Open Banking 2026: UK, EU, US Rule 1033 and India's Account Aggregator

Open banking rests on a simple idea: your financial data belongs to you, and you should be able to tell your bank to share it with another company you trust. Four major economies have tried to put that idea into law. They took very different routes, and in 2026 their results are diverging fast. One passed a billion payments, one is rewriting its rulebook, one is stuck in court and one quietly built the largest consent system of the lot.

What open banking actually does

There are two halves. The first is data access: with your permission, a budgeting app, lender or accountant can read your account balances and transactions through a secure connection instead of asking for your password or a stack of PDF statements. The second is payment initiation: a third party can trigger a bank transfer from your account, again with your consent, which lets merchants take payment directly from bank accounts instead of cards.

The value is in what that enables. A small business owner in Manchester can get a loan decision in minutes because the lender reads real cash flow. A customer can pay a utility bill by bank transfer with two taps. A freelancer can see accounts from three banks in one app.

The UK: payments are the breakout

The UK started in 2018, when the competition regulator ordered the nine largest banks to build standard APIs. In July 2026, Open Banking Limited said the system had passed one billion open banking payments and 100 billion API calls since launch, with 40.16 million payments in June 2026 alone, as Open Banking Expo reported. More than 16 million people used open banking services in 2025, and payments grew 53% year on year, according to Payment Expert.

The next step is commercial variable recurring payments, which let a customer authorise a merchant to pull varying amounts within limits, much like a card on file but over bank rails. A scheme backed by 31 firms was expected to make its first live payments in early 2026. If it works, it gives UK billers a real alternative to cards and direct debits.

The EU: PSD2 grows up

The EU's second Payment Services Directive created open banking rights across the bloc from 2018, but implementation was uneven. Each bank built its own interface, quality varied, and some made the consent flow so clunky that customers gave up. In November 2025, EU lawmakers reached a provisional agreement on a new Payment Services Regulation and PSD3, according to Taylor Wessing.

The package gives customers a dashboard to see and revoke the data permissions they have granted, lists barriers banks may not put in front of licensed providers and extends name-matching checks. It also shifts more fraud liability onto providers, including full refunds for some impersonation scams. A transition period of about 21 months is expected once texts are final. A separate framework for wider financial data sharing has moved more slowly.

The US: a rule in limbo

The US has had open banking in practice for years, built on screen scraping and private deals between banks and aggregators. In October 2024 the Consumer Financial Protection Bureau finalised a rule under Section 1033 of the Dodd-Frank Act requiring banks to share data with authorised third parties, generally free of charge.

It has not taken effect. Bank groups sued, the CFPB itself told the court in 2025 that it viewed the rule as unlawful, and a federal court paused enforcement while the agency reconsiders, according to a status tracker. The first compliance date of April 2026 passed without effect. In August 2026 the CFPB sent a new proposed rule to the White House regulatory office for review, Consumer Finance Monitor reported. The central fight is whether banks may charge fees for data access. Some large banks have already begun charging aggregators commercially.

Open banking succeeds when someone builds the pipes for everyone. It stalls when every bank negotiates its own toll.

India: consent as infrastructure

India took a different approach. Rather than ordering banks to open APIs to any fintech, the RBI created a new type of regulated entity, the Account Aggregator, whose only job is to carry encrypted data between institutions with the customer's consent. The aggregator cannot read or store the data. It is a consent manager and a pipe.

The scale is now large. A Sahamati report from June 2026 said the ecosystem had passed 45 crore (450 million) cumulative consents, with more than 7 lakh consents a day in FY26, and had facilitated nearly 3.8 crore financial services such as loans and investments, IANS reported. Personal finance management users reached 5.96 crore.

Lending drove the early growth. Non-bank lenders use aggregated bank statements to underwrite borrowers with thin credit files. It sits alongside India's other public rails, including UPI and Bharat Connect, as part of a deliberate national stack.

The design has a trade-off. Because every institution must connect through licensed aggregators and follow common technical standards, onboarding can be slow, and some banks have had high failure rates when responding to data requests. But the consent artefact, a machine-readable record of exactly what was shared, for how long and for what purpose, is a feature other markets are now studying closely.

Four models side by side

Market	Legal basis	Status in 2026	Strongest use
UK	Competition order (2017), PSD2	Live, moving to commercial VRPs	Account-to-account payments
EU	PSD2, PSR/PSD3 agreed Nov 2025	Live, rules being upgraded	Data access, payments growing
US	CFPB Section 1033 rule (2024)	Enjoined, being rewritten	Private aggregator deals
India	RBI Account Aggregator framework	Live at national scale	Lending and data sharing

What it means for payments

Open banking's biggest long-term effect may be on how people pay bills and merchants. Bank-to-bank payments initiated through open banking are cheaper for merchants than cards and settle on instant rails where they exist. That is why the UK and EU are pushing variable recurring payments, and why the US fight over data fees matters well beyond budgeting apps. For a look at how this could change household bills, see the future of bill payments.

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