(4 min read)
The FCA has recently published a report summarising outputs from its mortgages and open finance policy sprint, which examined how open finance could improve mortgage journeys. The sprint outputs show that the debate has moved far beyond whether open finance could improve mortgage journeys and is instead focused on the enabling conditions. Although the report makes no formal recommendations or rules, it provides a clear indication of the direction of future regulatory expectations.
Introduction
On 3 September 2026, the Financial Conduct Authority (FCA) published a report summarising outputs from the FCA’s mortgages and open finance policy sprint, which examined how open finance could improve mortgage journeys. The report sits within the FCA’s wider Open Finance Roadmap, and mortgages were chosen deliberately as the test case. The sprint outputs show that the debate has moved far beyond whether open finance could improve mortgage journeys and is instead focused on the enabling conditions. Teams identified the specific data that could support different mortgage journeys and considered how it might be structured so that firms could rely on it. They developed commercial model options including proposals for basic access, enhanced services and cost recovery. They also explored conditions that could support adoption including commercial incentives, broader participation and areas where some participants considered that regulatory or other intervention might need to be considered. Although the report makes no formal recommendations or rules, it provides a clear indication of the direction of future regulatory expectations.
Inside the sprint
The sprint took place on 8 and 9 June 2026 and involved around 80 stakeholders, including banks, building societies, fintechs, third-party providers, credit reference agencies, property experts, trade bodies, academia and consumer organisations. Participants worked in mixed teams using fictional personas to test mortgage lifecycle use cases, from preparation through to later-life decisions like equity release.
Why mortgages
Mortgages were chosen deliberately as the test case as they are a significant financial commitment that depends on a wide range of evidence over time. Much of that information is scattered and held across different organisations. Therefore, a mortgage decision is often a decision made from many partial pictures stitched together, often by the consumer themselves. Consumers are, in effect, gathering and interpreting it themselves i.e., repeating information, re-explaining changed circumstances, and shouldering the burden created by a lack of shared infrastructure to verify and rely on data across institutions. The sprint examined whether open finance could change this position by enabling consumers to share relevant information more safely, consistently and efficiently.
Key themes that emerged from the sprint
- Data must be usable as trusted evidence: Participants stressed that the problem is not just that data doesn’t move between organisations. Even when data can be shared, there is no reliable infrastructure to check its source, accuracy or evidential status in a way lenders can trust and use for consumers’ benefit. Open finance must therefore provide both access to data and the standards, checks and accountability needed for lenders to rely on that information in mortgage journeys. Participants described this as “decision-grade data”.
- Infrastructure and interoperability needed: Participants said that future proof infrastructure is essential for adoption. They suggested interoperable data sharing interfaces (likely using APIs), along with standard data formats and digital systems for verification, authentication and certification.
- Participation may need to be compulsory: Participants raised concerns that incomplete participation could leave gaps in consumer journeys and limit the overall value of open finance. The report floats mandating as a live possibility, which could mean regulatory intervention, legislation or another mechanism to require key organisations to participate, make specified data available, or follow common standards and scheme rules prescribing governance, accountability and liability arrangements that should apply.
- Commercial sustainability matters: Preference was shown towards a layered commercial model in which common standards and a minimum mortgage-relevant dataset would support consistent access, while firms compete through enhanced services and analytics.
- Accountability needs to be resolved: Accountability questions raised repeatedly i.e., if a lending decision is made on shared data that turns out to be wrong, who is liable? The originating institution, the platform, or the lender relying on it? It was suggested that clear and proportionate liability arrangements could encourage participation across the ecosystem by reducing uncertainty around accountability and providing firms with greater confidence to rely on shared data, infrastructure and services.
- The relevant risks need to be recognised and mitigated: The sprint surfaced questions on possible risks including where the boundary sits between information-sharing and regulated advice, ‘consent scope creep’ (data shared for one purpose being used for another), embedded bias in automated decisions, digital exclusion for less tech-enabled customers, and weak redress mechanisms.
Where this is heading
Although the FCA has not made any recommendations, it has named the building blocks it expects future policy to be built from. These include:
- Use-case-led data standards that define the minimum data needed for specific mortgage journeys (e.g. decision in principle, affordability assessment, remortgage);
- Interoperable data-sharing interfaces, likely to include APIs that allow different systems (lenders, brokers, platforms) to connect seamlessly;
- A consent and permission framework capturing consumer consent in a clear, granular way and covering one-off and ongoing access;
- Digital verification mechanisms so participants can confirm that data belongs to the consumer and can rely on it without repeated manual checks;
- A governance model that defines participant roles, standards, performance expectations, liability and redress;
- Commercial arrangements that make participation viable for data holders, lenders, intermediaries, smaller firms and consumer-facing service providers; and
- Safeguards for fairness, explainability, challenge and human review where data contributes to personalised or automated outcomes.
The FCA has said that the insights generated through this policy sprint will contribute to a discussion paper on the key enablers for open finance. The findings will also feed into the FCA's Smart Data Accelerator's next phase of work, which will dig into the architecture for data sharing and what trust infrastructure is needed and how all of this connects with agentic AI.
What this means for firms
Firms that move early and treat this as more than a narrow compliance exercise will be better placed to use trustworthy data‑sharing capability to support their position as open finance develops. Firms may therefore want to consider taking some early steps including: mapping regulatory gaps between current systems and future expectations (especially if participation becomes mandatory), designing contracts that clearly allocate liability for ‘decision‑grade’ data across originators, intermediaries and lenders, building consent architectures that withstand both data protection and financial regulation scrutiny, and aligning commercial models with legal risk allocation.
Next steps
We’re here to help you navigate these changes. To explore how the Government’s policy may impact your organisation, discuss strategic engagement with upcoming consultations, or seek expert support in planning for the new regulatory regime, please contact our Financial Regulation team.
