Open Banking and the Promise of Inclusion
Author Ellie Duncan on how far open banking has reached the people it was meant to help.
Open banking was sold as a way to bring the excluded and underbanked into the financial system, and journalist Ellie Duncan has looked into whether it actually has, culminating in her book Open Banking and Financial Inclusion: Creating a Financial System That Provides Security and Equity. Ellie’s answer is a considered yes, with caveats: the clearest wins are in emerging markets like Brazil, the UK’s gains have been quieter and more about financial resilience than dramatic inclusion, and the technology’s promise still depends heavily on whether inclusion is designed in from the start.
Open banking began in the UK as a competition remedy: a way to give customers more control over their data and help new providers compete with established banks. Its potential to improve access and financial resilience soon became part of the wider conversation. Ellie Duncan has looked into whether it actually has, culminating in Open Banking and Financial Inclusion: Creating a Financial System That Provides Security and Equity. We asked Ellie five questions about what she found, and her answers follow in full below.
The UK Context: Why Exclusion Still Matters
Before getting into the interview, it is worth grounding this in what financial exclusion actually looks like in the UK today, because the numbers have been strikingly persistent for a country with one of the world’s most developed financial systems.
Updated 1 September 2026. These figures come from the FCA’s latest Financial Lives survey, based on fieldwork conducted in 2024. They are the latest published estimates, rather than a real-time count.
These are different measures of exclusion and vulnerability, and should not be read as the same thing. Open banking cannot fix every barrier to access on its own, but it has enabled tools that help people budget, compare deals, and build a stronger case with lenders. That is the question we put to Ellie Duncan below: more than eight years after launch and with over one billion payments recorded, how far has the technology reached the people it was meant to help?
The Origin of the Book
QWhat first drew you to the intersection of open banking and financial inclusion, enough to write a whole book about it?
I had been a financial journalist for over a decade by the time I came up with the idea for my book. It had often struck me how so many of the financial products and services I was writing about were aimed at already wealthy or financially savvy individuals. Obviously, it is important that people of all backgrounds have access to products and services that encourage them to save and invest, or to grow their financial confidence.
As I had become more familiar with open banking and the use cases it was generating, I saw that it had the potential to address an untapped part of the market, that is, individuals who are largely excluded or underserved by the financial system. I feel strongly that everyone has a right to access financial services but that there was no real incentive for certain parts of the industry to serve those individuals. Open banking appeared to be changing that, so I wanted to explore it more and felt that a book would enable me to do this in far more depth and scope.
Has Open Banking Actually Reached the Excluded?
QOpen banking was meant to open up financial services to the excluded and underbanked. From your research, has it actually reached them?
Yes, we are seeing plenty of examples of open banking-enabled innovation from fintechs that are offering products and services to individuals who have not typically been served by mainstream financial services. There are fintechs addressing issues such as being able to port your credit history with you to another country, so that individuals starting a life in a new country have evidence of their previous financial commitments and ability to pay. There are also lenders using open banking data to lend or offer credit to individuals considered ‘thin file’, such as students, immigrants and those who are newly banked.
Typically, in emerging markets or countries that have a significant un- or underbanked population, open banking and open finance has had a more obvious and far-reaching impact than in, say, developed countries. Brazil is probably the best example and is a country I look at closely in my book. At that point, it was only three years into its open banking and open finance journey. Brazil is now considered a leader in open finance. A recent article by Ozone API reported that there are more than 700 registered participants spanning all financial services, over 60 million customers actively sharing data, while Pix, its central bank’s payments platform, processes in excess of six billion monthly transactions.
By contrast, in the UK, the impact of open banking is more obviously felt among those who are underbanked and who need to build their financial resilience. By that I mean that open banking-enabled financial services in developed markets have tended to address the need to improve overall financial health, particularly in the past few years as the cost of living has soared. The statistics, however, are still impressive, with some important milestones having been reached recently. According to Open Banking Limited, more than one billion open banking payments and 100 billion API calls have been recorded across the CMA9 banks since the launch of open banking more than eight years ago.
