Open Banking, Twice: Why 2026 Feels Like the Second Arrival

First it arrives as legislation: pages of obligations, diagrams of trust frameworks, compliance dates that force everyone to build something by a certain Thursday. Then it arrives again, quietly, when enough of the plumbing works well enough that product teams stop talking about “the open banking integration” and start talking about the experiences it unlocks.

2026 feels like it’s tilting toward that second arrival.

Not because the hard parts are behind us (they aren’t), and not because the rules suddenly became simpler (they didn’t). It feels different because the centre of gravity is shifting away from “can we exchange data securely?” and toward a more demanding question: “can we exchange data reliably, predictably, and in a way that stays trustworthy at scale?”

For data holders, that distinction matters. The first era of open banking rewarded getting endpoints live. The next era rewards operational maturity: the disciplines that are boring until they become the reason customers trust your brand.

The most interesting change in 2026 won’t be a new acronym. It will be what the market starts to treat as normal.

Reliability becomes a product feature, not an engineering footnote. The organisations that thrive will be the ones that treat open data like a production channel with the same seriousness as cards, payments, or digital banking-because the consumer doesn’t experience “a standard”; they experience a journey. If the journey is slow, inconsistent, or confusing, they don’t blame the ecosystem. They blame the bank.

That nudges everyone toward a more adult set of conversations: data quality as an outcome, not a best effort; conformance as something you continuously prove, not something you once passed; incident response as a measured capability, not a heroic scramble; partner support as part of customer experience, not a cost centre. In practical terms, it’s less about how many APIs exist, and more about whether those APIs behave the same way on Tuesday at 9am as they do on Saturday night during a release.

It also changes what “good” looks like in product design. Consent stops being a checkbox and becomes a form of customer care.

The most sophisticated teams are starting to see consent as the beginning of a relationship, not a one-time hurdle. That means fewer dark corners and fewer surprises: clearer explanations of what’s being shared and why, easy ways to manage permissions, re-authorisation flows that feel like a feature rather than a punishment. It’s a subtle shift, but it compounds. When consent is designed with empathy, it increases completion rates, reduces complaints, and lowers the downstream operational load. When it isn’t, it creates the kind of friction that makes even a technically “successful” integration commercially fragile.

If you’re a data holder, this is where brand and compliance quietly converge: the cleanest consent journeys tend to be the easiest to evidence. The best audit trails tend to be the easiest to explain. The most defensible security posture tends to align with the least surprising customer experience. None of this is accidental, it’s the result of treating open data as a first-class channel.

Another theme that’s hard to miss: governance is becoming less theoretical.

As open banking matures in different regions, the ecosystem starts asking for scheme-like behaviour: clear operating rules, predictable change processes, better dispute pathways, more consistent conformance expectations. Not because anyone is trying to centralise innovation, but because scale is allergic to ambiguity. When every participant interprets a standard a little differently, the cost is paid not in architecture diagrams but in customer drop-off, escalations, and “why does this work with Bank A but not Bank B?” support tickets.

In 2026, I expect more emphasis on the unglamorous mechanics of running a data-sharing ecosystem well: versioning discipline, deprecation policies that don’t surprise people, tested rollback plans, and the ability to evolve standards without breaking the world. The organisations that take this seriously will make it easier for everyone else to deliver good experiences—and they’ll earn trust for it.

Then there’s the part of open data that’s still widely underestimated: expansion isn’t just “more APIs”, it’s more domains.

When open data moves beyond deposit accounts into adjacent sectors—lending, energy, wealth, and beyond—the complexity isn’t additive, it’s multiplicative. Different products mean different consent expectations, different data semantics, different edge cases, different risk profiles. “Account balance” is relatively intuitive; “credit decisioning inputs” or “tariff details” can be anything but. So 2026 will favour platform thinking: designing your data-sharing capability so that adding a new domain feels like extending a framework, not inventing a new system.

That’s good news for data holders, because platform thinking is where managed infrastructure and consistent operating models really shine. It reduces the overhead of constant change and lets teams focus on governance, customer experience, and risk—rather than rebuilding plumbing every time the market evolves.

We should also talk about “write” capabilities (action initiation, account-to-account flows, and consented initiation patterns like variable recurring payments) because they change the nature of open banking from “informational” to “transactional”. It’s tempting to frame this as an inevitability, but it’s more accurate (and more respectful to the realities data holders manage) to say: the direction is clear, the sequencing will be cautious, and the standards will have to earn the right to scale.

Initiation raises the bar. It requires stronger controls, clearer liability and dispute pathways, and sharper thinking about fraud and authorisation. It also has to coexist with existing payment rails and customer expectations. In 2026, the most credible progress here won’t come from hype; it will come from well-governed, well-instrumented implementations that make customers feel safer, not simply faster.

And finally, a prediction that’s less about technology and more about posture: the winners in 2026 will be the organisations that learn to treat openness as a continuous capability rather than a project.

Projects end. Capabilities improve.

A capability has release rhythms. It has observability. It has a language for risk. It has dashboards and SLAs and runbooks and owners. It has product managers who care about conversion and compliance people who care about evidence, and the two groups share the same metrics because they are, in reality, measuring the same thing: trust.

If there’s a “genius move” available to data holders this year, it’s not a clever feature. It’s choosing the boring excellence that customers never explicitly request but always feel: consistent performance, predictable behaviour, clean consent UX, and operational calm when things go wrong.

That’s how open banking stops being something you “support” and becomes something your customers quietly rely on, without having to think about it at all. Which is, in the end, what the future usually looks like when it finally arrives.