Article

The Instructions Are There. Now We Build the Future.

20 October 2026

Open Banking has proved that trusted data sharing works; now we must put in place the long-term framework that allows that trust to power the next generation of financial services, Smart Data and AI-enabled innovation. 

Keynote speech by Marion King at Open Banking Expo 2026

Introduction

The week of Open Banking Expo always has a back-to-school feel about it. 

It is around this time of year that many of you may have made the journey to drop off a young person at university.  

You arrive with a carload of bedding that will be changed approximately twice a year,  

A bundle of electronics, chargers and cables that are probably a fire risk,  

clothes that may soon become a bio-hazard …

and an implausible amount of flatpack furniture to squeeze into a tiny floorspace. 

After spending several hours assembling a flatpack desk,  

you realise you have several screws left over. 

As you’re busy pondering whether your offspring is more likely to be found buried under a mound of dirty laundry… 

or buried under a collapsed Ikea desk, they suddenly opine: 

‘Mum, can you take this home? I don’t really have space for a desk.’ 

You spend years raising them with deceptively simple instructions, balancing competing demands,  

and then you reach the point of unleashing them, ready for their next chapter. 

This is where we are with Open Banking… 

which has involved some familiar lessons:  

build carefully,  

adapt constantly  

and never assume the instructions contain every answer. 

From Foundations to Growth

I have been involved in the financial services industry for four decades,  24 years of those in payments, so there is not much I haven’t seen in terms of technology, use cases or regulatory conundrums. 

Yet working at OBL has often felt like being part of a start-up. 

Rather than creating a single product or service… 

we have channelled that entrepreneurial energy into building infrastructure that enables many of the innovations being created by people in this room. 

The work has involved constant learning,  

balancing different demands and, of course,  

defining the standards. 

Now, that infrastructure must evolve for the next generation of innovators. 

Better credit decisions,  

Faster account to account payments 

Easier ways to pay your bills… 

Not quite taking away all of the friction but at least a lot of the admin and overheads… 

Now we must ensure those foundations can support the next generation of innovation. 

Long Term Regulatory Framework

With more than 19 million unique users, Open Banking is no longer an experiment. It is part of everyday life… 

helping people make the most of their finances,  

small businesses make better decisions,  

and account-to-account payments move more quickly and easily. 

That scale matters. But success is not measured by the number of APIs we have built;  

it is measured by what they allow consumers and businesses to do. 

The Long-Term Regulatory Framework – the LTRF – may sound like something designed to keep a room of lawyers occupied for several years. 

In plain English, it is the rulebook that will take Open Banking from a competition remedy created for only some banks at one moment in time,  

and turn it into permanent national infrastructure that can serve the whole market. 

Our experience offers some clear lessons…  

as we look to the future framework, and the role the standard setter can play in that.  

The Standard must remain living and dynamic.  

Participation should be holistic and proportionate.  

Funding should be sustainable, transparent and shared fairly among those who benefit.  

The current arrangements proved the concept,  

but they were not designed to carry every future service, provider or technology.  

A long-term framework must preserve the ongoing consistency of a common Standard while giving it room to respond as customer expectations, business models and threats change. 

That is how regulation can support investment rather than simply supervise it. 

That requires a clear division of roles.  

As I see it, legislation should establish the enduring rights, responsibilities and protections:  

who can participate, 

on what basis,  

and with what obligations. 

The FCA should set and supervise the outcomes the ecosystem must achieve.  

The Future Entity should translate those outcomes into detailed rules, monitor performance and convene the industry to solve problems and make decisions. 

Commercial schemes – and I believe there will be many – should build on the common Standard to deliver enhanced, competitive services. 

This allocation matters.  

In this way, the Future Entity can be more than a custodian of a technical manual… 

with the Standard operating as one integrated framework, with broad and proportionate participation… 

This allows innovators to build once and reach the whole market,  

while giving customers a consistent experience wherever they bank.  

Consistency is what turns successful innovation into trusted infrastructure; and competition can flourish above that common base. 

Funding is part of that same equation.  

It must be transparent, proportionate and sustainable, with contributions shared across those who benefit and an appropriate voice for participants in shaping its future.  

Without that certainty, firms will hesitate to commit the people, capital and technology needed for the next wave of services. 

The market also needs practical mechanisms to resolve issues before they become regulatory cases.  

The framework needs capable day-to-day stewardship, 

clear escalation routes  

and, ultimately, enough flexibility to adapt before emerging issues become barriers to innovation or sources of harm.  

We can think about infrastructure like a building. We want solid foundations; but not every detail should be set in stone. 

We do not want to pour the wiring, plumbing and every future appliance into concrete. 

Equally, if everything is left open, firms and customers will not know where they stand. 

The LTRF must strike this balance. 

It must also arrive at pace.  

Firms from across the industry have come together to design the FE, and OBL is preparing for Transition 

As Trustee and chair, it is my top priority to prepare for a smooth and safe transition 

to a future model that supports the ongoing delivery of Open Banking but which could – industry, regulators and participants willing – go much further. 

We are working alongside HMT and the FCA as they develop the LTRF… 

With close alignment and communication, we can collectively move this work forward in parallel, and reclaim the UK’s advantage. 

