Smart Data 2035: The UK government publishes its Smart Data Strategy
At the end of March 2026, the UK government published Smart Data 2035: The UK's Smart Data Strategy (the “Strategy”), setting out its long-term vision for Smart Data schemes in the UK and the steps it intends to take between now and 2035 to establish the UK as a global hub for data-driven growth. Businesses operating in the sectors that are identified as targets for Smart Data schemes should begin to consider how they may be affected by future Smart Data regulations, including potential obligations to share customer or business data through standardised interfaces. In this Legal Update article, we summarise the principal elements of the Strategy, including its objectives, sector-by-sector plans, cross-sector coordination measures, and the implications for businesses operating in the UK.
Recap: What is Smart Data?
Smart Data is the secure, consented sharing of customer or business data with authorised third parties (“ATPs”). The government believes that Smart Data empowers customers by enabling them to share data held by service providers with third parties who can then use that data to offer innovative products and services. Open Banking, the UK’s first Smart Data scheme, is the leading example. According to the Strategy, Open Banking now has over 17 million active users and records more than 2 billion monthly API calls.
Using the powers given to it under the Data (Use and Access) Act 2025 (the “DUA Act”), the government can require firms to participate in Smart Data schemes through regulations, or firms can voluntarily set up and participate in schemes by agreeing common standards and processes for data sharing.
The 2035 Vision: 25+ Smart Data schemes by 2035
The Strategy sets an ambitious target of five or more active Smart Data schemes by 2030 and 20 or more by 2035, spanning many sectors of the economy. The government estimates that Smart Data schemes in just four sectors could generate £71.2 billion in “net social value” from 2028 to 2043, with annual GDP contributions reaching £9.6 billion by 2043. To begin achieving this, the government says that it is investing at least £36 million over the next four years. Given the scale of the government’s expansive ambitions set out in the Strategy, it remains to be seen whether this ostensibly modest amount will be adequate to implement all of the proposed schemes.
Although the Strategy is not a consultation, the government does say that it welcomes stakeholder input on a variety of ‘themes’, which include prioritisation of sectors and use cases, the interplay between industry and government in developing schemes or regulations, and how to expedite progress.
Sector-by-Sector Plans
The Strategy identifies ten initial sectors in which the government will consider or progress Smart Data schemes:
Smart Data Schemes in 10 initial sectors:
- banking, finance, energy, road fuels, property, retail, digital markets, transport, telecoms, and agrifood
The following four sectors are given the most detailed treatment in the Strategy because these are amongst the ‘growth-driving sectors’ set out in the Modern Industrial Strategy:
Four ‘focus’ sectors for Smart Data Schemes:
- banking, finance, energy, and property
1. Banking. The government has committed to establishing a long-term regulatory framework for Open Banking under the DUA Act, with oversight transitioning to the Financial Conduct Authority (“FCA”). The government says that it will consult on the Open Banking scheme in “early 2026”, with regulations to follow “as soon as parliamentary time allows”.
2. Finance. Open Finance is presented as the natural progression of Open Banking. The Strategy refers to the FCA’s work on leading the Smart Data Accelerator to support experimentation and innovation in areas such as SME access to finance and mortgages, and says that the FCA will publish its roadmap for Open Finance in March 2026, with HM Treasury setting out next steps in Summer 2026.
The FCA’s roadmap for Open Finance was published on 14 April 2026. The roadmap targets: (1) collaboration with industry in 2026 to better understand what Open Finance should deliver; (2) shaping options for a long-term regulatory framework based on evidence from earlier work, in 2027; and (3) launching sustainable Open Finance schemes in collaboration with industry from 2028 to 2030.
3. Energy. The Strategy says that an energy Smart Data scheme could have a net social value of £9.5 billion between 2028 and 2043 and contribute £2.1 billion in GDP by 2043. The government says that it will consult on detailed energy Smart Data scheme proposals in 2026. Subject to consultation outcomes, regulations are expected to be introduced in 2027/2028.
