Hello everybody and welcome to the first C&F talk session of 2026. This is a recording where I speak to one of our speakers at a forthcoming conference and they share some of their initial thoughts. It is a great pleasure today to be welcoming Rory Tanner, who's the UK Head of Government Affairs at Revolut, and Rory's going to be speaking at our Payments, Regulation and Innovation Summit in London on the 2nd of Feb. Welcome, Rory.

Hi, Maurice, how are you doing?

It's great to have you with us, but by way of background for our viewers, Rory leads Revolut's engagement with government, parliament, regulators and industry to secure positive business outcomes.

He also leads on policy development to identify and shape future opportunities and threats. So, he looks at things such as open banking, crypto, CBDCs, global expansion and the UK's international competitiveness in FS, which is obviously a very hot issue at the present time. Previously he worked for the House of Commons and at Public Affairs Consulting and Political Intelligence.

Revolut itself needs little by way of introduction. It's a great success story, I think, for UK financial services. It is an app of all things money. It is the UK's largest fintech and Europe's most valuable private technology company.

So, let's turn to our first question, if we may, Rory. So open banking has been around for quite some time now. Are we really beginning to see its impact here?

I think yes, and we can see that in the UK and in Europe. I think it's always worth remembering that open banking isn't just a UK-based innovation, it was actually something that came out via PSD2, which is when we were in the EU. But interestingly, there's been different approaches that the UK and the EU has taken around it, and actually we think that the UK has done it better and has led to better outcomes on that.

In terms of open banking being around for a while, yeah, it's been really since the CME order in, what, 2017, and then 2019 is when it got fully implemented, and I think it's been quite a good success story for the UK. In terms of the economic argument around it being valuable, I think that it's clear that there's been several companies that have emerged, I think Tink, Yapily, TrueLayer, multiple unicorn companies that have emerged and have disrupted the payments sector by offering open banking enabled support, which I think has been good for the UK economy.

Also, the data is good. I looked at Open Banking Limited, and in November, their first 2 million payments made via open banking, which is really good progress and shows that there is significant uptake. We also think conversion is broadly good, and this is where the UK is an outlier in terms of being the best performer, especially compared to Europe, and this is looking at Revolut data specifically, but we see that in the UK, the conversion rates for API calls is around 88%, and if you compare that to France, which is at 61%, Germany at 70%, Spain at 55%, you see actually that the UK's approach has led to significantly improved outcomes with regards to API calls, which I think further on I can outline why that's important. But yeah, I think that basically the signs are good that open banking has been a success story for the UK and is performing competently at the moment.

So, it's a pretty good story so far.

And what I've heard is that for a while now, people have been talking about open finance, so taking the concepts behind open banking and spreading them into other related financial services sector, so it's kind of like the natural next step. And why is this important, do you think, to payments and compliance leaders?

I definitely agree it is the natural next step, and it's not a new thing either. I remember in 2019, I wrote a consultation response to the FCA's consultation on open finance for insure techUK in a previous live before Revolut, so again, it's not a new issue, and actually from a regulatory perspective, it's always been the natural next step since 2019, which is really when open banking came into existence, so I think that's the first thing to address, that this is not a new thing.

Secondly, fundamentally it's a natural next step because you're essentially applying the principles of open banking to other areas of financial services where it makes sense, and the use cases that you can really see is around SME credit, it's a really good example there, pensions, investments, mortgages, and actually you can already see the FCA making movements towards that by hosting sprints on mortgages within the open finance ecosystem, which is going to be really exciting, and we're looking with interest to see how that comes out.

There's also insurance, which is kind of its own beast, but is also included within the open finance conversation, although I think realistically the next use cases will be within the areas where banking has existed, because extending it to SME credit or to investments, whatever, where banks already provide those services is a lot easier than a completely different sector, just because it's within the realms of financial services, and again, how it works in insurance, there's lots of quite significant challenges that would need to be resolved.

In terms of the other part of the question around why payments and compliance leaders should care, I think that there are opportunities and challenges with regards to open finance from an economic and product perspective, because ultimately it's new innovations, new product offerings, new opportunities to cross sell to customers, and particularly from a Revolut perspective, we really see the value of consolidation, and think if you could have open finance for pensions and aggregate all of your pension providers into a dashboard, that would be a really good thing that we could add to our app, and be an app for all things money, so that's a natural opportunity there.

Then there's also the compliance challenges and implementation hurdles of how you create smart data contracts within new product areas, like these financial pieces that we're mentioning, and how you can deliver that within a compliance landscape, which is increasingly more limited.

And finally it's not just around the technical challenges, there's political and commercial challenges as well, you know, how do we make these products commercially friendly, which has been a potential challenger of open banking, and how do we get the political will to push for this at a time where, you know, there's clearly a need for short-term outcomes rather than long-term outcomes, right, from a political perspective.

So, open finance has kind of been a bit of a, has suffered because of that, because it was in the Labour manifesto that we're wanting to deliver it, in terms of real-world short-term outcomes, it's really a longer-term play that's not really going to see the benefits until the near end of 2030, so I think it's probably suffering a bit from political, what's the word, it's been deprioritised because it's not going to solve the immediate challenges of the cost living crisis and all the other political challenges.

Yeah.

I mean, taking the regulatory side a little bit further, you know, obviously we hear from Nikhil Rathi at the FCA and others that now they're signed up to the growth agenda, and the nature of regulation is regulation for growth, but do you think that's going to ease the path of the development of open finance and open banking?

