Open banking in the UK has entered a phase that the regulatory architects did not anticipate and cannot control. What began as a competition mandate — forcing banks to share customer data through standardised APIs — has become a competitive battleground. The platforms that aggregate, interpret, and act on this data are competing for control of the financial infrastructure layer. The winner will occupy a position comparable to the card networks in payments: essential, ubiquitous, and extraordinarily profitable.

The Infrastructure Layer

The competition is not between banks and fintechs. It is between platform architectures. On one side, the bank-led aggregation platforms that use open banking data to retain customers within existing banking relationships. On the other, the independent platforms that use open banking data to create new financial relationships outside the traditional banking framework. The former have the customers; the latter have the agility. The question is which advantage proves more durable.

Our analysis suggests that the independent platforms are gaining ground. Transaction volumes through open banking APIs have grown 300% since 2024, and the majority of growth is flowing through independent platforms rather than bank-led initiatives. The infrastructure layer is being built by the challengers, not the incumbents.