Policy article

GUEST ARTICLE: What should future smart data schemes learn from Open Banking?

Today, the Data (Use and Access) Bill received Royal Assent, completing its passing through Parliament and becoming law, firing the starting gun for smart data schemes to roll out across businesses and communities. Smart data schemes share consumers’ data between organisations: this can create a lot of benefits, but also has risks. This is the first in a new blog series exploring smart data in society, the economy, and digital technology. We asked: what lessons do we need to learn from Open Banking - the UK’s first operational smart data initiative? We spoke to three experts to find out
6 min read
Caroline ClaytonSenior Policy Adviser

Smart data gives consumers the ability to share their data between businesses and other organisations, enabling new uses of data in ways that benefit consumers, society, and economy - potentially adding £27.8bn to UK GDP. Today, the UK’s Data (Use and Access) Bill became law - a significant milestone that fires the starting gun for rolling out smart data schemes across the country. 

Therefore, it is essential we learn from the only scheme that’s already live, Open Banking.  Since 2018, the UK’s biggest banks have been required to open up their data to rivals, other businesses, and charities. 

As Which? have explained, Open Banking allows consumers to manage multiple financial accounts and household bills through a single digital platform, with the option of allowing apps to ‘plug in’ and offer more personalised and intuitive services. Open Banking also enables innovations such as apps that can help consumers avoid charges or boost their savings by automatically moving money between accounts. As of March 2025, there were 13.3 million active Open Banking users, including both individuals and small businesses, demonstrating its widespread success. A world-first and an innovative initiative, Open Banking has demonstrated practical examples of what is possible when consumers share their data.

However, it is critical that smart data schemes are rolled out in the right way. Our recent policy paper ‘Building Consumer Trust in Smart Data’ identified risks of consumer harm, ranging from poor quality products and services, lack of meaningful consent, risk to consumer safety and the exploitation of vulnerable consumers. Our research also found that such failings could lead to consumer distrust and disengagement, undermining the potential for all future smart data schemes.

We asked experts from Open Banking and from the UK government’s Smart Data Council ‘What learnings should future smart data schemes take from Open Banking?’. 

Clarity and value

Faith Reynolds (Strategic Advisor & NED)

“Firstly, keep focusing on the value for people, communities and small businesses. A lot of the implementation of Open Banking was the heavy lifting of technological build - something which Smart Data can lean on. It’s easy to lose sight of what the ‘infrastructure’ or plumbing might deliver downstream in terms of innovative products and services. Undertaking consumer research, engaging consumer representatives and actively seeking challenges was crucial for Open Banking and will be for Smart Data initiatives too. We need to be clear about what all the technology and trust frameworks will actually deliver by way of practical, money-saving, value-enhancing products and services. We need to keep asking - how will this make our lives better? 

Secondly, public information: data sharing comes in all shapes and sizes, so what makes Smart Data different? Some data is permissioned sharing, other data is shared via legitimate interests or a tickbox. Data markets are opaque and lack transparency. Consumers offer up consent but have no record of where their data is, who is using it or what the implications of sharing it mean for them. Open Banking proved the value of giving people tools to view, manage and revoke their consent. We need the same for Smart Data but this time around we need better public information campaigns so people know what their rights are, how they can share their data safely and where to go when something goes wrong.

Which leads me to a final key learning - governance and accountability is key. The Open Banking Standard levelled the playing field by setting the rules of the game for all participants - in doing so it made sure that there was provision of high levels of security and consistency for consumers.”

Infrastructure for success

Marie Walker (Open Futurist), Raidiam: 

“Future Smart Data schemes can learn invaluable lessons from Open Banking's global journey, particularly in delivering meaningful benefits to consumers. Success depends on three critical pillars that determine consumer adoption.

Value exchange remains paramount - consumers must clearly understand tangible benefits from sharing personal data. Open Banking's successful implementations demonstrate measurable consumer value, from time savings through automated financial management to cost reductions via improved comparison services. Future Smart Data schemes must articulate specific, quantifiable benefits that outweigh privacy concerns.

Trust forms the bedrock of adoption. Open Banking reveals that robust security frameworks combining multi-factor authentication, real-time monitoring, and comprehensive data encryption are essential. Equally crucial is transparency about data usage, clear consent management, and straightforward revocation mechanisms. Consumers need confidence their data will be protected and used only for agreed purposes, with clear accountability when problems arise.

User experience determines success. Even secure and beneficial schemes fail if they create friction rather than convenience. Open Banking's gradual adoption highlights how complex interfaces and poor experiences stifle innovation. Future Smart Data initiatives must prioritize intuitive design, seamless integration, and experiences that genuinely improve upon current alternatives.”

Certainty and ambition

Emily Rayment (Head of Public Affairs), Open Banking:

“The opportunity of Smart Data as an enabler of growth, innovation and competition is huge - which is why it's important that we leverage the learnings of the UK's journey so far. Open Banking - the UK’s first Smart Data Scheme and Standard - provides a proven model for how to expand into new Smart Data sectors. Our experience has shown that to deliver success at pace, the following are required: 

  • A clear and ambitious roadmap, prioritised according to the potential opportunity for consumers, businesses and society as a whole 
  • A centralised coordinating entity - working in close partnership with industry - dedicated to driving forward implementation 
  • A single Standard, to provide the ubiquity needed to enable a dynamic and innovative ecosystem.  

Building on these, a key lesson from Open Banking has been the importance of planning for the development of operating rules and an equitable funding model from the start. These elements are crucial to fully operationalise Smart Data schemes and realise their full benefits - and getting them right from the start is critical for success.

Looking to the opportunity itself, a key benefit of a Smart Data Economy is the ability to enable multi-sector use cases - meaning use cases that leverage data from multiple sectors. Interoperability will therefore be critical, and sectoral frameworks should not be developed in silos. Instead, existing proven tools should be leveraged rather than reinventing them for each sector. 

Finally, adoption of Smart Data will be underpinned by trust and consent. Open Banking has demonstrated that consent-driven models work, and consumers must trust that their data is secure and that they have full control over how it is used. Achieving widespread adoption also relies on a clear legal foundation and regulatory certainty, combined with extensive collaboration between the government, regulators and the ecosystem to drive forward new and innovative solutions.”

Consumer empowerment

The key lessons from Open Banking are clear: ensure consumer consent is meaningful and manageable, focus on delivering real value for consumers, and build consumer trust through strong security and transparency. However, as smart data schemes roll out more widely across the UK, the stakes are higher than ever in earning consumer trust. 

Which? has previously highlighted two key shortcomings of Open Banking that future smart data schemes must address. Firstly, consumer representation in governance of Open Banking has been inadequate, with limited consumer influence over decision-making, leading to a lack of consumer protections. Which? have argued that unclear payment protections for consumers in Open Banking may have slowed down their adoption of it; and our smart data trust framework includes a requirement for robust redress mechanisms as a proactive measure to build consumer trust by assuring consumers that they can reach a resolution in the event of something going wrong. Secondly, there has been no robust evaluation of consumer outcomes: while adoption rates are known, there is little insight into impacts on financial inclusion, ethical concerns, or protection gaps. Future smart data schemes must embed strong consumer voices in governance and define success through clear, outcome-focused metrics that reflect consumer benefits, not just usage. This is why our smart data trust framework also includes vital monitoring requirements, to continually assess the consumer journey and consumer outcomes throughout the product or service, including consumer satisfaction and the security of customer data flows. 

Explore Which?'s trust framework to learn more on how to put consumer trust at the heart of future smart data schemes. And follow our new series about smart data across society, economy and digital technologies.