Karsten Wenzlaff, Advisor
August 26th, 2025
Karsten Wenzlaff is a Crowdfunding and Fintech Expert from Germany. He is Secretary-General of Digit[...]
Smart Data Infrastructure Redefines Financial Competition
Apr 8, 2026 | NCFA Feature | Open Banking Open Finance And Data Sharing
Data Infrastructure, Not Apps, Defines Competitive Advantage
On March 26, 2026, the UK Smart Data Strategy 2035 and the DRCF Smart Data Frameworks reports were published confirming that the UK's data sharing strategy is moving beyond banking into a cross sector system that covers finance, energy, telecoms, retail, property, transport, and more. The UK is planning to build it into national economic infrastructure.
The UK strategy estimates that just four smart data schemes could generate £71.2 billion in net social value from 2028 to 2043 and contribute £9.6 billion in annual GDP by 2043. It also sets a target of 5 or more active schemes by 2030 and 20 or more by 2035, backed by at least £36 million of public investment over four years. That puts smart data alongside AI, digital identity, and payments as part of the infrastructure layer that will determine how the next economy works.
This is not about better apps. It is about who controls access to data across the economy.
Open Banking Proves The Model
Open Banking already shows what happens when data becomes portable. The UK now has more than 17 million active consumers and businesses using Open Banking and processes more than 2 billion API calls a month. It's plain evidence that once standards, rules, and trust are in place, consumer and business behaviour changes.
See: UK Open Banking Update and Road to Open Finance
The UK now wants a connected system where data can move securely across sectors and support better switching, lower costs, stronger competition, and more tailored services. Once that happens, the data driven moat around financial services starts to break down. Financial data can be combined with energy usage, telecom activity, property records, identity, and business data to support new products and new operating models.
Three Global Models Are Now Competing
The DRCF report lays out three distinct models now emerging globally.
The first is the regulator mandated model. Australia and Brazil are the clearest examples. This approach forces participation, sets standards, and can create rapid ecosystem scale. Brazil shows what that looks like. The report says Brazil’s Open Finance system had onboarded more than 940 institutions, served 40 million customers, processed more than 100 billion API calls, and managed more than 60 million active consents by 2024.
But scale alone does not guarantee success. Australia’s Consumer Data Right shows the other side of the model. The DRCF report points to high compliance costs, data quality issues, weak consumer awareness, and limited use. One review cited in the report found uptake at just 0.31% of Australian customers. That is the warning for policymakers everywhere. Mandating infrastructure is not the same as creating compelling use cases.
The second is the market facilitated model, seen in the United States and Japan. This approach allows industry to move first and can encourage experimentation. It also creates fragmentation, uneven standards, and uncertainty over liability, consent, and pricing. In the United States, the DRCF report shows how quickly a market led system can tilt back toward incumbents when access rules are unsettled and pricing power becomes a commercial negotiation.
The third is the public infrastructure led model, seen most clearly in Estonia and Singapore. These systems are built on trusted digital identity and shared national rails. That reduces friction because identity, consent, and data access work together from the start. Singapore’s SGFinDex shows the commercial upside of that approach. By the end of 2024 it had grown to more than 400,000 users, built on Singpass and a central consent architecture that gives users a consolidated view of financial data.
The third is the public infrastructure led model, seen most clearly in Estonia and Singapore. These systems are built on trusted digital identity and shared national rails. That reduces friction because identity, consent, and data access work together from the start. Singapore’s SGFinDex shows the commercial upside of that approach. By the end of 2024 it had grown to more than 400,000 users, built on Singpass and a central consent architecture that gives users a consolidated view of financial data.
This model also shows up in markets building broader digital infrastructure stacks. India’s digital public infrastructure model combines identity, payments, and data layers at national scale, showing how shared rails can support faster adoption and wider service integration across sectors.
The best approach isn't the one with the best regulation. It'll be the one with the best interoperability.
Interoperability Control Point
The strongest line in the UK strategy document isn't sector expansion on its own. It is the push for cross sector coordination. The government plans a Smart Data Guidebook by early 2027, a refreshed Smart Data Council, future consultation on long term governance, and stronger links to digital identity, AI, the National Data Library, and trade digitization.