It must be transparent, proportionate and sustainable, with contributions shared across those who benefit and an appropriate voice for participants in shaping its future.  

Improving Open Banking

In dealing with the future, we must also focus on the present – ensuring we are always improving. 

In the space of several weeks, consultations closed on Smart Data,  

HMT’s modernisation of payments regulation,  

and Retail Payments Infrastructure. So much for a quiet summer. 

I know many here today have also been involved putting their organisations’ submissions forward…. 

These reforms are not just about setting the foundations for more innovation in Open Banking… 

But about exploring the interaction between payment rails and Open Banking and how these can fit with Smart Data schemes that are expanding into other sectors. 

In practice, account-to-account payments must work reliably from beginning to end.  

If a customer has paid, a business should not have to guess whether the money is coming.  

Providers need a clear status: completed, pending or failed… 

so businesses know where a payment stands without having to investigate.  

Across the ecosystem, we need consistent functionality, useful information when something goes wrong and authentication that is as smooth as security allows. 

We also need the framework to recognise how people increasingly choose to pay.  

Variable Recurring Payments will take Open Banking into more digital use cases – that is in sight 

But we will also need wallet integration – a smooth point of sale experience – to make open banking a convenient, dependable everyday choice. 

The larger goal is an experience that combines reach, resilience and trust. The operational detail matters, because it determines how far and how fast Open Banking will go. 

Building the Next Generation

The work of the Retail Payments Infrastructure Board is closely connected to the next phase of Open Banking.  

The National Payments Vision identified Open Banking as the key enabler of account-to-account payments.  

The strategic opportunity is to ensure that the next generation of retail payments infrastructure is flexible, scalable and with functionality capable of supporting innovative products and services. 

This is not a separate payments conversation happening alongside Open Banking.  

It is a chance to align shared infrastructure with a market capability that already exists …and to make both stronger.  

The prize is an account-to-account proposition with the openness to support competition, the resilience to inspire confidence  

and the adaptability to serve uses we have not yet imagined. 

That requires the right capabilities to be designed in from the outset: certainty about payment outcomes… 

compatibility with the ways people choose to pay  

and the ability to share information that helps the market prevent fraud and resolve problems.  

These are not isolated technical features; they are the conditions for trust and scale. 

The goal is the advancement of safe, reliable, competitive account to account payments. 

Reform to the underlying rails can absolutely change the game 

But for the product that already delivers account-to-account payments – open banking – it is more an ongoing evolution.  

We do not need to start again – we need to finish the job: strengthen the foundations, unlock more capability and make the experience reliable at scale. 

Trust must grow with adoption.  

Open Finance can extend the same trusted approach to savings, investments, pensions, mortgages and insurance.  

AI and the Future

As artificial intelligence begins not only to advise us but to act for us,  

the human questions become more important:  

who authorised it, 

what data can it see,  

what is it allowed to do,  

can we trace its decisions… 

and can we stop it? 

Everyone is talking about the power of AI. But powerful technology on its own is not enough.  

The real question is whether these new services can operate using information that is trusted, verified and shared with permission. 

That will require more than clever technology.  

Agents will need permissions that are understandable, bounded and revocable.  

Firms will need to know where responsibility sits when an automated action crosses several services.  

Customers will need confidence that convenience has not come at the cost of visibility or control.  

Open Banking has spent the last decade solving exactly those problems.  

This is why standards, frameworks and infrastructure must remain flexible,  

adapting to future requirements and technology  

Enabling the benefits of innovation… while people remain in control. 

Conclusion

This year we have taken great strides towards the LTRF,  

Genuine progress, that has been long-awaited for many of us, has been made 

Because developing the LTRF is not an administrative tidying-up exercise.  

It is the bridge between a successful first chapter and a much larger market which will evolve as data gets more accurate, bigger and smarter and 

as technology moves from assisting to acting on our behalf, in our interests. 

Done well, it will give customers consistent rights,  

innovators dependable access,  

established firms clear obligations  

and regulators the tools to protect the system without freezing it in time. 

Done slowly or narrowly, it will preserve today’s gaps and invite investment to go elsewhere.  

The opportunity is also there for the taking with Open Finance.  

The UK has already done much of the hard work:  

common standards,  

secure consent,  

directories,  

certificates  

and a culture of collaboration between data holders and third parties.  

We should reuse those foundations rather than commission a new set of flatpacks for every part of financial services. 

The UK’s lead was built through a rare combination of regulatory ambition,  

industry expertise and common infrastructure.  

Keeping that lead does not require us to invent everything again.  

It requires us to finish the job. 

To unlock the full potential of Open Banking data 

To give Open Banking payments the tools to be truly competitive. 

The first chapter of Open Banking proved that shared standards could open a market.  

And what next? There is no final chapter of Open Banking. 

It is, if you like, a never-ending story that continues to evolve.  

The task now is to make that market reliable in everyday life,  

inclusive in its reach  

and ready for whatever comes next. 

The instructions are there.  

The foundations are in place.  

Now it is up to all of us to assemble the future. 

Ends.