Asima reflects on the implications for infrastructure, industry collaboration and the broader ecosystem.
Growth in open banking adoption and usage
In its 16 December 2025 progress update, the Financial Conduct Authority reported that UK open banking has continued to expand rapidly: there are now over 16 million active users across all open banking services, and open banking payments have grown 53 % year-on-year.¹
The FCA highlighted that variable recurring payments (VRPs) now account for a material portion of overall transactions - 16 % of open banking payments, reflecting strong developer and commercial traction for this new pattern of account-to-account use.¹ VRPs allow trusted third parties to initiate flexible, automated flows that go beyond traditional direct debits, offering a compelling alternative for consumers and businesses looking for greater control and real-time movement of funds. (We're ever hopeful of a much better consumer-facing name for cVRP - "Smart Debits" being Asima's preference.)
This sustained growth underscores that open banking is not just a regulatory artefact; it is becoming a real-world infrastructure layer supporting payments and account data services at scale.
Industry collaboration delivering next-phase infrastructure
One of the most important developments noted in the FCA’s update is the momentum behind industry collaboration to operationalise commercial VRPs. Ahead of 2026, the FCA states that a new independent company - the UK Payments Initiative (UKPI) - will be established by 31 firms to enable a commercial VRP scheme.¹ That mirrors the industry-owned model co-funded by signatories including banks, fintechs and infrastructure providers, of which Wonderful (Asima) is a founding funder.¹
According to the FCA, first live payments under the UKPI scheme are expected in the first quarter of 2026, marking the transition from pilots and proofs-of-concept to commercially available infrastructure for flexible payments.¹
This next phase is designed to expand flexible, consent-driven payment flows into regulated sectors like utilities and other billers that benefit from predictable yet adaptable recurring settlement.
What the FCA sees ahead: standards, regulatory powers and open finance
Beyond usage statistics and commercial VRP developments, the FCA update also looks forward to regulatory evolution.
The FCA plans to work with government on legislation to grant it explicit powers to set open banking rules - part of a broader effort to produce a long-term regulatory framework, expected to be consulted on before the end of 2026.¹ That framework will sit alongside the Data (Use and Access) Act 2025 and National Payments Vision, both of which underpin a more strategic regime for open banking and open finance.²
In practical terms, this indicates that:
- standards and interoperability will be formalised through new bodies and frameworks;
- regulatory oversight of open finance will expand beyond the original PSD2/PSRs mandate; and
- the government and FCA intend to align open banking with broader financial innovation goals.
These moves echo the principles set out in the FCA’s Open banking and open finance research note, which emphasises the need for stable, risk-informed frameworks and the exploration of broader smart data use cases in financial services.³
What this means for infrastructure providers
From Asima’s perspective, the FCA’s progress announcement highlights several key themes that infrastructure teams should be integrating into their roadmaps:
Growing participation and transaction volumes show that open banking is more than a “nice-to-have”. It’s becoming a core, high-throughput financial infrastructure. API performance, consent management and resilience will increasingly distinguish winners from also-rans.
2. Collaborative and industry-owned models are taking shape
The UKPI commercial VRP scheme exemplifies a shift away from bilateral or siloed integrations toward shared, industry-owned infrastructure. For clients, this means building systems that can plug into neutral, standardised commercial rails rather than bespoke bank connections.
3. Regulatory clarity is improving - but still evolving
The upcoming regulatory framework consultation presents both opportunity and complexity. Infrastructure must support not only current API mandates but also anticipated standards, supervisory reporting and interoperability requirements across the broader open finance landscape.
4. Open finance is on the horizon
While the FCA update focuses mainly on open banking and payments, its alignment with government strategy signals an inevitable extension to open finance, where insurance, credit and investment data have a role. Providers should be thinking beyond account data and payments to holistic, consent-centric data models.
Closing thoughts
The FCA’s “Open banking: a year of progress” report confirms that 2025 has been a year of maturation, not merely message-moment volatility. Adoption is rising, payments are scaling, and commercial VRP infrastructure is approaching production reality.
For Asima - as one of the founding funders of the UK Payments Initiative - this represents a validation of the vision that open, standardised, interoperable rails are not only feasible but commercially viable. The real test now is execution: scaling safely, building resilient and observable infrastructure, and collaborating across industry to deliver the next generation of open-banking-enabled services.
The rails are proving themselves. Now the ecosystem must prove it can build on them at scale.
¹ FCA. Open banking: a year of progress. 16 December 2025. Link
² FCA. FS25/4: Design of the Future Entity for UK open banking. 8 August 2025. Link
³ FCA. Research Note: Open banking and open finance in the UK. 6 October 2025. Link
