Open Banking Expo 2026

Visibility before pain

UKPI, NatWest and the FCA debate who pays when open finance goes wrong in the UK, and what changes now AI agents are in the chain.

Visibility before pain

Three points from the debate.

The FCA doesn't yet have an answer on liability

Its Smart Data Accelerator will test roles with industry in the coming months. Until then, the customer calls the bank, whichever entity in the chain caused the problem.

The FCA doesn't yet have an answer on liability
A scheme and a bank proposed the same fix

A scheme and a bank proposed the same fix

UKPI wants the stalled data audit trail work revisited, and NatWest would make transaction risk indicators a prerequisite. Both come back to one point: you can't price what you can't see.

AI agents are in the chain before liability is resolved

The FCA called identity and consent the mechanisms for understanding agent risk and liability, and asked whether an agent's purpose can drift as it learns.

AI agents are in the chain before liability is resolved

Open Banking Expo 2026

Visibility before pain

13pages
16min read
Open Banking Expo 2026

Published

Updated

Download the white paper

Contents

  1. Executive summaryp. 2
  2. Who pays when an open finance chain breaks?p. 4
  3. Can banks see their exposure past the first hop?p. 5
  4. Is open finance risk priced correctly?p. 6
  5. Who is responsible when an AI agent acts in the chain?p. 7
  6. How mature is open finance risk management in the UK?p. 9
  7. Conclusionp. 11
  8. Open finance liability readiness checklistp. 12

Frequently asked questions

Who is liable when open finance goes wrong in the UK?

Liability for open finance data sharing is not yet defined in UK regulation. For payments, NatWest's Stephen Wright said liability already follows the party controlling the activity. In practice, customers call their bank first, whichever entity in the chain caused the problem.

Who is responsible when an AI agent acts for a customer?

No UK rule yet defines who consents, who is authorised or who is liable when an AI agent acts in an open finance chain. The FCA's Smart Data Accelerator is adding agents to its testing with industry.

What are transaction risk indicators?

Transaction risk indicators are metadata that travel with a payment or data share, showing its purpose, its recipient and who to contact. NatWest's Stephen Wright argued they should be a prerequisite for open finance.

Read the full white paper

13pages ·16min read ·Open Banking Expo 2026

Download the white paper