FinTechTalk: Embedded finance – adapting to changing expectations

On 16 September 2025, FinTechTalk host Charles Orton-Jones was joined by Lauren Jones, Open Banking Lead, Paylume; andCraig Greenhouse, Principal Consultant, Opendata Consult Ltd.

 

\Where are we with open banking? 

In the UK, Open Banking (OB) started with the CMA9 being mandated to share customer data securely. Generally speaking, in the UK and Europe, the standards of open banking are rather strict and the uptake is relatively low: currently, there are about 9 million people that regularly use some OB service. First adopters were followed by other countries – Brazil, Australia – while the US is still in limbo about adoption. OB is an enabler of embedded finance but not the only one. However, the US and the UK have already had some form of OB for the last 20 years.

 

What we mean by OB in the modern sense of the word, though is large regulated, mostly API-driven, safe and secure data sharing. Today, there are about 80 countries globally either with live OB systems or with one in the pipeline. The schemes vary but there are some common themes in adoption, some of which the UK can also look at for best practice.  

 

OB gives the client control over their data, who can share it with various financial providers. While in the UK there was a competition remedy agenda to OB, the driver in other countries has been, among others, innovation, security or financial inclusion. Industrial use cases, like the Emirates Airline adopting OB for payments are key to mass adoption.  

 

OB-enabled embedded finance 

Open banking is only one of the enablers of embedded finance. OB’s push payment and account information sharing capabilities, however, make it particularly well-suited to embedded finance. The best use cases of embedded finance include AI and advanced data analytics too in addition to OB. Fastest adoption is taking place in the credit space – Experian, for example, has been enhancing its credit bureau with OB data. In the UK, the shift from open banking to open finance is happening really slowly.  

 

OB can be seen as an enabler for real-time credit scoring, a technique that embedded finance providers use extensively to decide whether to make a loan or insurance to clients. In the UK, FCA approval for TPPs takes long – the way around which is to use an aggregator or Bank-as-a-Service – the latter coming with limited functionality. In the UK, there are also a number of legislative hurdles to open finance. Moreover, the system is still based on bilateral connections between individual fintechs and banks.

 

Among the countries that have adopted OB, Switzerland’s implementation stands out – a highly centralised, industry-driven system with banks on the one side and fintechs on the other, which is highly commercialised. AI, vibe coding and tools like Curser can be handy with making small snippets of code on highly regulated markets like the UK –  but not for anything more than a few hundred lines. Meanwhile, developers in Asia seem to be much more open to using AI at the core of their solutions.  

 

The panellists’ insights 

• As UK standards are strict, it’s hard to turn them into a working product.  
• The UK is doing the best in making banks compliant, flagging up banks that underperform or have a high API response time.  
• Hong-Kong’s scheme can serve as model as far as educating the public on OB is concerned. They set up a communications group within the implementation, which shaped a central narrative about the project about what makes information sharing secure.