affairs
FCA long term framework consultation	Consultation paper, proposed rules, cost benefit analysis, implementation date	Compliance and product
UKPI service availability	Participating banks, providers, sectors, scheme rules, live customer journeys	Payments and partnerships
Access fee model	Final pricing methodology, governance, Phase 2 position, changes to regulator stance	Finance, procurement, competition counsel
Commercial VRP performance	Completion, failure, cancellation, fraud, refunds, support contacts, not promotional claims	Product analytics
PSD3 procedure	Council first reading position, Parliament decision, final Official Journal text	EU legal and compliance
Payment Services Regulation	Final text, application date, delegated measures, EBA work	Payments compliance
FIDA procedure	Parliament position, negotiations, final scope	Data strategy and EU legal
FCA open finance roadmap	Discussion papers, experiments, selected use cases, formal consultations	Strategy and product
Smart data schemes	Scheme specific regulations, standards, approved participants	Data governance
Open Banking Standard	New versions, implementation dates, breaking changes	Engineering and providers
FAPI adoption	Jurisdictional adoption, certification, provider migration plans	Security architecture
Adoption metrics	Defined population, unique users, active connections, volumes, periods, as at dates	Analytics
Customer outcomes	Comprehension, complaints, disconnections, errors, harm indicators	Customer experience
Marketing reuse	New purpose, lawful basis, PECR, transparency, platform transfer assessment	Privacy and marketing

Frequently asked questions

Are PSD3 and the EU Payment Services Regulation already in force?

No. A provisional political agreement was announced in November 2025 and the agreed text was approved in committee on 5 May 2026, but both European Parliament procedure files still recorded the status as awaiting the Council’s first reading position on 28 July 2026.

Has UK commercial VRP fully launched across the market?

No. The June 2026 UKPI announcement was an important commercial scheme development. It is not universal bank, provider, merchant or sector availability, and the regulators’ pricing position covers only Phase 1 and Wave 1, in a limited set of lower risk use cases.

Do the UK adoption figures represent unique users?

No. Open Banking Limited reported active user connections, and one person or business can hold more than one connection. The published report is also internally inconsistent, giving both over 18 million and over 19 million in the same document, with no as at date for either.

Does a VRP mandate permit marketing?

No. A payment mandate defines permission to initiate payments within agreed parameters. Marketing communications and reuse of personal data require separate assessment.

Has open finance become law in the UK?

No. The UK has enabling smart data legislation and an FCA open finance roadmap. That is not an operational open finance scheme. Scheme specific rules, standards and implementation are still required.

Is FIDA the same as PSD3?

No. PSD3 and the proposed Payment Services Regulation concern the EU payment services framework. FIDA is a separate proposal concerning financial data access beyond payment accounts, and it is at an earlier stage.

Does higher open banking payment volume prove better conversion?

No. Volume measures usage. Conversion impact requires merchant and journey specific evidence with an appropriate comparison.

Conclusion

The most important development of 2026 is not an adoption figure. It is the shift towards a more commercial and institutionally mature phase of open banking.

In the UK, commercial VRPs, access fee arrangements, payment services reform, open finance planning and smart data policy are advancing together and at different legal and operational stages. In the European Union, PSD3 and the proposed Payment Services Regulation have advanced politically without becoming final law, while FIDA has not moved on the record since December 2024.

Monitor the developments that change what service can actually be offered, which provider may offer it, what data or payment authority is required, how the customer understands and controls it, what it costs, and how success and harm are measured.

For the durable principles behind those decisions, return to the opportunities and limits of open banking.

Update log

28 July 2026: Full rewrite. Added UKPI, the access fee prioritisation statement and its Phase 1 and Wave 1 scope, the Payments Forward Plan, the Smart Data Strategy, the FCA open finance roadmap, the HM Treasury consultation and its closing date, current PSD3, PSR and FIDA procedural status including latest recorded events, Standard 4.0.1 including the cryptoassets transaction risk indicator, and July 2026 adoption evidence with its internal inconsistency noted. Removed unsupported company metrics and undated forecasts.

2025 edition: Previous version of the article. Superseded by this evidence dated rewrite.

References

1. Open banking takes next step forward with launch of UK Payments Initiative scheme. Financial Conduct Authority. Regulatory statement, 2 June 2026. Source type: regulator, independent public authority. Limitation: UKPI is an industry led scheme; the statement is not evidence of market wide availability, and the promised long term framework consultation is subject to expected legislation. Interest: none.

2. Regulators give clarity in relation to open banking pricing models. Financial Conduct Authority and Payment Systems Regulator. Joint regulatory announcement, 20 January 2026. Source type: regulator, independent public authorities. Limitation: this page is the announcement wrapper; the substantive position is in the prioritisation statement at reference 3. Interest: none.

3. Prioritisation Statement Commercial Variable Recurring Payments, UKPI scheme (Phase 1/Wave 1). Financial Conduct Authority and Payment Systems Regulator. Joint prioritisation statement, published 20 January 2026. Source type: regulator, independent public authorities. Limitation: an enforcement prioritisation position, not a finding of competition law compliance. It applies only to Phase 1 and Wave 1 and to lower risk use cases, may be reconsidered, and runs until the long term framework is in place or July 2027, whichever is earlier. Note: the published URL contains the misspelling “commerical” and resolves correctly as written. Interest: none.

