Events

From Mandate to Momentum – Cocreating the Next Chapter of Open Banking 

29 October 2025

OBL CEO Henk Van Hulle delivered a keynote at the Open Banking Expo 2025 on Regulator Day, focusing on how the UK’s approach to open banking has evolved from a regulatory mandate to a model of co-creation and industry leadership.

Thank you for the invitation – and for the way today has been convened. A closed door conversation among regulators and industry is a privilege, and a responsibility – the kind of setting where we can be candid about what’s working, honest about where we need to improve, and clear about what comes next.  

Today I want to focus on one central theme – how the UK’s approach to Open Banking has evolved from a regulatory mandate into a model of cocreation and industry leadership.  

This is not a story about technology for its own sake – it is about partnership, shared accountability and enabling innovation at scale. The key message is simple: when government sets direction, regulators focus on outcomes, and industry leads delivery, we create a framework that drives adoption, unlocks new markets, and delivers better results for consumers and businesses alike.  

The UK Journey  

So how did we get here? The UK’s journey began as a targeted competition remedy, but the deeper lesson is about roles. Government set the direction and the guardrails, regulators concentrated on outcomes, and the market had the space – and the incentive – to step up and deliver.  

That enabling approach is the lens for everything that follows today – the signals of progress, the pressure points we must address, and the practical commitments we can make together. 

Why does this shift to cocreation matter? Because complex ecosystems don’t thrive on command and control. When regulators have to prescribe every detail, innovation slows and compliance becomes a ceiling rather than a foundation.  

Cocreation flips that dynamic – it enables regulators to facilitate safety, security and innovation. It aligns incentives, brings those closest to customers into the design process, and creates solutions that work in the real world.  

It means regulators can focus on outcomes – reliability, fairness, resilience – while industry innovates on delivery. That combination produces better adoption, faster iteration, and stronger consumer trust. 

When the regulation that started Open Banking as we know it in the UK – the CMA Order – was introduced, it was a precise intervention to correct competition failures in retail banking. The Open Banking Implementation Entity then established the foundations – standards, trust frameworks, a directory – so that firms could build at pace on common rails.  

OBL’s role 

Over time, the baton passed to Open Banking Limited, maintaining those foundations and convening the ecosystem around improvements, performance and conformance.  

My organisation’s own role has evolved too. Open Banking Limited is not the implementation entity of the early days, focused on compliance and mandates.  

We have shifted to become a partner and convenor for the ecosystem. That means moving from delivery mechanics to enabling collaboration – maintaining standards, publishing transparent performance data, and creating the forums where issues get solved collectively.  

It’s a role focused on facilitation and enablement, a critical one: without a trusted centre of gravity, cocreation stalls and fragmentation creeps in. Our job is to keep the rails aligned so innovation can happen at pace and with confidence. 

The thread running through all of this is partnership – government setting direction, regulators overseeing outcomes, industry delivering against clear expectations. 

Signals of Progress 

And we – the whole ecosystem – are delivering. 

Let me ground that with three simple signals. 

Adoption – this summer the UK crossed 15 million users of open banking – a moment that tells us we are beyond early adopters and into everyday finance. 

Usage – in a typical month we’re seeing mid20 million open banking payments, with seasonal peaks higher and growth rates that still look healthy as use cases broaden. 

Public endorsement – HMRC’s use of open banking for tax payments is a powerful signal: when the state chooses standards based rails, trust and convenience follow. 

Those facts matter – but they are just illustrations of a broader message. The point is how we keep improving the model so adoption turns into durable value – for people, for businesses, and for the wider economy. 

The UK is now moving from a world of top down prescription to outcome based regulation with industry delivery.  

The Data (Use and Access) Act provides the legal toolkit to take Smart Data beyond banking, while also enabling a long-term footing for Open Banking itself through a Long Term Regulatory Framework.  

It sets the stage for a Future Entity with clear accountability, a remit to set and maintain standards, and a role in performance transparency – under regulatory oversight but commercially sustainable. Government enables – industry delivers – regulators safeguard outcomes. 

