After marking its one year anniversary on Sunday, the open banking 'revolution' didn't arrive in year one of the grand project, but to think that it would have done might be missing the point entirely.
While YouGov research from August showed that 72 percent of UK adults had never heard of open banking, the success of the regulation should be measured more by overall adoption of open banking-enabled services, and less on name recognition.
Jed Murphy, UK head of strategy and innovation at Cardlytics put it best when he told Computerworld UK: "Most people knew there wouldn't be a 'big bang' moment with open banking. But even as we approach the end of 2018, it is some way off from effecting real consumer change.
"Old habits die hard when it comes to your personal finances, particularly around privacy. If entrenched customer behaviour is going to change, concerns must be tackled head-on, with industry-wide changes and truly compelling propositions."
This reflects the thoughts of Tom Renwick, strategy analyst at challenger bank Atom, who said: "Whilst open banking began not with a bang, but the proverbial whimper; very few aside from the most ardent of open banking enthusiasts were expecting a 'revolution' in January.
"The promise of open banking will only be realised when there are fintechs and banks alike producing innovative products and services leveraging APIs that seek to address real customer needs."
While banks may consider spending some marketing budget on open banking education initiatives, a better approach might be simply to deliver intuitive, useful new digital products to customers, without getting bogged down in the parlance of regulators.
Imran Gulamhuseinwala, trustee of the Open Banking Implementation Entity (OBIE) noted in his reflection on the first year that while it was first regarded as a "a typical compliance exercise championed only by a handful of fintechs," the past year has shown that "banks have very firmly moved from viewing open banking as a compliance exercise to an opportunity to compete and innovate".
"In short, it is clear that there are signs of an emerging dynamic, vibrant and developing ecosystem – an ecosystem which is rapidly becoming more sophisticated and expansive in its coverage," he added.
Things got off to a rocky start last year, with the banks given a deadline extension to release their public APIs. Version 2 of the Open Banking Standards was eventually released in March. By May there were 1 million open banking API calls made for the first time and by November this was up to 17.5 million per month.
Today there are already more than 80 third party providers (TPPs) registered with the FCA to provide either payment initiation or account information services, and Gulamhuseinwala expects this ecosystem to ramp up rapidly in 2019.
"We have over 100 regulated entities enrolled in open banking, with in excess of 100 waiting to join. We expect the ecosystem to develop with even greater momentum and pace not least as we see greater conformance with the implementation of the Standards as well as greater innovation in the market," Gulamhuseinwala concluded.
There has been plenty of progress over the past year from banks and fintechs leveraging these new open API capabilities however.
The two most striking examples come from Barclays and HSBC. Both of the banks made it possible for customers to see multiple accounts from their mobile apps, regardless of if that account is held with a rival bank.
While HSBC created a whole new app, first as a beta then as the Connected Money app, Barclays has baked the feature into its core banking app for all customers.
On the fintech side Token made the first end-to-end payment through open banking APIs in June and then in November Iwoca made the first business loan using open banking data.
Iwoca later announced new open banking connections to Barclays and HSBC in December, adding to an existing connection with Lloyds Bank. This now allows small businesses that bank with those lenders to apply for loans or a credit facility quickly and easily by giving them direct access to five years of transaction history instantly.
Speaking more generally, Samantha Seaton, CEO of Moneyhub said: "Open banking makes it easier for people to take action where their money is concerned, from permission for an automatic 'sweep' of money from a savings account to avoid unnecessary overdraft fees at the simple click of button to informative nudges which can save them money such as notification of lower Loan to Value ratios reached.
"Such changes empower consumers and businesses in the UK and across Europe to achieve greater financial wellbeing. As the potential is realised, the next few years will be transformational."
That being said, there are still major barriers to be overcome to start considering open banking anything approaching a success, specifically the need for shared standards and robust data security.
