Open banking marks eight years in the UK this year, dating back to a January 2018 launch mandated by the Competition and Markets Authority following its 2016 investigation into the retail banking sector. The order forced the nine largest current account providers — Allied Irish Banks, Bank of Ireland, Barclays, Danske Bank, HSBC, Lloyds Banking Group, Nationwide, NatWest Group and Santander, collectively known as the CMA9 — to open their payment account data to authorised third parties through standardised APIs. What began as a narrow remedy for weak competition in current accounts has since become infrastructure that a large share of UK current account holders touch without necessarily knowing its name.
From CMA Order to Everyday Infrastructure
The body originally responsible for building and policing the technical standard, the Open Banking Implementation Entity, was funded directly by the CMA9 and wound down its original mandate once the standard matured. Its successor, Open Banking Limited, now runs the API standard and the directory of regulated providers, while the Financial Conduct Authority continues to authorise and supervise the account information and payment initiation firms — companies such as TrueLayer, Yapily, Moneyhub and Plaid — that sit between banks and the apps consumers actually use. None of this required new legislation beyond the original CMA order and the UK's onshored version of the second Payment Services Directive; it was, and remains, a regulatory remedy rather than a voluntary industry initiative.
That distinction matters for anyone trying to understand why open banking looks the way it does in 2026. Because the CMA9 were compelled rather than persuaded, the pace of investment has tracked regulatory deadlines more closely than commercial appetite, and smaller banks and building societies outside the original nine have adopted the standard on a slower, voluntary timetable. Some regional providers still route open banking connections through screen-scraping fallbacks rather than the full API standard, a gap that account aggregation apps quietly work around rather than advertise.
Millions of Users, Uneven Awareness
Open Banking Limited's own published figures put active users of open banking-enabled products at more than 11 million UK consumers and small businesses, up from a few hundred thousand in the standard's first year. Most of that growth sits in account aggregation — budgeting apps such as Emma and Snoop, and challenger banks including Monzo and Starling, that pull balances and transactions from multiple providers into one screen — and in payment initiation, where retailers and billers let customers pay directly from their bank account instead of by card.
Awareness of the term itself has not kept pace with the usage figures. Surveys commissioned by UK Finance and the FCA over the past several years have repeatedly found that a majority of people who use an open banking-enabled app do not recognise "open banking" as the mechanism behind it; they know their banking app, their budgeting app or their loan application, not the API standard underneath. That gap is arguably the clearest measure of the scheme's maturity: infrastructure that works well enough to become invisible.
The Regulatory Handover Still Isn't Finished
The Joint Regulatory Oversight Committee, made up of the FCA and the Payment Systems Regulator with HM Treasury and the CMA as observers, published a roadmap for open banking's next phase in April 2023 and recommended establishing an independent "future entity" to take over governance from Open Banking Limited on a permanent, industry-funded footing. That handover has moved more slowly than the roadmap's original timetable implied, and Open Banking Limited continues to operate the standard in the interim under its existing CMA-linked funding arrangement.
Parliament gave the wider agenda a legislative foundation with the Data (Use and Access) Act, which received royal assent in June 2025. The Act creates Smart Data powers that let ministers mandate open-banking-style data sharing in other sectors — energy, telecoms and pensions have all been floated as candidates — without needing sector-specific primary legislation each time. Open banking, in other words, has stopped being a one-off banking remedy and become the template the government reaches for whenever it wants a market to share customer data through regulated intermediaries.
What It Means at the Till and in the Loan Application
The most tangible change for ordinary account holders sits in lending. Mortgage brokers and short-term lenders increasingly ask applicants to connect a bank account through open banking rather than upload PDF statements, because the API feed is faster to process and harder to alter than a scanned document. Specialist lenders serving self-employed and gig-economy borrowers, a group that struggled under traditional affordability checks, have leaned on open banking income verification particularly hard since it gives underwriters transaction-level detail rather than a payslip snapshot.
On the payments side, sweeping variable recurring payments — the CMA-mandated ability to move money automatically between a customer's own accounts, used mainly for savings pots and overdraft top-ups — have been live since 2022 and remain the most established VRP use case. Retail take-up of pay-by-bank checkout options has grown more unevenly, constrained less by the technology than by the absence of the chargeback protections consumers expect from card payments, a gap that continues to shape how cautiously retailers promote the option at checkout.
Fraud Protection Caught Up Later Than the Technology
Trust in moving money through a third-party app took longer to build than the technology itself, largely because the reimbursement rules for authorised push payment fraud lagged behind open banking's rollout by several years. The Payment Systems Regulator's mandatory reimbursement requirement for APP scams over Faster Payments took effect in October 2024, splitting liability between sending and receiving banks and giving open banking payment initiation providers a clearer, shared framework for handling disputed transactions rather than leaving the customer to argue with their bank alone. Consumer body Which? had campaigned for exactly this kind of liability split for several years before it arrived, arguing that open banking payments would stay a minority option at checkout for as long as the protections trailed behind cards.
Business Banking Has Quietly Caught Up
Small business accounts were a secondary consideration when the CMA9 order was drafted in 2016, but accounting software providers such as Xero, QuickBooks and FreeAgent have since built open banking feeds into daily bookkeeping for hundreds of thousands of UK small businesses, replacing manual bank statement imports with same-day transaction matching. Invoice financing and revenue-based lenders serving small firms — a segment banks have historically underserved because thin credit files make traditional underwriting expensive — now treat a connected business current account as close to a baseline requirement for an application, rather than a nice-to-have alternative to three years of filed accounts.
Eight years after the CMA9 were first ordered to open their systems, the FCA and PSR are still working through how open banking's governance, funding and consumer protections should look once the transitional arrangements finally end.