What Open Finance Needs to Earn Customer Trust

People do not experience their finances as separate product lines. Open finance becomes useful when connected data helps someone understand what they have, whether they are on track, and what they should do next.

That was one of the central challenges raised by Larry Banda, CEO of TISA Commercial Enterprises and Chair of Select ID, when he joined us on the Regulated Digital podcast.

Larry brings decades of experience across mortgages, investments, financial planning, and digital advice. Before joining TISA, his work at Nationwide included developing roboadvice in the FCA sandbox and rolling out video-based mortgage and financial planning advice services during the Covid-19 pandemic.

In the episode, we discuss what needs to happen for open finance and digital identity to move from industry initiatives into services that firms can deliver confidently and customers will actually trust and use.

Created from episode transcript

Open Finance Has to Answer "What Should I Do Next?"

A customer may hold a current account with one bank, savings elsewhere, investments on a platform, and several pensions from previous employers. Add a mortgage, insurance, and paperwork stored at home, and it becomes difficult to see a complete financial position.

The industry tends to organise this information through products and providers. The customer still has one financial life.

Larry described three basic questions that open finance should help people answer: What have I got? Am I on track? What should I do next?

An aggregated view can answer the first question. The larger opportunity is to interpret what the information means, identify where attention may be needed, and provide a sensible route into guidance, targeted support, or advice.

"The real prize for open finance isn't data. It's access to understanding."

Larry Banda, CEO, TISA Commercial Enterprises and Chair of Select ID

A technically impressive dashboard could still leave the customer staring at a screen and wondering what to do. The quality of the service will depend on whether connected information leads to a decision the customer can understand and act upon.

Connected Data Is Only the Starting Point

Open banking demonstrated that firms can collaborate on standards, customers can grant permission to share information, and services can be built across competing providers. Larry pointed to payments, affordability assessments, income verification, account aggregation, and cash-flow management as examples where the customer benefit is immediate.

Open finance brings more complicated information into the picture. A current-account balance is relatively easy to interpret. A pension may involve contributions, investment risk, tax treatment, charges, guarantees, projections, and decisions with consequences lasting decades.

Why Pensions Need More Than Account Aggregation

"If I misunderstand my current account, I might go overdraw," Larry explained. "If I misunderstand my pension, I could make a decision that affects the next 30 years of my life."

The Pensions Dashboards Programme is intended to let people access pension information, including their State Pension, securely in one place. Pension providers and schemes in scope must complete connection to the dashboards ecosystem by 31 October 2026.

That visibility can help people locate forgotten pensions and understand what they hold. The next-step problem will remain. Customers may still need help interpreting the information and deciding whether to consolidate, contribute more, seek advice, or leave an arrangement unchanged.

Collaborate on the Rails, Compete on the Journeys

TISA's Open Savings, Investments and Pensions project completed a beta using synthetic data to test customer journeys, APIs, standards, and participation agreements.

The work showed that technical connections are only one part of the system. Firms also need clear rules around governance, liability, service standards, conformance testing, accreditation, and commercial participation.

These issues become particularly important for smaller providers, platforms, and fintechs. A firm without existing open-banking infrastructure cannot be expected to carry the same implementation costs as a major bank, especially when it only needs a limited part of the available data.

Larry summarised the principle as: "Collaborate on the rails. Compete on the journeys." Common definitions, permissions, and participation rules can reduce duplicated integration work. Providers can then compete through insight, guidance, service, price, and customer experience.

The FCA's open finance roadmap, published on 14 April 2026, maps a path from prioritising and testing high-impact use cases through to wider delivery by 2030. The Data (Use and Access) Act 2025 creates powers for new Smart Data schemes and provides a statutory foundation for digital verification services.

Digital Identity Should Stop Customers Starting Again

Financial-services customers repeatedly prove who they are. They upload passports, driving licences, utility bills, selfies, and liveness checks to different organisations, sometimes several times during one transaction.

A mortgage journey may involve separate checks by an estate agent, broker, lender, and solicitor. Larry also described having to email identity documents to a bank while acting as treasurer for a charity. Repeated verification creates cost for firms and spreads sensitive documents across more systems and inboxes.

Reusing Verified Identity Safely

A reusable digital identity could allow someone to prove relevant facts once and use them again with permission. The receiving firm would still need to decide what evidence is appropriate for the product, risk, and regulatory requirement, but the customer would not automatically begin every relationship from the beginning.

Select ID describes its model as a marketplace connecting UK businesses with a choice of identity providers that are independently certified against government rules for digital identity services.

In an open-finance journey, identity can help confirm that the correct person is requesting information, granting consent, and acting on it. Once identity and permission are established, connected data could support a faster move into onboarding, targeted support, or advice.