See: UK FCA Palantir Trial Puts Regulator Data At Risk
And it makes perfect sense given that siloed data schemes don't create a true data economy, they create compliance burden. Advantages are realized when data can move cleanly across sectors and support services that aren't stuck inside one scheme or industry.
If interoperability fails, smart data becomes compliance. If it works, it becomes infrastructure.
That's why the UK is treating smart data as national economic infrastructure. Cross sector data improves core financial functions such as affordability assessment, underwriting, and fraud detection, while enabling real time switching, automated reporting, and AI tools that act on behalf of consumers and SMEs with better insight and cleaner data.
Property And Energy
The UK strategy a sector specific example. In energy, the government says a smart data scheme could generate £9.5 billion in net social value between 2028 and 2043 and contribute £2.1 billion in GDP by 2043. In property, where the average home transaction still takes 120 days after an offer is accepted and about one in three transactions fail, the strategy cites modelling that suggests a homebuying smart data scheme could generate around £28.7 billion in net social value and £4.2 billion in annual GDP impact by 2043, depending on implementation.
For fintechs this is where financial services can embed into wider data flows. Mortgage journeys, affordability checks, insurance, transaction verification, and SME finance are all inside those ecosystems.
The biggest fintech opportunities may sit in data problems outside finance.
Consent And Trust Impact Adoption
Smart Data succeeds when users trust the consent controls and can see a clear benefit in saying yes. The DRCF report highlights the point well. Brazil’s experience shows how poorly framed consent can damage trust and expose systems to misuse. India’s Account Aggregator framework points in a better direction, using regulated consent managers that are data blind and focused on facilitating transfer rather than exploiting the data itself.
Trust isn't a compliance feature. It is a growth driver.
See: Open letter to the Honourable Mélanie Joly, Minister responsible for Statistics Canada
If users don't understand or feel comfortable with the legal design and consent flow, adoption stalls. If they do, entirely new categories of service become commercially viable. It's key for onboarding, conversion, and revenue and also for privacy law.
Canada Enters Implementation With A Strategic Choice Ahead
Canada is no longer just progressing toward Open Banking. Bill C-15 received Royal Assent on March 26, 2026, enacting the revised Consumer-Driven Banking Act and advancing Canada from framework design into implementation. The next steps now sit in regulation, technical standards, and launch preparation.
It now has the legal foundation for consumer-driven banking, with the Bank of Canada taking the oversight role for the framework while the Department of Finance continues policy and regulatory development.
Canada has already positioned consumer-driven banking as the first layer of a broader data mobility system. The federal framework says it will be the first iteration of an economy-wide right to data mobility in sectors that develop secure and interoperable frameworks, while a second phase will examine broader functionality and participant scope, including write access.
The real strategic question is not direction. It is design timing.
Canada can implement a narrower banking framework first and extend it later, or it can build interoperability, identity, and governance with a broader Smart Data system in mind from the start. That choice will determine how quickly Canada can evolve from consumer-driven banking into open finance and wider cross sector data mobility.
Why This Changes How Fintechs Compete
Smart Data benefits companies that can use permissioned data better than everyone else. That changes how fintechs think about distribution, underwriting, payments, financial advice, fraud controls, and AI.
See: Canada’s Artemis II Moment Challenges How We Build
Lenders gain richer inputs for decisioning. Payment firms gain new rails tied to identity and consent. Wealth and financial wellness firms gain more insight for aggregation and guidance. AI driven services gain access to cleaner, structured, permissioned data inside trust frameworks that users can understand and control.
Data access becomes the new distribution layer.
Incumbents still hold large datasets and strong customer relationships. But once data becomes portable, that advantage weakens if it's not matched by better service, lower friction, and stronger execution.
Conclusion
Open Banking proved that consented data sharing can change financial services. Smart Data raises the stakes by extending that logic across the wider economy and tying it directly to growth, AI, and national competitiveness.
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