4. Payments Forward Plan. HM Treasury and the Payments Vision Delivery Committee. Policy paper, published 26 February 2026. Source type: government policy roadmap, not legislation. Limitation: the document describes a regulatory roadmap over the next three years, tabled across 2026, 2027 and 2028; individual programmes within it run to different timetables. Interest: none.

5. Smart Data Strategy, published as “Smart Data 2035: The UK’s Smart Data Strategy”. Department for Business and Trade. Policy paper, 26 March 2026. ISBN 978-1-5286-6348-9; E03572600; CP 1551. Source type: government strategy under enabling legislation. Limitation: enabling powers do not make any individual sectoral scheme designed, adopted or operational. Interest: none.

6. Open finance roadmap: our vision for a smart data future. Financial Conduct Authority. Corporate policy roadmap, published 14 April 2026. Source type: regulator, independent public authority. Limitation: a roadmap of policy intentions, not binding rules; the 2028 to 2030 scaling phase is indicative. Interest: none.

7. Modernising Payment Services Regulation. HM Treasury. Open consultation, published 14 July 2026; closing 6 October 2026. Source type: government consultation. Limitation: proposed policy only; the contents are not rules and may not survive the consultation. Interest: none.

8. Payment services: Council and Parliament agree to step up the fight against fraud and increase transparency. Council of the European Union. Press release, 27 November 2025. Source type: official institutional communication. Limitation: evidence of a provisional political agreement only; it is not adopted law and the final texts may differ. Interest: none.

9. Payment services and electronic money services in the Internal Market. European Parliament Legislative Observatory. Legislative procedure file 2023/0209(COD). Status accessed 28 July 2026: awaiting the Council’s first reading position; most recent key event 5 May 2026. Source type: official legislative status record. Limitation: a live procedural record that changes without notice; re-check before relying on the status. Interest: none.

10. Payment services in the internal market. European Parliament Legislative Observatory. Legislative procedure file 2023/0210(COD). Status accessed 28 July 2026: awaiting the Council’s first reading position; most recent key event 5 May 2026. Source type: official legislative status record. Limitation: a live procedural record that changes without notice; re-check before relying on the status. Interest: none.

11. OBL publishes Open Banking Standard v4.0.1. Open Banking Limited. Standards announcement, 1 April 2026. Source type: official UK implementation standard, published by an interested industry body. Limitation: publication of a standard version is not evidence that providers have implemented it. Interest: none.

12. Open Banking Payments Fraud Monitor, June 2026 Edition. Open Banking Limited. Industry monitoring report and summary, published 8 July 2026. Source type: primary industry operational evidence, published by an interested party rather than an independent researcher. Limitation: the report states “over 18 million user connections” in its introduction and “over 19 million active user connections” on its final page and in the summary, and gives no as at date for either figure or for the monthly payments figure. Its fraud analysis draws on account providers representing more than 60% of open banking payment volumes for the period March 2024 to March 2026; that period does not apply to the connection or payment figures. Interest: none.

13. Framework for financial data access. European Commission, Directorate-General for Financial Stability, Financial Services and Capital Markets Union. Official proposal explainer; legislative proposal recorded 28 June 2023. Source type: official policy explanation of a legislative proposal. Limitation: describes a proposal, not enacted law; the Commission is an interested party in its own proposal. Interest: none.

14. Framework for Financial Data Access. European Parliament Legislative Observatory. Legislative procedure file 2023/0205(COD). Status accessed 28 July 2026: awaiting Parliament’s position at first reading; most recent key event 18 December 2024. Source type: official legislative status record. Limitation: a live procedural record that changes without notice; re-check before relying on the status. Interest: none.

15. Variable recurring payments. Open Banking Limited. Official UK implementation explainer. No date displayed; accessed 28 July 2026. Source type: implementation body explanation, interested party. Limitation: undated, and explanatory rather than normative; the scheme rulebook governs commercial VRP obligations. Interest: none.

16. Open banking: a year of progress. Financial Conduct Authority. Regulatory news article. First published 16 December 2025; updated 12 February 2026. Source type: regulator citing industry adoption figures rather than its own measurement. Limitation: the FCA does not state which periods the 53% comparison covers, attributes the figure to latest industry figures, and gives the user count as “more than 16 million users” without defining the unit. Interest: none.

17. FAPI 2.0 Security Profile. Fett, D., Tonge, D. and Heenan, J.; OpenID Foundation. Final standards track specification. Published 22 February 2025; status Final. Source type: independent technical standard, standards body evidence. Limitation: final publication is not evidence of adoption by any jurisdiction or provider; UK implementations may run an earlier FAPI profile. Interest: none.

About the author

İlkem Erul spent around a decade on the account side of an enterprise personalisation platform, working with retail, luxury, cosmetics, automotive and consumer electronics brands across Türkiye, France and the wider European market, latterly leading customer success for Europe and the UK. He now works on purchase data and consumer marketing infrastructure.

Disclosure. I run a company built on purchase data. That gives me a commercial interest in the broader direction this article describes, and in arguments that favour purchase records over behavioural signals. This page is intended as a status roundup rather than an argument for either, and the market observations marked as my own reading should be treated as opinion rather than published evidence.

Client examples are described without naming the organisations involved, and observations drawn from that work are reported as single accounts rather than benchmarks. Nothing here is legal advice; open banking deployments require specialist legal, compliance and regulated service review.