Consent Has to Remain Under the Customer's Control

Consent becomes difficult when customers are presented with broad permissions and lengthy legal text. A customer asking for help with savings may be comfortable sharing savings information without granting access to their entire financial position.

Permission should match the purpose of the service. Customers should also be able to see active permissions, understand what they cover, and withdraw them when they no longer want the service to have access.

Accessing information, using it to provide a service, retaining it, and sharing an insight derived from it are separate activities. A clear journey needs to explain those distinctions without requiring the customer to interpret dozens of pages of terms.

"Customers lose confidence when identity checks, consent, document delivery, and the next action feel like separate processes. Firms need to make clear who is asking, why information is needed, and what the customer can expect next, while applying stronger checks when the action warrants them."

Adam Byford, COO, Beyond Encryption (Mailock)

This also affects how firms communicate throughout the relationship. Sensitive information, permission requests, identity checks, and instructions need to arrive through a route the customer recognises, with enough context to understand what is being requested and why.

Better Data Could Expand Guidance and Targeted Support

Advisers and support teams often spend substantial time gathering information before they can begin helping a customer. Permissioned data could reduce repetitive fact-finding and give professionals more time to interpret the customer's position, identify gaps, and discuss possible next steps.

The FCA's targeted support regime went live on 6 April 2026. Firms need the specific permission to provide suggestions designed for groups of consumers with common characteristics.

Connected data could help firms recognise when support is relevant. Digital identity could help confirm who is acting, open finance could provide the authorised information, and the support service could guide the customer towards an appropriate next step.

For firms reviewing these journeys, communication remains part of the infrastructure. Mailock keeps email as a familiar delivery route while adding AES-256 encryption, recipient authentication, secure replies, and message tracking for sensitive customer communications.

Open Finance Must Work for Less Digitally Confident Customers

Open finance will be easiest to design for customers who already use banking apps, investment platforms, and personal-finance dashboards. Larry's concern is that success could be limited to people who are already engaged and comfortable managing their finances digitally.

The larger opportunity is to help people who find financial services fragmented, intimidating, confusing, or simply difficult to prioritise. That includes customers who need help from an adviser, call-centre colleague, branch employee, carer, attorney, or trusted family member.

Inclusive design therefore cannot assume that everyone wants to manage their financial life through a smartphone. Some customers will need assisted journeys, larger screens, human explanations, telephone support, or a way for an authorised representative to participate.

Digital infrastructure should make assisted routes easier to provide while keeping human support available.

Measure Better Decisions, Not Connected Accounts

The number of connected providers or available data fields will show whether the infrastructure is growing. Customer outcomes will show whether it is useful.

Larry suggested measuring whether more people engage with pensions earlier, receive support before retirement, obtain better savings outcomes, and avoid repeating the same information across every service. Firms should also be able to reduce manual information gathering and give advisers more time to help customers reach a decision.

Useful indicators include whether customers complete the journey, understand the permission they granted, return without restarting, and know where to go for help.

Larry's test is simple: "That was easier than I thought, and now I know what to do next." Open finance will have become part of ordinary financial services when customers can say that, return to the service, and carry on from where they left off.

FAQs

What Is Open Finance?

Open finance is the permissioned sharing and use of a wider range of financial information than open banking. It may include savings, pensions, investments, mortgages, insurance, and other parts of a person's financial position.

How Is Open Finance Different From Open Banking?

Open banking has focused largely on payment accounts, transactions, and related services. Open finance aims to connect a broader and more complex range of products, including long-term savings and pensions.

What Role Does Digital Identity Play in Open Finance?

Digital identity can help confirm that the correct person is requesting information, providing consent, and acting on it. Reusable identity services may also reduce the need to submit the same documents repeatedly.

Why Does Open Finance Need Common Standards?

Common data definitions, APIs, consent models, liability rules, and participation requirements reduce duplicated integration work. Firms can then develop different customer services using shared foundations.

References

Larry Banda, LinkedIn

Who's Who at TISA, TISA

Open Savings, Investments and Pensions, TISA

Open Finance Roadmap: Our Vision for a Smart Data Future, Financial Conduct Authority, 2026

Data (Use and Access) Act 2025, UK Government, 2025

Six Months to Go to the Pensions Dashboards Connection Deadline, Pensions Dashboards Programme, 2026

Select ID, Select ID

Supporting Consumers' Pensions and Investment Decisions: Rules for Targeted Support, Financial Conduct Authority, 2025

Adam Byford, LinkedIn

Reviewed by

Sam Kendall, 14.07.26