Back to all articles Payments

Open finance use cases: what deserves enterprise investment

The FCA's new PRISM framework gives enterprise teams a structured way to compare open finance propositions, expose evidence gaps and decide what to fund, test or defer.

Kieron James
Open finance use cases: what deserves enterprise investment

The Financial Conduct Authority published the PRISM Taskforce outcomes report on 7 October 2026. The Prioritisation and Real-world Insights Selection Matrix gives the FCA and industry a common method for assessing the potential impact of open finance use cases. It makes the evidence, dependencies, risks and delivery conditions behind each proposition visible.¹

For a CPO or CTO, the immediate value is investment discipline. A proposition can promise a better customer journey, broader access to finance or lower operating cost and still lack the data, participation, safeguards or commercial incentives needed for delivery. PRISM provides a way to test those assumptions before product, compliance and supplier budgets become committed.

The report is an industry-informed analytical framework published through the FCA's Smart Data Accelerator. It supports future policy and testing work. It does not approve a use case, create a regulatory requirement or determine a national delivery sequence.²

A use case needs a decision-grade definition

PRISM begins with classification and dependencies. Each use case needs a defined problem, affected actors, required datasets, a clear account of what it adds to current services, the capabilities it depends on and the further services it could enable. The first stage also records time to value, expected duration, value type, the baseline without open finance and the assumptions carrying the case.²

This changes the quality of the investment conversation. A broad idea such as better SME lending contains several possible propositions. Faster application preparation, more accurate affordability evidence, earlier identification of financial stress and improved cashflow forecasting each serve different users and depend on different data, permissions and operating processes.⁴

The baseline deserves particular attention. Teams need to show the customer or business outcome under current arrangements, the friction that remains and the specific contribution permissioned data sharing could make. That keeps the case anchored to an observable problem and gives later testing a credible comparator.

Data assumptions also need to be explicit. Availability, coverage, provenance, timeliness and permitted use determine whether a proposition can support the decision it promises. The open banking data freshness control model provides a useful way to connect evidence age and lineage to the action that consumes it.

Scores need rationale and confidence

PRISM's second stage applies a one-to-five scale across six dimensions: impact depth, impact scale, future unlock, readiness, risk of user harm and market risk. Every score carries a short rationale and a high, medium or low confidence rating based on the strength and relevance of the available evidence.²

That confidence rating prevents a plausible story from carrying the same weight as observed evidence. A team may have strong evidence that a target group experiences a costly process and limited evidence that customers will grant the required permissions or continue using the service. The investment record should preserve both conclusions.

The report allows observed evidence, comparators, proxies and expert judgement, provided uncertainty remains visible. Amber flags identify cautions that should shape sequencing, mitigation or further research. Red flags identify issues capable of blocking a use case or requiring resolution before a high score is acted on.²

Trust runs through several dimensions. It appears in customer understanding, permission control, accountability, redress, adoption and market governance. A single trust score would hide those different failure modes. The report therefore treats trust as an overlay expressed through evidence, rationales and flags.²

A portfolio view keeps trade-offs visible

The third PRISM stage compares use cases while preserving the six dimensions, confidence levels and flags. Heat maps, radar diagrams and foundation maps can show where propositions differ and where they rely on the same data, infrastructure or governance. The report says the framework supports informed judgement and excludes an automatic fixed ranking.²

That approach suits enterprise portfolio decisions. A proposition with high potential impact may still have low readiness. Another may offer a smaller initial outcome with stronger evidence, faster delivery and reusable capabilities. A third may expose a red flag around consent, liability or market concentration that needs resolution before further spend.

Investment committees can retain that shape by recording a decision for each use case alongside its evidence plan. Funding can support discovery where the problem and data need are clear, targeted testing where an assumption determines viability, and deferral where a blocker has no credible owner or route to resolution. These are Asima recommendations derived from the framework. They are commercial and delivery judgements for the enterprise to make.

