英国はオープンバンキングを立ち上げる方法は示しているが、その後の長期的なビジョンは示していない。

The latest open banking performance figures show why the UK is rightly seen as one of the early success stories in this space. It also highlights several important lessons for regulators, banks and fintechs to consider in shaping their open finance strategies.

The headline is that open banking adoption by UK customers continues to build. The most recent Impact Report from the Open Banking Implementation Entity (OBIE) suggests that there were 5.8 million consumer and 700,000 business users of open banking in December 2022, marking another important milestone in the development of the ecosystem.

These headline figures are significant, and there are three further themes to highlight.

1. Small business is a key customer segment for open banking

In December 2022, an estimated 10-11% of digitally enabled retail and small business customers in the UK were reported to have used open banking at least once. This means that they used an open banking-enabled service or a workflow that involves open banking in some way (such as a loan application). This number is based on data provided by the CMA9 banks (the nine institutions subject to the UK’s domestic open banking regulation) and is broadly representative of the total population. On a consistent basis, this grown from an estimated 9-10% in March 2022.

Adoption is highest among small business customers, reflecting the impact that open banking can have in delivering value to this customer group. Around 16% used an open banking-enabled service or workflow in December 2022 (equal to around 700,000 businesses), compared to just over 10% of retail customers. In part this reflects the range of small business use cases (something discussed at length in the Celent report: Using Open Banking to Build Stronger SME Propositions) as well as the degree to which open banking can be used to address a range of operational pain points for business users.

2. Data-led use cases dominate API volumes

The OBIE provides some directional analysis on the most common use cases, and the majority relate to the relatively straightforward use of transaction data to remove manual data entry or aggregate accounts.

Around 90% of API calls to small business accounts relate to ‘financial decision making’ which are led by connections to online accounting platforms or account aggregation services. It is not surprising to see this use case dominate API traffic, as a single instance can generate multiple calls per day (to pull in the latest transaction data). Around 600,000 businesses are estimated to have used this feature in December 2022, suggesting plenty of untapped opportunity yet in the market.

Among consumers, there is a more even split between data and payment use cases. The OBIE estimates that 3.5 million consumers used a service or workflow supported by an account information API call in December 2022, compared to 2.8 million that initiated at least one payment (implying that a small proportion of consumers did both).

Lending has become a very important area within the spread of use cases for open banking, and accounts for around 24% of account information API calls in the UK. Clearly the opportunities to use open banking to help lenders to enhance their user experience and operational efficiency are becoming more widely understood. However, and as with the small business segment, financial management (such as PFM apps) is the biggest single area for the use of account data, and accounts for around 47% of API calls.

3. Payments initiated by open banking API will grow strongly where available

Payments is one of the most important use cases for open banking in Europe and there were 41.2 million payments initiated via open banking API in the UK 2022. This has grown by 154% compared to 2021 and demonstrates the degree to which businesses are growing comfortable in offering this as an option to customers. For context, the 7.7 million payments initiated in December 2022 is equal to around 2.8% of the total flow through the UK’s domestic real-time payment infrastructure.

Adoption is being driven largely by consumer payments to businesses, and the leading use case is account top-ups, such as making payments to wallets, deposit, or investment accounts. According to the OBIE’s estimates, this accounts for around 53% of the number of payments initiated. Banks are also an important customer of open banking services, using the payment initiation workflow to replace inbound payments for customer credit card bills made via cash, cheque, or other payment tools. In December 2022, 29% of payments initiated via API were for this purpose.

Open banking payments for other goods and services, such as digital commerce, account for around 14% of API calls. This represents a clear opportunity for growth, particularly if non-sweeping variable recurring payment services become commercially available from a wider pool of banks.

Payment initiation accounts for around 10% of the API calls on small business accounts, and the OBIE estimates that around 100,000 used this feature in December 2022. It’s worth noting that this should reflect only payments made from small business accounts though, rather than those received by business customers from consumers.

A long term vision is required to stimulate investment and innovation

The UK experience offers some important lessons to regulators, banks and other ecosystem players embarking on their own open finance initiatives.

The first is that a strong regulatory emphasis on ensuring delivery is essential. Several factors have driven the success to date in the UK, but one of the most important has been the existence of a body (in this case the Open Banking Implementation Entity) with a focus on delivering the fundamental building blocks required for this new ecosystem to thrive. Work around API standards, performance and reporting, consistency in the customer experience, and creating a framework for identifying changes to unlock improvements for stakeholders has been invaluable to the initial rollout of open banking in the UK.

However, the UK is also at a critical juncture and the lack of a clear long-term vision poses a risk to further activity. With the initial open banking roadmap now complete, the future direction of UK open banking is up is unclear while the Joint Regulatory Oversight Committee (comprising the Payment Systems Regulator, Competition and Markets Authority, and Financial Conduct Authority) work to determine what will come next.

This is a clear contrast to many newer initiatives, such as those in Australia or Brazil, which are more expansive than the UK for example. In turn EU regulators are working on an ambitious agenda for open finance and new payment services via SPAA (the Sepa Payment Account Access scheme). In this wider context, the future path set out by JROC will ultimately determine whether the UK can once again be seen as a leader in open banking and finance.