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Insurance is the next step in the UK’s open banking journey

September 09, 2025

  • Digital Banking
  • Digital Lending
  • Digital Payments
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FintechOS
Teo Blidarus, Co-Founder and CEO of FintechOS

By Teo Blidarus, Co-Founder and CEO of FintechOS

Following the launch of the UK’s open banking regime in 2017, the country has built a global reputation for its technical innovation and regulatory prowess. Despite this leadership, the UK has not maintained the level of innovation that kick-started the global rollout of open banking infrastructure. Technology is not our industry’s core challenge; changes to the commercial and liability frameworks that underpin the ecosystem are necessary for further growth.

Earlier this summer, Helen Child, CEO of Open Banking Excellence, announced a pragmatic solution that could lay the foundation for the next stage of open banking expansion by embedding insurance into the open banking liability model. If implemented, this proposal could reduce barriers to building innovative financial products that rely on open banking while increasing public trust in the technology, bringing the UK back to the forefront of the global open banking race.

Liability is an obstacle in open banking

The technical architecture underpinning open banking is robust, currently facilitating secure, consent-driven data sharing between banks and third-party providers, enabling the creation of new products and services across the finance sector. However, the commercial arrangements around liability have not kept pace. Banks and FinTechs shoulder significant risk concerning fraud and cyber breaches, which are too often unevenly distributed and poorly managed, creating barriers to investment and innovation.

Although large banks can absorb this risk, it incurs a considerable capital cost, limiting the scope and reliance on open banking-based financial products and services. The problem is amplified for smaller FinTechs and new entrants, for whom the liability burden is one of the most significant obstacles to scaling. The result is a market where technical capability outstrips commercial viability.

Insurance for all participants 

The core of Helen Child’s proposition is an insurance-backed liability framework that would standardise risk management across the open banking value chain. Enabled by the UK’s world-class insurance sector, this model pools risk and applies risk-based pricing to create capacity and predictability.

The insurance-based approach brings several clear benefits. First, it reduces capital strain on banks by shifting part of the liability risk to insurers. It also levels the playing field for FinTechs, enabling them to innovate without incurring excessive risk. Consumer protection is also strengthened, a crucial factor in building trust with the public and meeting ongoing regulatory requirements.

Best of all, the insurance model aligns incentives across all participants. When risk is priced correctly and managed, each participant has a shared but proportionate interest in maintaining operational resilience and security. This alignment encourages collaboration and supports the development of new services and products built on a stronger, more stable foundation.

Trust through transparency and protection

Support and adoption from the public remain a critical factor in the success of open banking and open finance. Still, recent incidents of inconsistent consumer protection have surfaced significant vulnerabilities in the current framework. Helen Child’s additional suggestion of an industry-backed trust mark, supported by both insurance and accreditation, directly addresses this challenge.

A recognised mark of trust would signal to consumers that a product or service meets high standards for security and liability coverage. Transparency of consumer protection simplifies decision-making for consumers and helps to build confidence in the innovative products possible through an insurance-based open banking model.

This universal, embedded insurance model builds a safety net for consumers of every open banking-based product, guaranteeing protection against unforeseen events. Upon the unfortunate occurrence of fraud or failure, insured parties can offer timely compensation, reducing financial harm and reinforcing confidence in digital financial services.

Heightened relevance amid regulatory trends

The timing of this insurance-backed liability model is particularly relevant. The UK government’s Data (Use and Access) Bill signals an expansion of open banking into open finance, including pensions, insurance, utilities and more. These new use cases increase the complexity and volume of data flows, intensifying the need for scalable and resilient liability arrangements.

Industry initiatives demonstrate what’s possible through collaboration and focused effort, exemplified by the development of commercial variable recurring payments. Establishing an insurance-backed framework can provide the commercial stability needed to support long-term growth and broader adoption, supporting government plans to broaden the usage of open banking infrastructure.

AI-driven risk management through data access

Open banking infrastructure and insurance frameworks lay the groundwork for something bigger: AI-powered risk management. Powered by access to richer, real-time data, insurers can move beyond traditional underwriting and use predictive analytics to assess and manage risk more accurately and proactively.

With expansive data access, AI can identify fraud patterns and personalise products at scale, improving both operational efficiency and the customer experience. The proposed insurance-backed liability model supports these advancements by providing a solid foundation for responsible innovation. With professionally managed and transparent risk, we can build the conditions for data-driven decision-making and embedded finance to grow with confidence.

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