TL;DR: One in five UK consumers and small businesses now use open banking, Raidiam's survey found, alongside 1.3 million self-assessment payments worth £4.7 billion in January 2026. Smart data schemes now need reusable consent and identity controls if delivery is to scale across sectors.
Editorial analysis by NHI Mgmt Group, based on content published by Raidiam: “The Delivery Decade Has Begun: Reflections on the Smart Data Forum 2026”.
By the numbers:
- 1.3 million people paid their self-assessment tax bills via open banking in January 2026.
Key questions
Q: Why do interoperability programmes fail when governance is inconsistent across sectors?
A: They fail because participants cannot rely on the same rules for consent, authentication, liability, and data use.
Q: What breaks when AI agents are given access without identity governance?
A: What breaks is accountability.
A: Start by treating consent, identity, and authorisation as shared platform capabilities, not project-specific controls.
Practitioner guidance
- Embed governance in the platform layer Design consent, identity, and authorisation into shared infrastructure so each new scheme does not need a separate trust overlay.
- Standardise API security across schemes Adopt one security baseline for federated data exchange so authentication, token handling, and access checks behave consistently across sectors.
- Define machine-consumer governance Treat agents and other non-human consumers as governed identities with explicit access scope, current permissions, and auditable decision paths.
Bottom line: Smart data is now constrained less by policy intent than by the governance architecture needed to make delivery trustworthy at scale.
Glossary terms: Support Data Governance, Governance architecture, Permissioned First-Party Data, Interoperability trust boundary
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Governance architecture, not enthusiasm, is now the limiting factor in smart data delivery. The article shows a market moving from proof-of-concept to infrastructure reality, which means the bottleneck has shifted from policy intent to operational trust design. When adoption starts to scale, the quality of the governance layer decides whether interoperability compounds or fragments. Practitioners should read this as a mandate to treat trust infrastructure as core architecture, not programme decoration.
A question worth separating out:
Q: How should security teams balance trust, innovation, and control in smart data schemes?
A: They should set a common security and consent baseline that is strong enough to protect data-sharing, but simple enough that participants can actually adopt it. The goal is reusable governance that scales with more schemes, not bespoke controls for every integration.
👉 Read our full editorial: Smart data delivery now hinges on governance built into infrastructure