5 things you need to know from the UK’s new Smart Data Strategy

The UK’s Smart Data Strategy, published on 26 March, sets out the government’s aims and plans for smart data in the UK until 2035. With the necessary primary legislation now in place under the Data (Use and Access) Act 2025 (DUA Act) to support the development of smart data schemes in sectors across the UK economy, the Smart Data Strategy provides (some) answers to key outstanding questions for organisations:

Which sectors are being prioritised for smart data schemes and what developments are expected soon? 

The government is aiming to have 20 or more interoperable smart data schemes (that allow the consented sharing of customer (or business) data with authorised third parties) in the UK by 2035. Initial focus is on smart data schemes in 10 sectors identified as key growth drivers: banking, finance, energy, road fuels, property, retail, digital markets, transport, telecoms and agrifood. Among those 10, schemes in banking, finance, property and energy look to be taking prominence, with government statistics showing that these four schemes could add £9.6 billion to UK GDP annually by 2043. 

The strategy sets out some concrete next steps for a number of schemes, including: 

• A detailed consultation on an energy smart data scheme (this could facilitate the sharing of real time customer energy usage data between providers, as well broader information sets, such as on tariffs).
• A consultation on the Open Banking scheme, in relation to the establishment of a long-term regulatory framework for the scheme under the DUA Act and oversight of Open Banking moving to the FCA.
• A call for evidence on a property smart data scheme, informed by the government’s ongoing work to reform home buying and selling (including their consultation last autumn).
• A call for evidence on the potential value of a transport smart data scheme. The strategy indicates that such scheme could pave the way for improvements in both business and consumer travel, including for freight logistics and to facilitate green travel choices.
• A call for evidence on a smart data scheme in retail, to assess the potential of a scheme beyond the scope of the online grocery retail segment. The government has already modelled that an online grocery smart data scheme could add £479 million to UK GDP a year between 2028 and 2035. 

Complementing the strategy, the FCA has separately published a roadmap on the delivery of open finance (discussed further in this blog), prioritising exploration in the areas of SME access to credit and consumer access to mortgages. The FCA will publish a discussion paper focused on the first open finance scheme in Q4 2026, with a view to publishing a discussion paper on delivering a long-term regulatory framework in H1 2027. 

What about interoperability between schemes? 

While smart data schemes are being developed on a sector-by-sector basis, the government is looking to ensure interoperability between the various sector schemes. It recognises that doing so could enable use cases and services that leverage data from multiple schemes. To facilitate this, the government is developing a Smart Data Guidebook, that will cover scheme design decisions and promote best practice across schemes, e.g. on governance, security and customer experience. The Guidebook’s development is being overseen by a refreshed Smart Data Council, that will also foster additional linkages between sector work. The government is also exploring introducing a multi-sector data testing environment, building on the FCA’s Smart Data Accelerator.  

How will smart data schemes support AI? 

The strategy suggests that the development of smart data schemes could boost AI adoption and the development of AI-enabled services in the UK, via providing ‘AI ready data’, although detail of how smart data will be used to support AI in practice is lacking at this stage. While clearly still in development, the UK’s ambition to leverage smart data flows for AI mirrors similar thinking in the EU, as outlined in the EU’s latest Data Union Strategy (discussed here).

Is the compliance burden being factored in?

Smart data schemes will place new compliance obligations on organisations, both in terms of preparing for and ongoing compliance with scheme requirements (as discussed further here) alongside the existing web of digital regulation. The strategy outlines that the government is working to address these concerns, including by exploring where smart data can be used to reduce existing regulatory admin burdens, e.g. by automating regulatory reporting. In delivering smart data, the government is working in partnership with UK regulators, including via the Digital Regulation Cooperation Forum and with the CMA which should help mitigate potential frictions between smart data and other laws. Extensive international cooperation is also central to the government’s plans.

What should organisations be doing now? 

The Smart Data Strategy confirms the government’s long-term ambitions for smart data and shows that concrete progress is being made towards scheme development in a broad range of sectors. However, progress in most schemes is still at an early stage with much detail still to be worked out. For now, organisations should closely monitor smart data plans in their sector, as well as the progress of front-running schemes, such as Open Banking, as they will give insights into how the new schemes will operate in practice.