This research examines different models of open finance infrastructure supporting secure, trusted and scalable data sharing in the UK.
As part of the Smart Data Accelerator, we commissioned Saïd Business School, University of Oxford, working with Raidiam Services Limited as technical partner, to develop and assess potential infrastructure models for open finance in the UK.
The research provides reference architectures that can be tested to build evidence supporting future decisions.
Open finance is more than an expansion of open banking into additional financial products. As data sharing extends across a wider range of products, firms and other smart data sectors, it creates a broader challenge for infrastructure design. As AI-enabled services become more capable of acting on behalf of consumers and firms, infrastructure needs to support new approaches for verification, delegation and accountability.
The research considers the practical conditions needed to make financial data sharing usable, trustworthy and scalable. These include:
- common technical standards
- secure application programming interfaces (APIs)
- reliable accreditation and identity arrangements
- effective consent and authorisation
- operational monitoring
- the ability to suspend or revoke access when necessary
What the research covers
The research:
- Explains why open finance should be considered as an infrastructure design challenge.
- Identifies common technical and assurance foundations that would be required across different infrastructure models.
- Examines 3 infrastructure model families: centralised, decentralised or federated, and hybrid.
- Considers international examples from Australia, Brazil, the European Union and the United Arab Emirates.
- Explores how infrastructure may need to adapt to emerging technologies, including agentic AI and developments in quantum computing.
The infrastructure models
These models are reference architectures rather than recommendations.
Our research suggests that the central question for the UK is not whether the future system should be entirely centralised or decentralised, but which infrastructure functions require common coordination and which should remain distributed.
Centralised
A centralised model concentrates key trust, assurance and coordination functions within a central institution or set of shared services.
This can support consistency, clearer accountability and rapid ecosystem-wide action, but may also create concentration risk, operational dependency and reduced flexibility.
Decentralised or federated
A decentralised or federated model distributes responsibilities across authorities, standards bodies and individual participants.
This can provide flexibility and support sector-specific approaches, but may lead to fragmented implementation, inconsistent user journeys and higher integration costs if standards are not sufficiently coordinated.
Hybrid
A hybrid model combines common coordination of functions such as:
- accreditation
- participant status
- trust information
- monitoring and revocation with distributed data custody
- APIs
- customer journeys
The research uses this model to explore which functions may benefit from common control and which should remain distributed to preserve proportionality, flexibility and innovation.
Next steps
The research provides the Smart Data Accelerator with a structured basis to move from conceptual models towards practical testing.
Future work can examine how the different architectures perform against observable measures, including participant onboarding, trust portability, consent and permissions, interoperability, monitoring, incident response, and access revocation.
The findings will contribute to our broader work on open finance and smart data. They do not represent a final infrastructure decision or FCA policy position.
Authors
- Josh Lowe, associate, Smart Data Accelerator, FCA Innovation
- Ekaterina Borisova, technical specialist, Smart Data Accelerator, FCA Innovation
Acknowledgements
We would like to thank Kyeyoung Shin, Pinar Ozcan, and Shuchita Prakash of Saïd Business School, University of Oxford, and John Heaton-Armstrong of Raidiam Services Limited, for their work on the commissioned research.