Open banking in the UK and EU: two paths, one destination?

Open banking began with a shared ambition on both sides of the Channel, but the UK and EU have taken markedly different routes. The UK has leaned on a central implementation entity and common standards; the EU has relied on market-led API initiatives under PSD2.

With commercial variable recurring payments in the UK and the upcoming Payment Services Regulation in the EU, those paths are diverging further. Pricing, liability and dashboard requirements are the main points of difference.

For firms operating in both markets, the practical answer is an abstraction layer that isolates market-specific rules from core payment logic — and a product strategy that does not assume one regime will converge on the other.