FCA maps three open finance infrastructure models but stops short of picking one

Worth reviewing.

The FCA has published commissioned research from Saïd Business School, University of Oxford ("Powering Open Finance Infrastructure"), working with Raidiam Services Limited as technical partner, mapping potential infrastructure models for open finance in the UK. The FCA published the research in September 2026 under the Smart Data Accelerator programme. No rule change follows from it directly.

The research describes three reference architecture families. A centralised model concentrates key trust, assurance and coordination functions within a shared institution or set of services: consistent, accountable and capable of rapid ecosystem-wide action, but carrying concentration risk, operational dependency and reduced flexibility. A decentralised or federated model distributes responsibilities across authorities, standards bodies and participants: flexible and sector-adaptable, but prone to fragmented implementation, inconsistent user journeys and higher integration costs if standards are not sufficiently coordinated. A hybrid model combines common coordination of functions such as accreditation, participant status, trust information, monitoring and revocation with distributed data custody, APIs and customer journeys: intended to capture the benefits of both approaches while limiting single points of failure and preserving sector flexibility.

The FCA's headline finding is that the right question is not centralised versus decentralised, but which infrastructure functions require common coordination and which should remain distributed. That framing matters: it signals the debate will focus on carving up responsibilities rather than choosing a single architecture wholesale.

The research also identifies the practical conditions any model must satisfy to make financial data sharing usable, trustworthy and scalable: common technical standards; secure APIs; reliable accreditation and identity arrangements; effective consent and authorisation; operational monitoring; and the ability to suspend or revoke access. Future work under the Smart Data Accelerator will test how each architecture performs against observable measures including participant onboarding, trust portability, interoperability and incident response.

The FCA frames open finance as more than an extension of open banking into additional products. As data sharing extends across a wider range of products and firms, infrastructure design faces a broader challenge. The research considers how infrastructure may need to adapt to agentic AI (systems that act autonomously on a user's behalf rather than simply responding to queries) and developments in quantum computing, noting that infrastructure will need to support new approaches for verification, delegation and accountability as these services mature. The findings also draw on international examples from Australia, Brazil, the European Union and the United Arab Emirates.

The FCA is explicit that this does not represent a final infrastructure decision or FCA policy position, and no timeline has been published for when practical testing of the reference architectures will begin. For most firms, this is a watching brief. Firms that expect to participate in Smart Data schemes will want to track this work as it progresses. The architecture choices made here will determine the technical and compliance framework firms must integrate with. That work is not yet settled.

Sources

• Powering open finance infrastructurefca.org.uk