Beyond compliance: Why Smart Data 2035 is your next growth opp

Data sharing is becoming a requirement, not a choice

In April 2026, the Department for Business and Trade published Smart Data 2035, the government’s long-term strategy for embedding mandatory data sharing schemes across the UK economy. The target: five or more active schemes by 2030, twenty or more by 2035. Sectors in scope span banking, energy, financial services, property, retail, telecoms, transport and agrifood. £36 million committed to get there.

Worth pausing on what this actually means. Not encouraging organisations to share data. Not incentivising it. Requiring it, sector by sector, through secondary legislation, with the infrastructure and governance to back it up.

Open Banking’s biggest lesson wasn’t compliance

Open Banking is the proof point most people reach for here, and it’s the right one. But not just for the reasons usually cited.

The CMA mandate in 2017 was met with scepticism. Eight years on it underpins billions of pounds of payment flows and Open Banking Ltd estimates the long-term market benefit at full adoption at over £43bn. The obligation created a market nobody had fully mapped in advance.

What’s less talked about is what happened to the incumbents who waited to be pushed. The FCA’s Financial Lives survey found that 14% of UK current account holders had an account with a digital bank in 2024, up from under 0.5% in 2017. Monzo grew its customer base 31% in 2024 alone, to 9.7 million. McKinsey warned in 2017 that traditional banks needed to exploit their trusted status immediately “to halt the loss of business to new entrants.” Most didn’t move fast enough. The risk for slow movers wasn’t a poor Open Banking implementation. It was erosion of their core business while others built the relationships, the data advantages, and the infrastructure they should have been building first.

When the EU introduced PSD2, requiring banks to open payment account data to third parties, the same dynamic played out. An entire category of business became viable that largely didn’t exist before. Account aggregators, payment initiators, cash flow tools for SMEs. Not because the market willed it into existence. Because the data started flowing, and the organisations that moved early shaped what came next.

Closer to home: the government’s £600 million commitment to create the Health Data Research Service, a single secure access point to de-identified NHS datasets, is the same logic applied to health. A 2025 LEK Consulting report estimated that better commercial access to NHS and UK Biobank data could add over £10bn a year to the UK’s life sciences economy. The data was always there. What changed was the decision to make it flow.

Why governments keep coming back to this model

The macro case for why this is good for UK PLC isn’t complicated.

Mandated data sharing creates secondary markets. When organisations are required to make data accessible, third parties build services on top that didn’t exist before. The FCA’s Smart Data Accelerator is already testing use cases for open finance, extending the Open Banking model into pensions, insurance, investments and savings. An enormous set of data assets that currently go nowhere beyond the organisations that hold them.

It reduces structural data advantages that incumbents hold not because they earned them, but because they accumulated them. That’s generally good for competition, even if it’s uncomfortable for the incumbents in question.

The real decision isn’t whether to share

Here’s what the policy conversation tends to gloss over.

The question isn’t really whether to share data. For organisations in the sectors Smart Data 2035 has in scope, that decision is being made for them. The question is whether they move before they’re pushed, or wait.

Waiting looks like the safer bet. It isn’t. By the time a mandate arrives, the organisations that moved early have already built the distribution infrastructure, the external relationships, the operational capability. They’ve made the mistakes and fixed them. The late movers are starting from scratch under time pressure, spending money on compliance rather than capability, and watching their position erode in the meantime.

The organisations that navigate this well treat external data distribution as a product discipline, not an IT project. They think carefully about who receives what, under what terms, with what visibility. They build for repeatability rather than one-off integrations. They invest before they’re forced to.

The ones that wait discover the complexity late, underestimate the operational demands, and end up with something fragile and expensive to maintain. They comply. But they don’t build anything durable. And the ground they lost while waiting doesn’t come back.

The window is already open

Smart Data 2035 sets an ambitious trajectory. The sectors in scope represent a significant chunk of the UK economy, and the data assets sitting across them represent real latent value.

The ones that move deliberately now will be the ones that benefit. The ones that wait for the mandate will find it harder than they expected, and later than they’d like.