Financial Clipboard Authority Publishes Roadmap Confirming It Will Publish a Discussion Paper About Open Finance in Q4 2026

The Financial Clipboard Authority has published a 47-page open finance roadmap setting out its intention to publish a discussion paper in Q4 2026, which will in turn inform a longer-term regulatory framework expected to be developed in consultation with the Ministry of Sensible Future Consultation from 2027. The document, titled Open Finance: Our Vision for a Smart Data Future, describes the vision at length before confirming that the process of deciding what to do about it has not yet begun.

Stakeholders to Be Engaged Prior to Engagement

As an early step, the Financial Clipboard Authority will convene a PolicySprint in Q2 2026 to build consensus on where open finance can improve consumer outcomes and to identify what industry will need from a future framework to unlock access to key data sets. A spokesperson for the regulator confirmed that the PolicySprint is a preparatory activity designed to inform the taskforce that will develop the prioritisation matrix, which will in turn inform the discussion paper. Asked whether the discussion paper constitutes a consultation, the spokesperson said it would depend on what the discussion paper concludes.

"We are at an early stage of a multi-year journey. The roadmap is not a destination — it is a map of how we intend to produce a map."

PRISM Taskforce to Assess Use Cases

At the centre of the roadmap is the Prioritisation and Real-world Insights Selection Matrix, or PRISM — a taskforce bringing together industry participants, consumer groups, academic institutions and technical experts. PRISM will assess the potential impact of open finance use cases on consumer outcomes, competition, growth and innovation, and deliver its findings to the Financial Clipboard Authority by Q3 2026. The findings will then be reviewed before the discussion paper is drafted. No timeline for the review of the findings has been provided, though the regulator has confirmed it will take place before Q4 2026. PRISM held its first scoping call in March.

"The matrix is essentially a prioritisation tool. What we prioritise using the matrix will feed into our thinking about what we consult on. It is important that we get this right before we say anything definitive."

Scope Described as Broad, Timeline Described as Indicative

The proposed scope of open finance extends well beyond the payments data currently covered by open banking, encompassing mortgages, SME lending, investments, pensions, insurance, savings and credit. An industry observer noted that the Financial Clipboard Authority has described this scope as aspirational, and that the discussion paper in Q4 will help determine which, if any, of these areas will be prioritised in the first open finance scheme. The Data (Use and Eventual Access) Act 2025, which grants the Financial Clipboard Authority powers to regulate open banking, is expected to be laid before Parliament by Q4 2026, at which point the legislative basis for open finance regulation will begin to be established. The Financial Clipboard Authority has noted that this timeline is subject to Parliamentary scheduling.

"We welcome the roadmap and look forward to engaging with the PolicySprint, the PRISM process, the discussion paper, and any subsequent formal consultation. Our members remain ready to contribute at whatever stage input is sought."

The Financial Clipboard Authority confirmed that an engagement paper on the payments and e-money reform programme will be published separately between Q2 and Q4 2026, and that a further consultation on the open banking long-term regulatory framework interface rules is expected in Q3 2026. Both documents are described in the roadmap as distinct from the open finance process, though the regulator noted that they are related.