AVAILABILTY OF PROPOSITIONS

Some reduction in overall numbers of TPPs, but the ecosystem remains vibrant

Since 2022, OBL has tracked the number and type of TPP propositions in the market, using six high-level propositions outlined in the original CMA Retail Market Investigation. Overall, we see a small contraction in the number of TPPs which has fallen to 145 in March 2025 from 155 when this analysis was last completed in December 2022.

Figure 11: Number and Type of Live to Market TPP Propositions

We continue to monitor the same six categories of proposition as set out below, although we have continued to see innovation in the types of firm within each area:

Proposition Area	Types of service	Live to Market Firms (March 2025 and change since December 2022)	Comments
Improved Financial Decision-Making	Account aggregation, Personal Financial Management (PFM), cloud accounting, tax assistants, balance availability.	39 (-10)	We have seen market exit in traditional PFM type solutions, although many remain. Cloud accounting remains a vibrant and well-served segment. Solutions now seem to be more integrated into other propositions (e.g., balance availability) or more focused on a specific need (e.g., tax assistants).
Expanded Payments Choice	New payment offerings, loyalty services.	45 (+2)	A vibrant sector, with some exits, but several new players entering. Loyalty has emerged as a notable sub-segment.
Better Borrowing	Lenders, third parties offering affordability and other insights to lenders, collections.	22 (-3)	Continues to be a key area, with several firms offering services to lenders to improve loan decisioning, loan performance and collections.
Increased Access to Advice & Guidance	Tools to support IFAs, advice services to consumers, debt advice.	7 (+2)	There has been some growth in services targeting IFAs and wealth advisors, helping them to build holistic overviews of their clients’ financial position. Debt advice does not appear to have emerged as a key area for propositions despite initial optimism.
Increased Saving and Investments	Automated savings, open banking-enabled savings providers	8 (+0)	The key players remain in the market, though there has been limited innovation in this space. Several savings providers are reportedly using open banking payments, but not as TPPs so this innovation would not be recorded here.
Increased Switching	Services to help consumers compare or switch accounts.	2 (-1)	The aspiration for open banking in this space does not yet appear to have been realised through dedicated comparison and switching services, albeit we are unable to comment on the degree to which open banking enabled innovations have fostered switching more broadly. Limited innovation to date.
Mixed	Third parties offering “open banking as a service” to other parties, services combining multiple elements	15 (+0)	The market remains dominated by a core set of large, open banking enabling infrastructure players.
Other	Identity	7 (+0)	Identity validation and account checks remains an interesting niche area.

The most notable decline is in Improved Financial Decision Making, where the number of active firms has fallen from 49 to 39 through a combination of market exit and consolidation. In contrast, the number of payments firms has, in fact, increased by two, to 45.

What these numbers disguise, however, is the vibrancy of the open banking ecosystem, with a number of exits and new firms joining the ecosystem. In total, 33 firms left the ecosystem and 23 joined. The reasons for exit are varied, including acquisition, merger, funding issues, and strategic withdrawal.

Agency models remain a vital route to market

In understanding the shape and dynamics of the open banking ecosystem, it is vital to highlight that there are a far broader range of organisations using open banking data and payments than the 145 regulated TPPs. There are two other high-level routes firms can use when bringing a proposition to market, with the appropriate option depending on the level of ambition, time to market, the nature of the proposition and the regulatory position. These are:

Agency models: unregulated firms can be agents of TPPs and bring propositions to market on this basis.
Firms operating outside PSD2: the way that open banking works in the UK means that a firm does not need to be regulated under PSD2 to offer open banking payments as a checkout option or to utilise open banking data.

What we see in terms of TPPs is, therefore, potentially the tip of the iceberg. We know that there are potentially thousands of firms which enter an arrangement with a TPP to utilise open banking data, for example lenders, firms undertaking affordability assessments, loyalty providers, or identity specialists, and there is no data in the public domain on the extent of this.

The same is true in payments, where many leading billers and merchants offering open banking payments as an option at checkout are not PISPs. These companies enter a commercial agreement with a PISP to offer an alternative means of payment to their customers. Again, there are likely to be many such firms, possibly thousands, operating in the market today.

Model	Volume	Notes
Full registration as a TPP	145 (live-to-market only)	Some contraction, but there remain 145 regulated TPPs with a live-to-market proposition.
Agent of a TPP	406 (total number)	Continued growth, with 11% more PSD2 agents than in December 2022. This continues to be a route for firms to come to market quickly, test and refine propositions, with some moving from agent status to fully regulated.
Operating outside PSD2	This is unknown, but believed to be thousands of firms using open banking data or payments on this basis. In the payments arena, most biller / merchants are not PSD2-regulated, but use the services of a regulated PISP.	Limited visibility, but indications are of continued growth of firms outside the PSD2 perimeter leveraging open banking data and payments.

www.openbanking.org.uk Registered in England. Company Number: 10440081 Registered office: Suite 501, Dawson House, 5 Jewry Street, Aldgate, London EC3N 2EX