What the UK’s Smart Data 2035 strategy means for open finance risk management infrastructure – and who is building it.
The UK government published its Smart Data 2035 strategy in March 2026. Twenty or more interoperable smart data schemes by 2035. GDP contributions of £9.6 billion annually by 2043 from just four schemes. A long-term regulatory framework for Open Banking under the Data Use and Access Act. A refreshed Smart Data Council. A cross-sector Guidebook by 2027.
It is, by any measure, a serious strategy.
Invela is building the open finance risk management infrastructure – accreditation, real-time risk monitoring, and financial accountability – that makes it work in practice. Here is what that means.
What the strategy gets right
The government has understood something that took open banking a decade to learn: data access is not the same as data trust.
Connecting consumers, banks, aggregators, and third-party providers is the easy part. What makes the system work – what makes it safe, sustainable, and scalable – is what happens around the connection. The accreditation that verifies who is in the network. The monitoring that tracks how participants behave once they are in it. The accountability framework that ensures liability lands in the right place when something goes wrong.
Smart Data 2035 names all three as requirements. It defines accreditation as the process of confirming that organisations meet “the required governance, security and technical standards to participate in the trust framework.” It describes real-time risk monitoring as central to how smart data schemes will operate. It acknowledges consumer redress and accountability mechanisms as foundational to public trust.
That is exactly the right framing. The question is who builds it.
What the strategy leaves open
The document is candid about what it does not yet resolve. Consumer redress is defined as “mechanisms for resolving disputes or harms arising from smart data sharing” – but the question of how liability is allocated across a multi-party chain, between data holders, aggregators, and third-party providers, is not settled. It points to regulators and courts.
That is not a financial backstop. It is a process.
Open Banking Limited now records more than 2 billion monthly API calls across the UK. There are over 230 FCA-regulated third-party providers connecting into UK financial institutions. When something goes wrong in that chain today – and things do go wrong – there is no pre-agreed framework for who absorbs the cost. Contracts do not resolve it. Regulation does not resolve it. The bank – and the consumer – just absorb the damage.
Open Finance will be larger. Smart Data 2035 extends those same principles across energy, property, retail, telecoms, and beyond. The liability question does not get easier as the network grows.
What open finance risk management infrastructure actually looks like
Invela is building across three integrated layers – because the problem requires all three.
Accreditation. A consistent, verifiable process for confirming that every participant in the Invela Network meets a baseline standard before they connect. Not bilateral due diligence, replicated independently by every institution for every third party. A shared standard, applied once, trusted by all. Invela Accreditation embeds validated assessments performed by S&P Global into the process.
The Invela Risk Indicator. Continuous, real-time monitoring of participant risk profiles across the network. Accreditation at the point of entry is necessary – but it is not sufficient. The risk profile of a third-party provider changes over time. The network needs to see those changes as they happen, not six months later when the next audit cycle runs.
Insurance-backed Warranty. The financial backstop the current framework lacks. The Invela Warranty – in development – will provide the financial backstop that ensures when something goes wrong, liability lands in the right place rather than being disputed for years.
This is what Smart Data 2035 is calling for, in operational terms. A trust framework that goes beyond rules and standards to include verified participants, real-time risk visibility, and financial accountability.
Why the UK moment matters
The government has committed £36 million over four years. It has legislative powers under the Data Use and Access Act to mandate participation. It has a clear timeline: five or more active schemes by 2030, twenty or more by 2035.
The UK was first to market with open banking. It has the regulatory architecture, the fintech market, and now the legislative framework to lead on open finance. But first-mover advantage in policy does not automatically translate into first-mover advantage in markets.
What determines whether that potential is realised is whether the infrastructure is in place before the volume arrives.
Invela operates across the US, UK, and Canada. We have watched what happens when open finance scales without the risk management layer in place. The costs are real. The accountability gaps are structural. And they do not resolve themselves.
Smart Data 2035 sets the direction.
We’re building the infrastructure.
Open Finance, Covered.
