Consumer Duty Raised the Bar on Affordability. Open Banking Is How You Clear It.

On 9 June 2026, the Financial Conduct Authority published Consultation Paper CP26/18, its most significant mortgage affordability intervention in years. The stated aim is to give more people, including those with variable incomes, older borrowers and those with past credit difficulties, a better chance of getting a mortgage they can afford. But tucked inside the proposals is a phrase that should concentrate minds across every lending and broker business in the UK: lenders must judge affordability using a borrower's complete and up-to-date financial position.

Complete. Up-to-date. Those two words are doing a lot of work. And for firms still relying primarily on payslips, three months of bank statements, and a credit file snapshot, they represent a meaningful challenge. The regulator is not mandating open banking by name. But it is describing, with increasing precision, exactly the kind of affordability evidence that open banking data provides.

What Consumer Duty actually demands from lenders

Consumer Duty, which came into full effect for existing products in July 2024, set a high bar for how firms must treat customers. It isn't being replaced or relaxed by CP26/18; the FCA is explicit that the new proposals sit on top of that foundation, not in place of it.

What this means practically is that lenders and brokers can no longer treat affordability as a point-in-time checkbox. The Duty requires firms to monitor outcomes continuously, develop the data and governance frameworks needed to evidence those outcomes, and demonstrate that their processes genuinely reflect each customer's financial circumstances.

The FCA has already published findings of poor practice in the second charge mortgage market, specifically calling out inadequate affordability and expenditure assumptions that didn't reflect real customer situations. For firms operating in first charge residential and buy-to-let markets, the message is the same: your affordability process needs to be defensible with evidence, not just documented with process.

The evidence gap in traditional affordability

Most affordability processes today rely on a combination of declared income, payslips, credit reference data, and a sample of bank statements. Each of these has known limitations. Payslips don't capture variable income, self-employment earnings, rental income, or gig economy work. Credit files reflect past behaviour but can be months out of date. And asking a client to gather and submit three months of statements introduces delay, friction, and the possibility of selective or incomplete disclosure.

The scale of the problem is substantial. Research from PwC estimates that up to 20 million UK adults are financially underserved due to inaccurate or incomplete credit data. Separately, 38% of UK adults report that their credit score has negatively affected their ability to access financial services. This isn't a fringe issue; it represents a significant portion of the mortgage-eligible population being assessed on data that may not accurately reflect their actual financial position.

For lenders, the risk runs in both directions: approving loans based on incomplete data, or declining applications that are genuinely affordable. Neither outcome sits comfortably under Consumer Duty.

"50% of sole applicants provided Open Banking consent — well above the 10% expected. Of those, 95% completed the process."

Leeds Building Society / L&C Mortgages open banking pilot, 2024–25

What open banking data actually provides

Open banking connects directly to a borrower's bank accounts, with their consent, and returns categorised transaction data in real time. Rather than asking a client to export PDFs of bank statements, the lender or broker receives a structured, machine-readable view of income, committed expenditure, discretionary spending, debt obligations and financial patterns over 90 days or more.

Providers such as LendingMetrics, whose OpenBankVision product draws on data from 99% of UK banks, have built affordability-specific categorisation layers on top of this raw data. The output isn't a stream of transactions; it's a structured affordability picture ready for underwriter review.

As of March 2025, there were 13.3 million active open banking users in the UK, up 40% year-on-year, with one in five consumers and businesses now using the technology. Consumer familiarity is no longer a barrier. Consent rates in live mortgage pilots have substantially exceeded expectations.

What lenders are already doing

Leeds Building Society provides the clearest case study in the UK mortgage market. Working with broker network L&C Mortgages and Experian's open banking platform, they launched a pilot in mid-2024. The results are worth quoting directly: statement retrieval dropped from four days to minutes; Decisions in Principle that had taken 24 hours were returning in 11 seconds for eligible cases, with 80% of the DIP journey automated. Consumer consent rates far exceeded expectations; 50% of sole applicants opted in, against an anticipated 10%, with 95% completing the process.

The pilot was not a one-off experiment. By January 2025 it had scaled with L&C Mortgages, and by March 2026 Leeds BS had extended the programme to Just Mortgages, its second major broker partner. What started as a proof of concept is now becoming standard operating procedure for one of the UK's larger building societies.

The IMLA forecasts gross mortgage lending reaching £295 billion in 2026. The volume of cases flowing through broker and lender pipelines makes even marginal efficiency gains commercially significant, and the Leeds data suggests the gains are far from marginal.

