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Open Banking Already Does Inclusion Work in UK Lending

Open Banking Already Does Inclusion Work in UK Lending

Sustainable Finance Live put open data on the inclusion agenda; UK community lenders already use it for affordability checks.

Open banking is already a working inclusion tool, not a conference aspiration. Responsible Finance says UK community lenders have used it for affordability checks for years, while Finextra's summary of Sustainable Finance Live shows open data and AI on the agenda for community-led models, without figures or commitments. The open question is evidence of outcomes.

The Ledger Desk · 3 min read

A conference agenda is not evidence, and the Finextra summary of Sustainable Finance Live contains none: it says sessions discussed placing social purpose over profit, improving access to inclusive banking, and using open data and AI for community-led models, with no figures or commitments. What can be checked is narrower. UK community lenders already use open banking in credit decisions, and a regulatory duty now asks firms to evidence outcomes. This piece covers the UK only.

Open banking is already used for affordability checks

Responsible Finance, the body for UK community lenders, notes that CDFIs have used open banking for affordability checks for years. It says this can widen access to credit by relying less on credit scores. The mechanism is simple: bank transaction data, shared with the customer's consent, can stand in for a thin or missing credit file, so a lender looks at actual income and spending rather than at borrowing history the applicant never had the chance to build.

The Consumer Duty asks Boards to evidence outcomes

As Responsible Finance describes the Consumer Duty, firms must make an annual assessment for their Board of whether they are delivering good consumer outcomes. That moves inclusion from a values statement to something a Board has to evidence. Responsible Finance reports that CDFIs monitor outcomes using quantitative and qualitative data, and that one built a toolkit pointing declined customers to other support. The source does not quantify the results.

Fair4All Finance flagged a burden on small lenders

In its 2022 response to the Consumer Duty consultation, Fair4All Finance warned that small community finance providers have fewer resources to implement the Duty, and that it could limit access for excluded customers unless inclusion is actively promoted. This is a warning from one stakeholder made before the rule took effect, not a measured outcome. Responsible Finance's 2025 review is a later source, and the two should not be read as confirming each other.

Editorial view: what remains unproven

This section is The Ledger's own judgment, not a sourced finding. The cited material shows that open data is in use and that Boards must evidence outcomes, but it contains no cost, loss or profitability data. Whether inclusive lending sustains itself at scale therefore cannot be concluded from it. The useful thing to watch is whether lenders or regulators publish outcome data that would let that question be answered.

What did Sustainable Finance Live discuss on inclusive banking?
Per Finextra's summary, the afternoon sessions covered strategies to place social purpose over profit, improve access to inclusive banking, and use open data and AI to build community-led business models. The summary gives no figures or commitments.
Is open banking already used to widen access to credit?
In UK community finance, yes. Responsible Finance notes that CDFIs have used open banking for affordability checks for years, which it says can widen access to credit by relying less on credit scores.
Why does the Consumer Duty matter for community lenders?
Firms must make an annual assessment for their Board of whether they deliver good consumer outcomes. In 2022, Fair4All Finance warned that small community providers have fewer resources to implement the Duty.
  1. Sustainable Finance Live: How can we power regenerative finance? — Finextra
  2. The Consumer Duty one year on — Responsible Finance
  3. Consumer Duty: Fair4All Finance response — Fair4All Finance