This follows on from the government’s recent call for evidence on developing an energy Smart Data scheme, which closed in March 2025. The government’s response to that was published in July 2025 and included a commitment to identify and cost options on the design and implementation of an energy Smart Data scheme to support a potential consultation on detailed proposals.
4. Property. In the property sector, the government will publish a roadmap in 2026 setting out how it intends to transform home buying and selling over the course of this parliament. A Smart Data call for evidence will follow. This builds on the government’s work looking at home buying and selling reform, which it consulted on at the end of 2025. The Strategy says that economic modelling suggests a homebuying Smart Data scheme could have a net social value of around £28.7 billion between 2028 and 2043, with an annual GDP impact of £4.2 billion by 2043.
For the remaining sectors (retail, digital markets, transport, telecoms, and agrifood) the government is at an earlier stage of exploration, with calls for evidence and further research planned during 2026.
Cross-sector coordination and the Smart Data Guidebook
A central feature of the Strategy is the government’s commitment to cross-sector interoperability and coordination. Key measures include the publication of a cross-economy “Smart Data Guidebook” by early 2027, which will set out best practice on scheme design, governance, security, customer experience, and interoperability. The government says that it will also consult on long-term institutional arrangements for Smart Data governance, including which functions and roles should be delivered centrally across the economy.
The Strategy also signals the government’s intention to connect Smart Data with its broader data and AI agenda, including the National Data Library, the AI Opportunities Action Plan, and digital verification of identities. The Guidebook will aim to ensure Smart Data schemes create “AI-ready” data, and the government will continue to explore how Smart Data can support AI adoption and innovation.
It is unclear whether the Strategy intends that Smart Data will be capable of being easily ingested by AI tools that are used to deliver the intended outcome of the relevant Smart Data scheme or whether the government is setting its sights more broadly, so that data will be available for other AI innovation (e.g. using Smart Data to train AI models that are used for purposes that are unconnected with the delivery of the relevant scheme). The links between Smart Data and AI adoption and innovation is one of the themes on which the government says that it would welcome further engagement from stakeholders.
Implications for Businesses
Although light on detail, the Strategy is an important document, providing an up-to-date insight to the government’s long-term commitment to Smart Data and its intention to use the regulatory powers in the DUA Act to mandate participation in schemes across multiple sectors.
Businesses operating in the ten identified sectors should begin to consider how they may be affected by future Smart Data regulations, including potential obligations to share customer or business data through standardised interfaces. With consultations in banking, energy, and property expected during 2026, and regulations potentially following in 2027/2028, businesses in these sectors in particular should consider engaging with the consultation process and assessing their data-sharing readiness.
For innovative businesses and ATPs, the Strategy presents opportunities: the government is actively encouraging industry-led collaboration and is funding pilots in some sectors. The development of the Smart Data Guidebook and multi-sector data-testing environments will also provide important infrastructure for businesses looking to develop Smart Data services.
While the government’s vision for Smart Data schemes is ambitious – aiming for 25 or more schemes by 2035 – some have questioned the feasibility of achieving such broad transformation within the proposed timelines. These concerns reflect the ongoing debates around Open Banking and Open Finance, which, despite years of discussion, have yet to result in definitive long-term regulatory frameworks. There is also recognition of the significant challenges posed by the need for cross-sector alignment, robust coordination between government and industry, and the complexities of establishing interoperability standards across diverse markets. The government’s work on developing the Guidebook and centralised arrangements for Smart Data governance will likely be crucial in addressing those issues and achieving their ambitious targets.
Stakeholders will need to watch closely to see how the government manages these hurdles and whether these goals do lead to practical, workable Smart Data schemes. The Strategy is optimistic and these practical challenges are likely to influence the pace and shape of implementation in the coming years.
Next Steps
Look out for future Law-Now updates on Smart Data, including on the outcomes of the forthcoming consultations on Open Banking, energy, and property Smart Data schemes, as well as developments in the FCA's Open Finance roadmap and the publication of the Smart Data Guidebook.
If you would like to discuss this article or how these developments may impact your business, please contact one of the listed lawyers or your usual CMS contact.