What does that mean for enablers like Open Banking Limited today? We are – and must remain – a neutral, trusted convenor. Our job is to keep the ecosystem moving: to steward standards with the community, to support conformance, to publish performance and reliability data that drive improvement, and to bring parties together where market incentives alone won’t deliver interoperability. That convening role is not about central control – it’s about reducing friction so more value gets to users, sooner. 

And – while the proof is in the outcomes – I am proud of the way that the UK industry, including OBL, is stepping up to this opportunity.  

If you want a crisp example of “industry led, regulator enabled” in action, look at cVRP – variable recurring payments. The ecosystem has co-funded preparatory work to move VRP from a promising capability into commercial reality. Regulators are clearing the path; firms are seizing the opportunity; and the outcome is better recurring payment experiences for people and merchants – with protections that feel native, not bolted on. That is what momentum looks like when roles are aligned. 

And this is just the start of what industry-led progress could look like. 

The international dimension matters just as much… 

Europe’s work on PSD3 and the Framework for Financial Data Access offers valuable perspectives on scope, consumer control and the data layer.  

Australia’s CDR and Brazil’s Open Finance demonstrate how breadth and pace can come together when governance and incentives land well.  

Benefits of co-creation  

Our contention is simple – let’s compete on execution, not reinvent the basics. Where we can harmonise on consent patterns, security profiles and core data semantics, we should. Where different policy choices are right for national markets, let’s keep the bridges strong so cross border providers can meet expectations without fracturing user experience. 

Cocreation is the bridge between policy intent and real-world delivery. It works better than prescription because it aligns incentives – those closest to customers help design how outcomes are met, while regulators keep their focus on what must be achieved. When we do this well, we see faster iteration cycles, fewer unintended consequences, and solutions that fit how people and businesses actually behave. In other words, cocreation doesn’t dilute regulatory ambition – it makes it deliverable.  

This approach also builds trust. When firms, regulators and government are solving problems together in the open – agreeing the minimums, testing in live environments, publishing performance – people can see how standards protect them and why changes happen. That transparency is what turns compliance into confidence, and confidence into adoption.  

But cocreation doesn’t organise itself. It needs a centre of gravity – a neutral place where competitors can collaborate, issues can be resolved once rather than in dozens of bilateral threads, and improvements can be agreed and measured.  

That is the quiet value of an organisation like Open Banking Limited. We don’t set commercial strategies; we create the conditions – common rails, clear rules of the road, shared performance data – that allow the market to move quickly and fairly. In a diverse ecosystem, facilitation is not bureaucracy – it is the glue that keeps momentum. 

Cocreation outperforms prescription for a simple reason – it aligns accountability with capability. Those closest to customers help design how outcomes are met; regulators set what must be achieved and test whether it has been.  

That division of labour reduces rule churn, surfaces issues earlier, and gets fixes into the wild faster. It also means that when tradeoffs are necessary – between protection and convenience, speed and certainty – they are made with the right people at the table and the evidence in hand.  

We can see the difference in delivery patterns. When changes are cocreated, pilots run on common rails, success criteria are public, and iteration is expected. Adoption follows because participants trust both the baseline (minimum service levels, dispute routes, performance transparency) and the room to innovate beyond it. In other words – compliance becomes a floor to build on, not a ceiling that flattens progress.  

Our role at OBL is to make that model practical. We convene competitors to solve shared problems once; we keep standards and conformance moving so improvements land predictably; and we publish performance so everyone can see where we are and what needs work.  

It is a deliberately quiet role – partner and convenor, not director – but without it, collaboration fragments into bilateral negotiations and momentum bleeds away. Our job is to keep the rails aligned so innovation can happen at pace and with confidence. 

Challenges – and how to solve 

All that said, let me be clear about the pressure points we still need to solve – the unglamorous work that determines whether we scale with confidence. 

Commercial sustainability and symmetry – if participation is to be durable, incentives must be balanced across the stack. That means baseline capabilities that are truly usable and minimum service levels that are actually met; it also means the space for premium features where clear value exists. Without predictability, investment hesitates. 

Dispute clarity and redress – when something goes wrong in multiparty journeys, people need intuitive redress and firms need certainty about routes and responsibilities. Design this into the model, don’t leave it to bilateral contracts alone. 

Performance transparency – high-quality, comparable data on API availability and responsiveness is one of the most effective regulatory tools we have – it rewards good actors and shines a light where improvement is needed without constant new rules. 

