UK vs Europe: Understanding the Differences in Open Banking

What began as a regulatory push has become a global movement: open banking is reshaping financial services. While the goal is the same – giving consumers greater control over their data and driving innovation, delivery varies across countries. APIs provide the foundation, but each market has taken its own path, shaped by local regulations, policy decisions, and technical standards.

For businesses expanding internationally, this brings both opportunities and challenges. Navigating different rules often means working with third-party providers to bridge gaps and standardise access across markets.

We’ll break down how open banking evolved in the UK and the EU – and how Noda makes it easier for businesses to bridge the differences and expand faster across both regions.

Open banking in the UK

The UK’s open banking formally launched in early 2018, though the foundations were laid several years earlier. Following a major review of the retail banking sector in 2016, the Competition and Markets Authority (CMA) concluded that greater competition and transparency were needed to benefit consumers.

In response, the Open Banking Implementation Entity (OBIE) was created. Its role was to develop and manage a common technical standard for how banks should securely share customer account data with licensed third parties through APIs.

Which banks can I access through open banking in the UK?

In the UK, there were initially nine banks signed up for open banking, known as the CMA9. These were: Allied Irish Bank, Bank of Ireland, Barclays, Danske, HSBC, Lloyds Banking Group, Nationwide, RBS Group, and Santander.

Other banks and building societies have joined since, with all participants required to provide secure API access under the Payment Services Regulations (PSRs) of 2017.

How the UK’s open banking standards are different

The UK went a step further than simply meeting PSD2 requirements. Banks had to follow a detailed and prescriptive framework for implementation. Key aspects included:

• Mandatory compliance with a common API standard
• Specific technical and security requirements
• Clear deadlines for delivery

This structured environment led to a more consistent and reliable open banking ecosystem. Payments in the UK typically settle in real time through the Faster Payments network, and strong security features like app-to-app authentication and biometric authorisation are standard practice.

Open banking adoption in the UK

Thanks to this coordinated approach between regulators, banks, and the OBIE, open banking adoption in the UK has accelerated significantly. By February 2025, there were nearly 14 million active open banking users in the UK – a clear indicator of growing trust and usage across consumers and businesses alike.

Open banking in the EU

Open banking in the EU operates under the broader framework of the Revised Payment Services Directive (PSD2). Introduced in 2015 and fully implemented by 2018, PSD2 was designed to strengthen security, modernise payment services, and encourage greater competition across the EU’s financial sector.

Under PSD2, banks are required to allow customers to share their financial data securely with authorised third-party providers. However, unlike in the United Kingdom, PSD2 does not mandate a single technical standard for how banks should deliver this access.

Open banking frameworks across Europe

Instead, several frameworks have been developed to support open banking across Europe, including:

• XS2A (Access to Account)
• STET (widely used in France)
• Berlin Group’s NextGenPSD2 (adopted by many banks across the EU)
• PolishAPI (specifically for the Polish market)

This flexibility allows banks and countries to adapt open banking to local needs, but also adds complexity for third-party providers.

Open banking adoption in the EU

Open banking in the EU is more fragmented compared to the UK. Adoption levels and infrastructure maturity vary significantly between markets:

• In countries like Poland, the Netherlands, and Germany, account-to-account (A2A) payments have strong adoption, supported by well-established local schemes.
• In other markets, such as Denmark, Italy, and France, A2A uptake remains lower, reflecting the slower development of domestic payment options.

As a result, businesses operating across the EU need to navigate a patchwork of technical standards, regulations, and market readiness when offering open banking services.

Difference between UK and EU open banking

Open banking is different in the UK and the EU in several important ways. While both aim to boost innovation and competition, the UK enforces stricter API standards and faster settlement times, while the EU leaves more room for variation between countries.

