On September 29, the Financial Conduct Authority's (FCA) Smart Data Accelerator published new research on how open finance infrastructure should be built in the United Kingdom. The research was commissioned from Saïd Business School at the University of Oxford and Raidiam Services, and it compares three model families: a fully centralised approach, a fully decentralised or federated approach, and a hybrid of the two. The paper is written by the Accelerator's own team, and it states its purpose as explaining their emerging thinking.

The research draws on four international examples: the United Arab Emirates (UAE), whose centralised trust framework and application programming interface (API) hub reduce fragmentation at the cost of concentration risk; Australia's Consumer Data Right and Brazil's open finance framework, both hybrid systems that pair central accreditation with distributed data exchange; and the European Union's Second Payment Services Directive (PSD2), which created a legal right to data access but left technical implementation fragmented across markets.

The research argues that no pure model fits the United Kingdom. A hybrid model, one that centralises the functions where consistency matters most (accreditation, participant status, trust metadata, conformance, monitoring, and revocation) while leaving data custody, APIs, and customer journeys distributed across firms and sectors, is, in its own words, “a credible proposition for further testing.”

Industry has a part to play

The paper does not name a vendor, and a model preference in a research note is not an endorsement of any single provider. But the list of functions it flags as candidates for central coordination, accreditation, trust metadata, conformance, monitoring, and revocation, does not describe infrastructure that has to be built from scratch. Standardised accreditation that vets a participant's risk once rather than every institution repeating the exercise separately, continuous rather than annual risk monitoring, and a liability mechanism that settles in advance where responsibility sits, already exist as commercial capability in the market today. The research is making the case, at the level of national infrastructure, for a services commercial providers are already applying at the network level: centralise trust and assurance, leave data and execution distributed.

The same problem, seen from two perspectives

This is not a coincidence of language. It is the same problem, seen from two perspectives. The FCA is asking which functions an ecosystem needs to hold in common so fragmentation does not undermine trust. Invela was built to answer that question for the commercial layer: who is accredited, what their risk looks like right now, and who is on the hook when something goes wrong.

The gap that matters most: agents

The research does not stop at today's participants. It treats artificial intelligence (AI) as a design constraint for the infrastructure, not a future problem to defer. As AI-enabled services begin interpreting data from multiple providers, making recommendations, and potentially taking action on behalf of consumers and firms, the paper argues that interoperable identity, delegation, monitoring, and revocation become more important, not less.

What happens next

The next phase of the Smart Data Accelerator's work will test the reference architecture through practical use cases, including how authority is delegated to an AI-enabled service, interpreted across institutions, and withdrawn by a consumer. The full research note is worth reading directly, not because it delivers conclusions, but because it asks the right questions in the right order: which functions require common coordination, and which should stay distributed.

Open finance is scaling toward agentic use cases at light speed. The FCA's research puts a name and a shape to the trust layer that scaling requires. Building it is the next job.

Invela is the infrastructure layer that makes open finance trustworthy - accrediting who's in the network, monitoring risk in real time, and ensuring liability lands in the right place.

‍