Interoperability over fragmentation – as Smart Data schemes develop in other sectors, consistency in consent journeys, security profiles and data definitions is what enables cross sector value – mortgages that recognise current account history; energy switching that reflects real payments behaviour; verified attributes that travel with the user. Build once, use often. 

Use case examples  

To illustrate why this matters, consider three short stories – all grounded in what we are already seeing. 

Households and HMRC – when people can make high value payments simply and securely through account to account rails, they adopt the behaviour and trust grows. HMRC’s experience shows that when the state uses the standard, confidence follows and volumes scale. 

SME cashflow – account connectivity and payments orchestration give smaller firms faster settlement and clearer cash positions. As recurring payment options improve, SMEs can reduce involuntary churn and reconcile in real time – saving cost and reducing fraud exposure. 

Lending journeys – verified transaction data – permissioned by the user – shortens underwriting cycles and improves accuracy. That’s good for affordability assessments and good for inclusion when done responsibly and transparently. 

Way ahead 

If we map this forward two years, here is a credible picture of what success can look like: 

A Future Entity – what my organisation OBL will evolve into – operating on a stable regulatory footing, with a clear remit for standard setting, performance transparency and conformance support – aligned to an outcomes based Long Term Regulatory Framework, and focused on innovation and enabling across the whole of the industry. 

Recurring payments that feel as familiar as card on file– with straightforward refunds, dispute routes that make sense to users, and reliability that merchants can plan around. 

Early Open Finance expansions where user value is obvious – savings, mortgages and credit in particular – delivered against common consent and verification patterns so journeys are simple, safe and explainable. 

A Smart Data trajectory that resists fragmentation by reusing proven components – consent frameworks, aligned security specifications, and shared trust services – so cross sector journeys feel coherent rather than stitched together. 

Now, a word about tone. As convenors, we should be open about what we know, honest about what is still evolving, and approachable in how we engage. That matters especially in rooms like this.  

It’s easy to lapse into technical jargon; it’s harder – and more valuable – to stay focused on user outcomes and to speak plainly about trade-offs. That’s been our commitment at OBL and it remains the most effective way to build consensus in a diverse ecosystem. 

This room’s opportunity  

Where does this leave us today – in a room of international regulators and industry leaders? 

First, let’s align on outcomes. Set targets that users can feel – reliability, speed, redress timelines – and measure them transparently. That gives industry the space to innovate, and regulators the levers to intervene when outcomes are missed. 

Second, let’s converge on minimums that travel. A small set of open, common patterns for consent, security and schemas will lower global friction. It won’t erase national differences – nor should it – but it will stop divergence from eroding user trust. 

Third, let’s test, then scale. Use timeboxed pilots for new features – like recurring payments enhancements – with transparent metrics. Scale what works; iterate what doesn’t; retire what fails. 

Fourth, let’s lock in symmetry and sustainability. Funding and incentive models should not privilege one layer of the stack. When value accrues across the ecosystem, costs and responsibilities should, too. 

Fifth, let’s share playbooks internationally. Redress models, minimum service levels, and performance disclosure are areas ripe for cooperation. Global providers will thank us – and users will benefit from consistency. 

If we do these things, we keep the best of the UK approach – a state that enables, regulators who are clear about outcomes, and an industry that leads – while learning openly from peers. That is how we turn mandate into momentum. 

Open Banking began as a narrow solution to a specific problem. It’s now a platform for competition, innovation and choice – supporting government services, helping households manage money, enabling businesses to grow. The next chapter – finishing Open Banking, and then in parallel turning to Open Finance and Smart Data done well – depends on the same compact: trust in the model, clarity about roles, and shared accountability for results. 

Close 

Let me end simply. We can move faster when we move together – regulators, government and industry – each doing what we do best. If we align on outcomes, insist on interoperability, and keep the economics sustainable, users will reward us with adoption – and adoption is the only metric that truly matters. 

The next chapter depends on cocreation – regulators, government and industry working as partners, with trusted convenors to keep the rails aligned. That is how we turn mandate into momentum. 

Location: Regulators Day, Open Banking Expo 2025, London

Delivered on 20 October 2025 (original script may differ from delivered version)