How is open banking different in the UK and the EU? Put simply:

• The UK’s version of open banking is more standardised, controlled, and uniform.
• The EU’s open banking version is broader, more varied, and shaped by national differences.
• Both are anchored by customer consent and secure data-sharing through APIs.
• In the UK, most open banking payments settle instantly via Faster Payments, while in the EU, instant settlement depends on market adoption of SEPA Instant, with full coverage expected by 2027.

For businesses looking for reliable infrastructure, the UK often offers a faster, smoother rollout. In Europe, success depends heavily on the specific countries being targeted.

What is the future of open banking in the UK?

Open banking has already made a lasting impact on the UK economy, now worth over £4.1 billion and supporting more than 4,800 jobs. In December 2024, active open banking users surged to 12 million, up from around eight million at the end of 2023.

Every month, more consumers and businesses are using open banking products, helped by integrations like Apple’s Wallet app pulling live current account balances.

Looking ahead, the UK is preparing for the next phase: open finance. Regulators are laying the groundwork to expand customer-permissioned access beyond bank accounts to include:

• Savings and investments
• Pensions and mortgages
• Insurance and utilities
• Telecoms and energy accounts

This shift could create a true "smart data economy," giving people better control over all their finances. As adoption grows, improvements to business models, consumer protections, and regulatory oversight are expected to make open banking and open finance a standard part of everyday life, much like contactless payments today.

What is the future of open banking in the EU?

Open banking in the EU is continuing to gain momentum, with user numbers rising sharply over the past few years. In 2020, Europe counted around 12.2 million open banking users. By the end of 2024, that figure had grown to nearly 64 million – a fivefold increase in just four years.

To keep pace, the European Commission is developing new regulations, including the Financial Data Access (FiDA) framework and PSD3. These proposals aim to expand open banking into open finance and create a more standardised environment for digital financial services across Europe.

Several challenges still need to be addressed:

• Legacy systems that delay technical improvements
• Different regulatory approaches across member states
• Gaps in digital investment, especially for smaller banks

At the same time, the use of electronic payments has continued to rise, reaching €240 trillion in transaction value in 2021. This strong shift towards digital finance positions open banking and soon open finance to play a central role in Europe’s financial future.

UK vs EU open banking for businesses

Launching with open banking in the UK

For businesses building on open banking, the UK offers a clear advantage. With a single API standard in place across major banks, launching services is faster, integration is simpler, and customer experiences are more consistent. Businesses can move quickly, without needing to redesign systems for each bank they connect to.

Launching with open banking in the EU

In the European Union, open banking is shaped by PSD2 regulations, but technical standards vary between countries. Frameworks like XS2A, STET, and NextGenPSD2 are widely used, but differences in interpretation and implementation mean businesses often need to adapt their systems market by market. While this adds complexity, it also creates opportunities for tailored services and partnerships across diverse markets.

Opportunities across both regions

Whether operating in the UK or across Europe, open banking opens the door to faster payments, richer customer experiences, and new product opportunities in finance, lending, e-commerce, and more. Businesses that invest early can build stronger connections with customers and offer smarter, more flexible financial services.

Recognising the distinctions between open banking as a global movement, the UK's structured Open Banking initiative, and Europe's PSD2 framework is key for businesses planning their next steps in an increasingly connected financial sector.

How Noda supports your growth

Noda helps businesses simplify payments and unlock new opportunities across the UK and Europe. Our Open Banking payment gateway makes it easy for merchants to integrate direct bank payments, delivering seamless, secure transactions with lower fees.

We offer more than just payments. Noda’s all-in-one platform brings together:

• Advanced Open Banking API for fast, secure direct bank payments
• KYC and payment processing tools to streamline customer onboarding and transactions
• LTV forecasting and UX optimisation to boost user engagement and business growth
• Data Enrichment feature for targeting high-value customers with actionable insights

Today, Noda connects with over 2,000 banks across 28 countries, supporting 30,000+ bank branches and a wide range of currencies for global businesses. Our scalable plans are built to grow with you, helping you stay ahead in a fast-moving open banking world.

Transform the way you pay, get paid, and grow — with Noda powering your next move.