From foundation to future-state
For years, UK open banking was dominated by a single imperative: build the rails. Now, following the 29 October 2025 keynote, Open Banking Limited (OBL) has made clear that the next phase is about AI-ready standards, identity integration and scalable, interoperable infrastructure¹.
OBL emphasised that the “spark of open banking” is now transforming organisations from early-stage innovators into established market players¹.
At the same time, the FCA’s October 2025 research note reinforces this shift: open banking has proven its stability, and the next challenge is demonstrating consumer and SME outcomes beyond raw adoption metrics².
Why infrastructure providers must take note
1. Moving from compliance to innovation
Open banking originally centred on CMA-mandated APIs and PSD2/PSRs compliance³. The new landscape is about building services on top of these rails: identity-linked journeys, enriched data flows, AI-driven personalisation and resilient recurring-payment frameworks.
For infrastructure providers, this means designing for agility, data orchestration and cross-product interaction, not just initiation endpoints.
2. Standards and trust frameworks become central
OBL stressed the importance of standardisation across identity, API performance, security controls and data-sharing governance¹.
To support this shift, infrastructure must provide:
- Built-in interoperability
- Robust observability of data, consent and flow behaviour
- Auditability suitable for regulated environments
The FCA similarly warns that inconsistent API quality and fragmented standards remain blockers to scale².
3. Identity-linked data reuse becomes core architecture
OBL’s keynote referenced digital ID, cross-product journeys and secure data reuse¹.
This requires infrastructure to embed:
- Identity linkage
- Consent refresh and revocation
- Session-level authorisation
- Durable, inspectable audit trails
Asima’s architecture already reflects these fundamentals: multi-factor authorisation, consent/event telemetry, and data-lineage visibility across all flows.
Asima’s view: three strategic imperatives
1. Treat infrastructure as a product, not just an API
Open banking infrastructure should not be treated as a compliance afterthought. Performance, resilience, observability and interoperability are becoming the competitive differentiators.
2. Design for scale, not just pilots
The future is production-scale open finance, not proof-of-concepts. The FCA stresses that meaningful outcomes require systems built for real-world load, not curated sandbox conditions².
Asima’s guidance to clients is simple:
If your roadmap assumes 10,000 users, design for 1 million.
3. Build trust into architecture, not documentation
Trust now resides in design choices:
- Consent logs
- Identity linkage
- Authorisation transparency
- Data-reuse governance
These are structural features, not add-ons. As OBL noted: “Together we are stronger”¹ - and trust frameworks are the connective tissue enabling that collective progress.
What clients should do this quarter
- Reassess your API and data strategy: Map each service against identity, consent, telemetry and audit requirements.
- Test for scale: Build for real-world usage, not demo conditions.
- Shift your narrative: Move from “compliance access” to innovation capability when engaging banks and partners.
- Prepare for cross-product identity flows: Lending, recurring payments, digital assets and risk decisions will all rely on identity-centred architecture.
Final word
Open banking in the UK is no longer about opening accounts and exposing endpoints.
It is now an ecosystem built on identity, data reuse, performance and trust.
For infrastructure providers, this is the pivotal moment. Asima’s role is to give organisations the rails, reliability and observability required to innovate safely and at scale.
The rails exist. The standards are evolving.
What you build next is the real differentiator.
¹ Open Banking Limited. What open banking did next: Building the foundations for open innovation. 29 October 2025. Link
² Financial Conduct Authority. Research Note: Open banking and open finance in the UK. 6 October 2025. Link
³ Open Banking Limited. About us – Open Banking UK. Updated October 2025. Link