What this means for brokers

For broker principals, Consumer Duty and CP26/18 are often framed as a lender problem; the affordability assessment happens at the lender's end, after all. But this understates brokers' exposure. The FCA expects intermediaries to understand the suitability of the products they recommend, and suitability is inseparable from affordability. Recommending a mortgage product without adequate evidence of the client's financial position is a conduct risk, not just an underwriting one.

Open banking also addresses a practical broker pain point that often goes undiscussed: document collection. The time a case handler spends chasing bank statement PDFs, reconciling inconsistencies and rekeying figures is time that generates no revenue. A workflow that replaces that with a single consent link, delivering categorised, lender-ready data within minutes, is a meaningful operational improvement, not just a regulatory one.

How Moxim helps brokers and lenders respond

Moxim is a UK-based SaaS affordability layer built for the realities of the intermediary mortgage market. Via API, Moxim connects to existing broker and lender workflows, without requiring a large IT project or lengthy integration, and delivers categorised open banking transaction data alongside structured affordability scoring and lender-ready reports for underwriters.

The platform is designed specifically for firms that aren't household names: regional building societies, specialist lenders, and broker networks that want the data quality advantages of open banking without building a data science team to support it. The methodology is transparent, the outputs are auditable, and deployment is measured in weeks, not months.

With CP26/18 in consultation until 28 July 2026 and Consumer Duty outcomes monitoring already live, the window to get ahead of this regulatory direction, rather than respond to it reactively, is narrowing. Firms that have open banking affordability evidence embedded in their processes before the FCA's final rules land will be in a substantially stronger position than those that don't.

Moxim collates a client's income, spending, credit, identity and property data into a clean affordability assessment the moment they share access — removing manual data entry and document chasing from case prep. We are currently onboarding pilot broker partners.

Join the broker pilot →

Evidencing good outcomes for a non-standard client

Take a client on a zero-hours contract with genuinely stable earnings built up over two years, just with month-to-month variation in hours worked. Under a payslip-led assessment, that variation reads as risk; the lender sees three payslips with three different figures and has to apply a judgement call, often a conservative one, about which number to use.

Open banking data shows the same client differently: twelve or more months of income actually landing, a clear seasonal pattern rather than noise, and spending that stays within it every month bar one. That is precisely the kind of evidence a Consumer Duty review is looking for when it asks whether a firm delivered a good outcome for a financially vulnerable or non-standard customer, not a judgement call buried in an underwriter's notes, but a documented, reproducible picture of why the decision was made.

The same logic extends to older borrowers assessed on pension and investment drawdown income, and to borrowers with a past credit difficulty who have since rebuilt a clean financial pattern. In each case, the traditional file leans on a static snapshot that was never designed to capture a change in circumstances; the open banking file shows the change directly, in the transactions themselves, without requiring the customer to argue their own case from scratch.

For a compliance lead building the evidence pack CP26/18 will eventually expect, that distinction matters more than it might first appear. A file that can only assert good treatment invites challenge. A file that can demonstrate it, transaction by transaction, closes the argument before it starts. Moxim outputs are built with exactly that reviewer in mind: every affordability score traces back to the underlying categorised transactions, so a compliance lead can answer an FCA query with evidence rather than a reconstruction exercise months after the case was written.

Sources

• FCA CP26/18: Mortgage rule review — supporting first-time buyers and underserved consumers (9 June 2026)
• FCA PS25/11: Simplifying responsible lending and advice rules (July 2025)
• FCA: Second charge mortgages — improving outcomes for consumers (good and poor practice)
• Open Banking Ltd: Impact Report 7 — open banking delivers real-world impact as adoption accelerates year-on-year
• Open Banking Ltd: Open banking in 2025 — now part of the UK's everyday financial life
• Experian: How Open Banking is reshaping mortgage lending at Leeds Building Society
• Mortgage Solutions: Leeds BS and L&C Mortgages open banking pilot streamlines mortgage applications (July 2025)
• Mortgage Solutions: Leeds BS trials open banking pilot with Just Mortgages (March 2026)
• LendingMetrics: Improving affordability checks to protect vulnerable customers
• IMLA: Predicts healthy lending growth for 2025, greater intermediary business and more remortgaging (December 2024)
• Finbryte: Breaking down the 2025 Open Banking Impact Report (PwC / underserved adults data)