Reading Ellie’s answer alongside the numbers she cites, a pattern is hard to miss: the markets moving fastest on inclusion are the ones that made it the point of open banking, not a side effect of it.
| Market | What is driving inclusion | Scale, as cited by Ellie Duncan |
|---|---|---|
| Brazil | Pix instant payments plus a wide open finance participant base | 700+ registered participants and 60m+ customers with active consent (Ozone API, Oct 2025); Pix exceeded 6bn monthly transactions in late 2024 |
| UAE | A national strategy that makes inclusion a stated policy goal | National Financial Inclusion Strategy 2026 to 2030, developed by the CBUAE with the World Bank, OECD and Arab Monetary Fund |
| UK | Financial resilience use cases: budgeting, thin-file lending, credit building | 1bn+ Open Banking payments and 100bn+ API calls across the CMA9 since 2018 |
None of these are like-for-like measures of inclusion itself, which is precisely Ellie Duncan’s closing point later in this interview: the industry is fluent in reporting volume, far less so in reporting whether that volume is reaching the people who need it.
The Human Cost of Exclusion
QWriting the book, you spoke to people across the industry and people who’d lived financial exclusion. What surprised you most?
One of the most surprising things among those I spoke to who had lived financial exclusion was how quick the financial system was to shut people out entirely and how little flexibility or nuance the industry allowed for. Some of those experiences had happened many years ago, while others I spoke to had experienced financial exclusion more recently. Some of those individuals had gone on to work in the industry that had previously excluded them and to make sure no-one had to go through what they did, which is admirable. Perhaps it was not surprising but it was certainly inspiring to speak to people working in financial services and open banking whose empathy, passion and lived experience give them a unique perspective on the products and services that have the most positive impact.
Learning From Brazil and the UAE
QWho is doing inclusion well, a market or country the UK could learn from?
Aside from Brazil, which is well documented, the United Arab Emirates (UAE) has been making huge strides when it comes to financial inclusion. The Central Bank of the UAE (CBUAE) has stipulated that “every natural Person shall have the right to access all or part of the banking and financial services”. The UAE’s National Financial Inclusion Strategy 2026 to 2030 has been developed in partnership with the CBUAE, the Organisation for Economic Co-operation and Development and the Arab Monetary Fund. Financial literacy and economic empowerment are a human right, so by placing financial inclusion front and centre, the UAE is clearly demonstrating that it recognises this.
At the same time, open finance in the UAE has been moving at pace and we’re seeing some exciting developments from fintechs and financial institutions in the region, particularly around account-to-account payments.
What Needs to Change
QIf you could change one thing to make open banking work better for the excluded, what would it be?
I think where open banking has been most effective at tackling financial exclusion is in those jurisdictions that have either built in financial inclusion use cases as a key outcome from the start, and where a hybrid approach has been taken, combining regulation with market forces. Countries that consider financial inclusion a key pillar of economic growth and recognise it as an opportunity to grow financial confidence will generate the most inclusive use cases.
I would also like to see countries measuring not only API calls and open banking payments, but also establishing a measurement of financial inclusion as a result of open banking and open finance initiatives.
Where This Leaves UK Businesses
Ellie Duncan’s book is mostly concerned with the lending and credit side of inclusion, helping people build a financial history, access affordable credit, and be seen by a system that has historically ignored them. Payments are a smaller part of that story, but not an irrelevant one, and it is worth being precise about what open banking payments can and cannot claim on the inclusion front.
A Pay by Bank payment does not require the customer to use a credit or debit card; it is made from an eligible bank account. Making the payment does not involve a credit check. For eligible sole traders and micro-businesses, Pay by Bank can provide a lower-cost way to accept payments without relying on card rails, helping to reduce one practical barrier to getting paid.
That is a genuine, if modest, contribution to inclusion: reducing reliance on card acceptance for people and businesses that are able to use an eligible bank account. It is a different claim from what Ellie Duncan’s research is really about, which is whether people who have been shut out of credit and banking altogether can get back in. Both matter. Conflating them would overstate what a payment method alone can do.
What Ellie’s interview leaves us with is a useful discipline: measure what actually changes for the person on the other end, not just how many payments moved or how many API calls were made. SSV SmartPay enables Pay by Bank through FCA-authorised payment-institution partners. Where that infrastructure can lower a real barrier, whether that is a fee, a card requirement, or a wait for funds to clear, it is worth building for. Where it cannot, it is worth being honest about that too.
Frequently Asked Questions
Has open banking actually reached the underbanked?
According to author Ellie Duncan, yes, in part. Fintechs are already using open banking to help people with thin credit files, such as students, immigrants, and the newly banked, access lending and credit, and to let people carry their financial history with them when they move country. The effect has been most visible in emerging markets, while in developed markets like the UK, open banking’s impact on inclusion has been felt more through improving overall financial resilience.
Which country is leading on open finance and inclusion?
