Open Banking 2.0: How the Second Wave Is Turning Data Sharing into a Revenue Engine

The first wave of open banking was, for most financial institutions, a compliance exercise. Connect the APIs, satisfy the regulator, minimise the disruption to existing business. The firms that approached it this way are now watching competitors who took a different view - who saw mandated data sharing not as a cost but as infrastructure for new revenue - pull decisively ahead.

Open banking 2.0 is the commercial phase. The infrastructure built under regulatory mandate is being repurposed, extended, and monetised in ways that are creating genuine competitive differentiation. And the scope is expanding: open finance frameworks that extend data portability to mortgages, investments, pensions, and insurance are arriving across Europe, the United Kingdom, Australia, and Latin America in 2026, multiplying the commercial surface area of the opportunity.

From Compliance to Commercial Infrastructure

The fundamental insight that separates the firms winning in open banking from those that are merely compliant is this: customer financial data, accessed with consent and processed with intelligence, is among the most valuable information in the world for understanding financial behaviour, assessing risk, and identifying unmet needs.

Firms that built their open banking infrastructure as a compliance minimum - an API endpoint that satisfies the regulator - have data that flows through their systems without being captured, analysed, or acted on. Firms that built their infrastructure as a data platform have a continuously refreshed view of their customers' financial lives: where else they hold accounts, what they spend, what their income patterns look like, how their financial position is changing.

This data advantage is not theoretical. It is being operationalised in 2026 in credit assessment models that use transactional data to underwrite borrowers who have thin or no credit bureau history, in personalised financial management tools that identify opportunities to save or invest based on real spending patterns, and in product recommendation engines that surface the right product to the right customer at the right moment in their financial journey.

The Account-to-Account Payments Acceleration

One of the most commercially significant dimensions of open banking 2.0 is the acceleration of account-to-account payments. The combination of open banking infrastructure, real-time payment rails, and variable recurring payment frameworks is enabling a new generation of payment products that bypass card networks entirely.

For merchants, account-to-account payments offer lower transaction costs than card payments, immediate settlement, and reduced fraud risk. For banks, the threat is the potential erosion of interchange revenue from debit and credit card transactions. For payment service providers, account-to-account payments represent either a significant opportunity - if they can build the orchestration layer that makes A2A payments seamless across merchants - or a significant threat if card-centric revenue models are not diversified.

The 2026 acceleration of account-to-account payments is being driven by the UK's open banking payment infrastructure, which has reached sufficient merchant and consumer adoption to create genuine network effects, and by the extension of similar frameworks across the EU under the Payment Services Regulation.

The Consent and Trust Architecture

The commercial potential of open banking 2.0 depends critically on consumer trust. The data that creates the most value - a complete picture of a consumer's financial life across multiple institutions - is also the data that consumers are most sensitive about sharing. The firms that build durable competitive advantage from open banking are those that build consent architecture that is genuinely transparent and genuinely controllable, not consent dark patterns designed to maximise data collection while obscuring what is being shared.

This is not only an ethical observation - it is a commercial one. The consumer backlash against data practices that feel exploitative has been significant in other sectors, and financial data is more sensitive than most. Firms that build trust earn the data advantage. Firms that extract data without genuine consent earn regulatory scrutiny and consumer attrition.

What Firms Must Do Now

- Audit your open banking infrastructure for commercial capability: Most financial institutions have open banking APIs that satisfy regulatory requirements. Far fewer have the data platform behind those APIs that captures, processes, and acts on the data that flows through them.

- Develop an account-to-account payments strategy: The growth of A2A payments is accelerating. Whether your firm is primarily threatened or primarily positioned to benefit depends on your business model and client base - but the strategic question needs to be answered.

- Prepare for open finance scope expansion: The extension of data portability to mortgages, investments, and pensions is arriving. Firms that prepare their data architecture and product roadmaps for this expanded scope will be better positioned than those that treat each regulatory extension as a new surprise.

- Build consent infrastructure that earns trust: The consent experience is a product design challenge as much as a compliance challenge. Firms that invest in consent architecture that is clear, controllable, and genuinely beneficial to the customer will build the trust that unlocks the full commercial potential of open banking.

Conclusion

Open banking 2.0 is the commercial phase of a regulatory-mandated infrastructure that is now large enough to generate genuine economic value. The firms that engage with it as a commercial opportunity rather than a compliance burden will build durable advantages in the data-driven financial services landscape of 2026 and beyond. At SpinDepth, we help financial institutions and fintech platforms navigate the commercial and strategic dimensions of open banking. The conversation starts here.