Jake Ranson, CMO at credit rating agency Equifax UK, said: "Open banking is still in its infancy and, of course, many challenges still lie ahead, namely an educational deficit regarding how open banking can improve consumers' financial lives, as well as understanding data's positive predictive capabilities.
"It is equally important that reassurance is provided around the control and maintenance of individuals' data, reiterating the information will only be used with their permission and they can revoke access at any time."
Writing for Finance Monthly, Kevin Day, CEO of HPD Software said: "The opportunities created by initiatives such as open banking, which have the potential to transform the industry, of course come with responsibilities, and one of the major challenges will be around managing risks related to security. A lack of homogenous technical standards may make operating processes susceptible to corruption and companies need to be clear on how they will safeguard their data against fraudulent activity."
"With complex chains of data access, both banks and fintechs must also consider the obstacles associated with responsibility for any security breaches, and ensure that their software is able to identify, predict and react to risks or breaches in good time," he added.
Shahrokh Moinian, global head of cash products and cash management at Deutsche Bank, wrote for Payment Source that while open banking provides a huge number of opportunities, "without a marketwide attempt to standardise the application programming interfaces - crucial to enabling such a system - these opportunities will be lost".
Writing about the Second Payment Services Directive (PSD2) specifically - a parallel European regulation that also seeks to open up banking via a set of standard APIs - Moinian said: "Many banks are yet to envisage how PSD2 can be transformed from a compliance burden to a business opportunity.
"Naturally, making PSD2 work in practice - and ensuring the interfaces are interoperable - rests upon an effective agreement of common standards, as well as a considerable level of harmonisation between market actors. Providing access to accounts in a disorganised or incongruent manner could endanger PSD2's opportunities for the entire market."
Renwick at Atom added: "PSD2 requires strong customer authentication to be performed in certain circumstances. It is imperative for the success of the wider ecosystem that banks ensure that the experience is easy, intuitive and secure. Unfortunately, a number of market implementations fall short of these critical design principles. Led by the OBIE, a major focus for the first half of 2019 will be on improving customer experience, including the introduction of app-to-app and decoupled redirection."
Gulamhuseinwala of the OBIE said in his reflection on the first year of open banking: "Our focus for 2019 is firmly fixed on an enhanced user experience - what we have today is, for sure, a step in the right direction but it does not yet meet the high standards of conformance and performance we expect. However, I am confident that 2019 - post March and the implementation of v3 of our standards - will bring a mobile-enabled and frictionless customer journey."
The key for the year ahead will be continued innovation and collaboration in the industry to create solutions that get at the heart of what open banking was intended to achieve: simpler and more transparent financial management for customers and businesses; while also easing customer concerns around data security.
As Ed Maslaveckas, co-founder and CEO of fintech Bud said: "We know that the regulatory standards are going to evolve next year, making it much more attractive for companies to make their products more flexible, and as this happens it will free up innovative companies to start designing more engaging experiences.
"As 2019 progresses we'll see more and more of that kind of opportunity, to create smart automations that save people time whilst helping them with their finances."
Looking ahead, Leon Muis, COO of fintech Yolt, said: "2019 looks set to be an exciting year for open banking as we see the legislation really take hold and move into the next phase to include credit cards and savings plus the increasing availability of PIS (Payment Initiation Service) APIs. The success of APIs has been proven and it is now time for all UK banks to improve the quality and availability of their APIs to enable more consumers to benefit from open banking.
"Taking this internationally, the UK has proven legislative success, with the implementation of PSD2 imminent, European banks should take note and ensure they are ready."
As Gulamhuseinwala said: "Consumers are gradually being offered products and services which will securely help them move, manage and make more of their money."
Senthil Ravindran, EVP and global head of xLabs at Virtusa added: "Open banking has been 'in the wild' for almost a year now, and though we've seen a handful of consumer apps, it's largely failed to spark the promised revolution, mostly down to banks' reluctance to give away data to fintech rivals."
He predicts that this will change in 2019, "with competition giving way to collaboration".