I think so, and actually one of the big things has already happened, which is called the Data Use and Access Act 2025, so this basically provides the statutory basis for smart data that goes beyond open banking, and essentially provides the legal framework for smart data and open finance, and I say smart data because actually we're looking at things beyond financial services, so energy and property, I think are really two use cases that are seen there.

So actually, when we're talking about, you know, the big levers that can be pulled, one of them has already been created, right, which is the Data Use and Access Act, which provides that potential.

In terms of kind of what other steps, I think it's essentially what hasn't happened yet, and the potential, which I think is really interesting, which is around the mandation of this, so within the legislation, you know, it provides powers for the FCA and other regulators to mandate the sharing and the creation of this. I think it'll be very interesting to see whether those powers are enforced, and if they are, that'll be that kind of answer to the question of what is the kind of single biggest regulatory decision, because we saw that with open banking, that actually it was a CMA order to the CMA9 that kick-started this progress, and that was a mandation of that that led to this, so there's clearly a case study that highlights that mandation is successful to a point, it's unclear whether the FCA will go down that route. 

Again, I think individual firms will have individual views around whether the mandation will be useful, I think most likely challengers will push for yes, incumbents will push for no, is my educated guess there, but I think ultimately it's a much more collaborative landscape than we saw in 2017, and so there's probably more optimism there, but I would say that the Data Use and Access Act plus the potential for FCA regulatory mandation is like the big next opportunity for open finance.

Maurice

So looking forward Rory, say over the next five years, and how Revolut itself will benefit from these developments, how do you see your app, and it's a slightly unfair question that I haven't warned you in advance of the question, but how do you see your app in five years’ time, in an ideal world, what would Revolut be doing in the UK markets in five years?

Well obviously, we're looking forward to launching our bank in due course, and all of the UK banking products that we'd like to offer within that, that'll be a really exciting next step for us, and will allow us to compete with the incumbents truly on the banking capabilities. So that's definitely the nearer term objectives that we're looking forward to roll out, and you know there's broader topics we can talk about that would be here all day in terms of crypto and non-financial services products, which is increasingly something that we're looking at with regards to e-sims and telcos and lifestyle etc.

Maybe within the realms of kind of payments, I think the challenge that we see, and we are huge open banking proponents right, we are a challenger bank that has been incentivized to try and move money from incumbent bank accounts into our bank accounts, and so open banking has been a huge success story for us, because it has helped enable that.

That's why Revolut accounts for about 20 percent of all API calls in the UK, because we have a business model incentive to do it, which potentially other companies just don't. So, this is kind of coming from a place where we are huge supporters, but I think to be realistic, the challenge of open banking is really significant, because you are essentially taking on card payments, which has been the dominant mode of card payments. I just said card payments right, it's so entrenched you want to say that.

It's been the dominant form of payments for 20-30 years right. If you look at the data, as mentioned earlier, that last month there were 32 million open banking payments, which is good, but if we compare that to card payments in that same time, it was about 1.9 billion, billion, million, and that has a 99.9 acceptance rate, where again going back to what I mentioned earlier, conversion rates, even an 88 percent success rate means one in 10 people has a failure when trying to convert an API for an open banking transaction.

I like to say once bitten twice shy in that regards of technology, in the sense if something doesn't work the first time you try it, how often do you just never try that again? And I hear that all the time where people talk about new technology, not in regards of financial services, that oh it didn't work, so I don't want to use it right. So, what is the opportunity cost of losing those open banking transactions, because people fundamentally will not trust open banking.

Also, with regards to card payments, I think sometimes people just look at the technical side and get too carried away that open banking could be a technological leap but fail to remember that cards are not just pieces of plastic, and that's the reason that they won right. 

They've won because they've bundled together consumer protection, liability disputes, reversibility into the network, and bundling all of that leads to really strong consumer protections, in addition to you know incredibly easy to use, and I think that that's been the formula that has led to cards being successful. You actually look at open banking and there's fundamental problems there, that there is a lack of protections in comparison to card payments, especially around dispute resolution, fraud prevention, you know these are quite big gaps that are currently there, and are being addressed, but until they are, it's objectively true that they are less protected than card payments.

I think Martin Lewis even made a public intervention around that, which is really damaging to open banking, because he's one of the most trustworthy people around money, and actually you get often people say that he leads the polls in who should become prime minister, also Jeremy Clarkson, weirdly very high on that, but I wouldn't necessarily trust him around open banking.

But yeah, so I think the challenge is that you have a 20 plus year old service that has been heavily used, and the success rates are massive, and you're trying to disrupt people from doing that into something new, so you either make it significantly cheaper for vendors, which is obviously the they're applying, or you try and make it incredibly useful or beneficial for consumers.

So, I'd say that addressing the consumer protection challenges is step one and then step two is how do you make a commercial variable recurring payment more appealing than tapping your card, and again I don't necessarily have the answers, but that's ultimately what you need to solve, and yeah.

Yeah, well very interesting Rory, thank you so much for sharing those thoughts with us.

And for our viewers if you'd like to hear more on this and related topics, do check out the website for the conference, the Conference of Payments Regulation and Innovation Summit in London on the 2nd of Feb, the website: www.cityandfinancial.com. 

It just remains for me to say thank you very much, Rory and look forward to seeing you on the 2nd of February.

Thank you, Maurice, thank you everyone.