"Discussion of Open Finance has been underway since 2019, when the FCA published it’s Call for Input on the subject. The initiative to open a broader range of financial services to third party access (including mortgages, pensions, investments, savings) comes as authorities and industry reflect on the success of Open Banking. There have been promising signs of growth recently with Open Banking surpassing the one million customer mark for the first time in January.

"We believe a testing environment between data holders and third party providers could accelerate the move towards Open Finance, and help regulators to develop rules that unblock, rather than restrict innovation. Open Banking gave consumers the ability to use third party providers, to view and manage their accounts and make payments. It has seen an influx of innovation in the UK, with hundreds of companies, including TrueLayer, now regulated to provide open banking services.

"It took five years to develop and implement the European legislation underpinning Open Banking, for Open Finance we potentially need a more agile approach of testing, standard development and feedback, taking inspiration from the FCA and other regulatory Sandbox initiatives.

"Alongside a Testing Environment, we are calling for the Authorities to consult on rules enabling consumers to access their Open Finance data via third party providers at an early stage.

"We believe embedding this right will provide the impetus for Open Finance data holders to consider how to facilitate access and create the catalyst for Open Finance innovation.

"Our response on Open Finance also points to unintended scope gaps in PSD2, which prevented customers from accessing certain types of bank accounts via third party providers. These gaps should be addressed as a first step for Open Finance."