Thought Leadership | Why Open Banking needs a Human Upgrade

Tim Kelleway of D.One recently offered a compelling view on how Open Banking is reshaping credit decisioning. His piece, titled Why Open Banking data heralds a new era of credit decisioning rightly called out the limits of CRA data and the opportunity Open Banking offers for expanding financial inclusion.

At Serene, we see these same issues every day – especially among the so-called “credit invisibles.”

But what if the biggest transformation Open Banking can enable isn’t just better credit decisions? It’s better customer care.

We’re not just in a lending crisis. We’re in a care crisis.

And Open Banking has a much bigger role to play.


From Risk Scores to Real Lives

At Serene, we don’t use Open Banking data to assess affordability. We use it to detect early signs of distress.

We look for subtle but powerful patterns – missed payments, income disruptions, changes in spending behaviours linked to emotional stress. These often signal deeper life events: mental health decline, bereavement, illness, burnout, or a breakdown in resilience.

But today, most financial institutions miss these signs. Not because they don’t care – but because they don’t have the tools to see them.

In our recent UK-wide survey:

  • 56% of consumers said they’d faced a personal or financial challenge—but didn’t ask for help
  • The top reasons? Shame. Distrust. Time pressure. Or simply believing support wasn’t available

That’s not just a service gap. That’s a trust gap.


Lending Logic vs. Human Logic

As Tim rightly points out, lending decisions often revolve around two questions:

  1. Will this person pay us back?
  2. Can they afford it?

But under new regulations like the Financial Conduct Authority’s Consumer Duty, a more urgent question is emerging: What’s going on in this person’s life—and how can we support them?

Here’s what the broader data tells us:

  • 7M+ UK adults have no credit history – but 97% have a bank account
  • 52% show signs of vulnerability – yet fewer than 10% are identified by their provider

That’s not just a missed opportunity. It’s a missed responsibility.

And it’s time to get personal.


Open Banking with Empathy

Our survey also revealed a strong willingness to share data – when the purpose is clear and trust is in place:

  • 85% said they’d be open to sharing their data via Open Banking if it led to more tailored support
  • 42% said they’d prefer to give consent to an independent wellbeing platform like Serene—compared to just 20% for their bank or lender

This tells us three things:

  • People want help – not just products or incentives
  • They want control over their data
  • They trust third parties to act in their best interest

That’s where Serene comes in: a neutral, consent-first bridge between customers and providers.

We enable personalised, context-aware insights – without needing full access to raw data.


From Credit Access to Proactive Support

Tim is right – Open Banking is helping level the playing field for credit access.

But now, we need to apply that same innovation to proactive support.

With the right signals and ethical AI, we can spot and respond to risk before it becomes a crisis.

That means:

  • Nudging budgeting help before a payment is missed
  • Offering flexible repayment terms when income drops
  • Connecting people with practical, emotional and financial support – automatically and with dignity
  • Embedding situational care into systems, journeys and culture

This isn’t just regulatory compliance. It’s AI-enabled empathy – at scale.


What Happens Next?

The next frontier for Open Banking isn’t just better lending or financial inclusion. It’s emotional and situational inclusion.

That means supporting customers across the full journey.

We’re seeing a growing appetite to layer vulnerability intelligence on top of existing risk models – not to replace them, but to enhance them.

This adds depth to decisions, context to support, and confidence to credit strategies – where approvals become more inclusive, servicing more personalised, and risk more contextualised.

Serene adds depth to how risk gets split – bringing emotional, behavioural, and context-aware insights into the equation.

Because the truth is, vulnerability is the norm – not the exception.

And in a world that’s only getting more complex, the question is no longer

can we use Open Banking for good?

It’s whether we choose to.


Want to learn more about what consumers want from financial services?

👉 Download our full consumer insights report ‘Empowering Change: What Consumers Want from Financial Services

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