Shared foundations change portfolio economics

PRISM compares use cases to reveal recurring needs for data, standards, consent, identity, governance and technical infrastructure. The FCA report says these shared foundations can influence impact as strongly as the individual service.¹

This introduces a portfolio effect. A permission service, participant-verification method, provenance control or monitoring capability may support several propositions. Its value extends beyond the first customer journey. The investment case should identify that reuse and state which parts need common consistency and which can remain configurable for a sector or product.

The FCA's separate infrastructure research reaches a related conclusion. It identifies common technical and assurance foundations across possible open finance models, while leaving future governance and operating choices open.⁵ The open finance infrastructure analysis explains which trust, permission, monitoring and revocation capabilities can be specified while those choices develop.

Shared capability also creates dependency. If several propositions rely on the same identity, consent or data-quality control, its failure reaches several customer outcomes. Reuse therefore strengthens the investment case and raises the standard for ownership, resilience and evidence.

Need help scoping your open banking proposition?
Book a discovery call with Asima to discuss delivery, compliance and commercial structure.

Evidence gaps should control the next spend

The strongest use-case assessment produces a specific evidence plan. A low-confidence adoption score can lead to customer research and journey testing. Uncertain data coverage can lead to sample-data analysis across relevant providers. Questions about supplier delivery can become proof-of-concept acceptance criteria and contract evidence, using the open banking provider RFP scorecard as a starting point.

Some gaps belong earlier in the sequence. A proposition that cannot define its permission model, affected users or route to redress needs further design before a delivery estimate will carry much value. Agentic services raise the same issue around authority. The agentic payments architecture separates an intelligent service's recommendations from the deterministic controls and evidence required for execution.

PRISM also asks whether the market would deliver the outcome through existing services and what open finance adds.² This intervention baseline protects the portfolio from funding technology in search of a customer problem. A credible proposition needs an identified user outcome, an additional capability, a viable participation model and evidence that the customer journey can earn sustained use.

Current testing gives teams useful comparators

The FCA's April roadmap prioritised SME lending and mortgages and established PRISM as part of a wider testing programme. It also set out a Q4 2026 discussion paper on the first open finance scheme and work with HM Treasury on longer-term regulatory options in 2027.³

The mortgage and SME finance TechSprints provide practical evidence for the assessment method. Participants used synthetic data to explore propositions covering lending, cashflow, resilience, affordability, switching and reusable credentials. The FCA observed that teams working with similar underlying datasets developed different services, which placed greater emphasis on common data, infrastructure, consent and verification foundations.⁴

Enterprise teams can use those cases as comparators while keeping their own evidence specific. A successful prototype in one journey establishes possibility within that test. A production investment still needs evidence for the intended users, data providers, permissions, operating model, suppliers and commercial incentives.

Keep policy and scheme choices provisional

PRISM helps structure a current investment decision. It leaves future regulation, national prioritisation, scheme design and participation choices open. The FCA's infrastructure models remain reference architectures for testing, and the roadmap's next policy milestones still require later verification.³ ⁵

Decision records should therefore separate current evidence from future dependencies. A team can fund a defined proposition, an evidence plan and reusable foundations now. Assumptions about mandatory data access, commercial terms, liability allocation, future operators or a national ranking need named owners and review dates.

The 7 October report gives enterprise teams a stronger basis for choosing where to invest. Define each use case consistently. Keep impact, readiness, confidence and risk visible. Fund the evidence that can change the decision. Give shared foundations their full portfolio value. That turns open finance ambition into a sequence of accountable commitments.

Footnotes

  1. Financial Conduct Authority, 7 October 2026. PRISM Taskforce outcomes report
  2. Financial Conduct Authority, 7 October 2026. PRISM Taskforce outcomes report PDF
  3. Financial Conduct Authority, April 2026. Open finance: our vision for a smart data future
  4. Financial Conduct Authority, 16 April 2026. Open finance TechSprints: mortgages and SME finance
  5. Financial Conduct Authority, 29 September 2026. Powering open finance infrastructure
Payments