Digital Economy Soundbite | Smart and Open Data: Combining accessibility and safety, The FCA and ICO Joint Insights
20 October 2025
Open data has immense benefits for the economy and society. A cohesive, co-ordinated approach from regulators is vital if the benefits are to be leveraged safely and effectively. To this end, the FCA and ICO continue to work together to bring operational reality to smart data, both in the UK financial services sector and more broadly. The two UK regulatory authorities have recently issued Joint Insights webpage on the future of open finance and smart data.
The FCA has confirmed its support for the UK's National Payments Vision and the UK Government's wider ambitions for the nation to become a global leader in open finance. Its recently launched Smart Data Accelerator offers a secure space to test high-potential and complex open finance use cases through targeted sprints and initiatives. The Joint Insights however, go beyond simply looking at open banking issues (or even those of open finance) to ask more pressing questions of the technologies that will shape the "future of [open] finance". Therefore, the increasing use of AI, Distributed Ledger Technology and smart contracts are considered in the interplay between smart data access and the roll out of these technologies. Tech convergence and how its impacts and ramifications will be managed are clearly at the forefront of both regulators' concerns in shaping any future policy on Smart Data ecosystems.
The ICO expressed its commitment to open finance and data portability schemes in January 2025. The recently enacted Data Use and Access Act 2025 sets out a framework for access, sharing and use of customer data, with specific sectoral Smart Data schemes, including open finance, to be implemented by statutory instrument. We expect the ICO to issue guidance for organisations on this topic as well as providing advice and support to the Government on the data compliance aspects of digital identity and AI – both of which will undoubtedly form a key part in driving open finance.
Organisations must review their risk appetite and ensure their data, IT and cyber governance policies reflect fast moving technological innovations and their regulatory impacts. It goes without saying that this has already hit your regulators' desks.