Brazil is widely cited as a leader. Ellie Duncan notes that Ozone API reported more than 700 registered open finance participants and over 60 million customers with active consent in October 2025, while Pix had exceeded six billion monthly transactions by late 2024. The UAE is also highlighted for embedding financial inclusion into national policy through its National Financial Inclusion Strategy.
What would most improve open banking’s impact on financial inclusion?
Ellie Duncan argues that countries which build financial inclusion into open banking as a goal from the start, combining regulation with market forces, see the most inclusive outcomes. Ellie also suggests that countries should measure financial inclusion directly as an outcome, rather than tracking only volume metrics like API calls and payment counts.
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References
- Open Banking Limited, “Open Banking surpasses one billion payments and 100 billion API calls,” press release, 30 July 2026.
- Financial Conduct Authority, Financial Lives 2024 survey. Latest published data: 0.9m unbanked adults, 13.1m adults with low financial resilience and 26.4m adults with one or more characteristics of vulnerability.
- Competition and Markets Authority, Retail Banking Market Investigation. Open Banking was introduced as part of remedies to address competition problems in retail banking.
- Duncan, Ellie. Open Banking and Financial Inclusion: Creating a Financial System That Provides Security and Equity. Kogan Page. Available to purchase at: https://www.koganpage.com/accounting-finance-banking/open-banking-and-financial-inclusion-9781398612402
- Ozone API, “The History of Open Finance in Brazil,” 24 October 2025. Figures on participants and active consent are time-specific and are attributed accordingly.
- UAE National Financial Inclusion Strategy 2026 to 2030. Developed by the CBUAE in partnership with the World Bank, OECD and Arab Monetary Fund.
- Central Bank of the UAE (CBUAE), “MENA Leaders’ Summit on Financial Inclusion Commences in Abu Dhabi with High-Level Regional and International Participation,” 17 November 2025, p. 2. Official CBUAE press release (PDF).
About this interview
About the author. Ellie Duncan is an experienced freelance journalist, author, broadcaster, speaker and podcast host, who has spent 15+ years covering financial services, with a focus on open banking, payments and financial inclusion more recently. She is the host of the Open Banking Expo Unplugged podcast and the podcast series Settling Up with GoCardless. In 2024, her book Open Banking and Financial Inclusion: Creating a Financial System That Provides Security and Equity was published by Kogan Page. She has written for Alternative Credit Investor, Working Capital Forum and Pensions Expert.
Quotes in this piece are drawn from a written interview conducted for SSV SmartPay and are reproduced in full, unedited. Views expressed by Ellie Duncan are her own and do not necessarily reflect the views of SSV SmartPay. Editorial statistics and source links were reviewed and updated on 1 September 2026; time-sensitive figures are dated in the text.
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Start free trial Book a demo Or get in touch with the team →Frequently Asked Questions
Has open banking actually reached the underbanked?
Yes, in part. Fintechs are already using open banking to help people with thin credit files — students, immigrants, and the newly banked — access lending and credit, and to let people carry their financial history when they move country. The effect has been most visible in emerging markets, while in the UK, open banking's impact has been felt more through improving overall financial resilience.
Which country is leading on open finance and inclusion?
Brazil is widely cited as a leader, with more than 700 registered open finance participants, over 60 million customers actively sharing data, and its Pix payments platform processing more than six billion transactions a month. The UAE is also highlighted for embedding financial inclusion into national policy through its National Financial Inclusion Strategy 2026 to 2030.
What would most improve open banking's impact on financial inclusion?
Countries that build financial inclusion into open banking as a goal from the start — combining regulation with market forces — see the most inclusive outcomes. Measuring financial inclusion directly as an outcome, rather than tracking only API calls and payment volumes, would also make a significant difference.
What is the relationship between open banking and Pay by Bank for financially excluded people?
Pay by Bank removes some barriers to access — no credit check is needed to make or accept a payment, and no card is required, only a bank account. This lowers the threshold for small businesses and sole traders who may have found card machines or merchant accounts harder to access. It is a modest but real contribution to financial access, distinct from the broader lending and credit-building work Ellie Duncan's research covers.
Who is Ellie Duncan?
Ellie Duncan is an experienced freelance journalist, author, broadcaster, speaker and podcast host with 15+ years covering financial services, with a focus on open banking, payments and financial inclusion. She is the host of the Open Banking Expo Unplugged podcast and the GoCardless Settling Up podcast series, and the author of Open Banking and Financial Inclusion: Creating a Financial System That Provides Security and Equity, published by Kogan Page in 2024.



