The term “Smart Data” was first used in 2018 in the UK Government’s “Modernising Consumer Markets” Green Paper published in April 2018. Its use has subsequently grown to by the official name for customer account data portability and is defined as:

The secure sharing of customer data – at the customer’s request – with Authorised Third Parties (ATPs), who use this data to provide innovative products and services that benefit the customer.

A Smart Data scheme is therefore the policy, regulatory (or contractual), technical and governance framework that enables the secure, standardised sharing of Smart Data for a specific sector, for example, Open Finance or Open Energy.

The Open Transport Initiative (OTI) has been campaigning and working with public & private sector organisations to implement an “Open Banking for Transport” scheme for the UK for many years. But creating a Transport Smart Data scheme for the UK is quite complex to achieve and will not happen by itself. The UK Government will therefore need to oversee a combination of legislative mandates, institutional oversight, and technical standardisation for this to happen.

Under the Data (Use and Access) Act 2025, the Government now possesses the statutory powers to require industry participation, ensuring that data holders share both business and customer data with ATPs.

The following specific interventions are now required to deliver this scheme.

1. Legislative and Policy Leadership

• Mandating Participation: The Government will use secondary legislation under the Data (Use and Access) Act (DUAA) to mandate that transport firms participate in the scheme. This prevents data silos and ensures no single entity or mode is disadvantaged by being a first mover.
  
• Leading Departments: The Department for Transport (DfT),  will lead on policy for transport, while the Department for Business and Trade (DBT) acts as a central source of expertise for establishing the overarching Smart Data economy.
  
• Discovery and Prioritisation: A joint research project between DBT and DfT is currently underway to identify and test feasible use cases. This will inform a formal call for evidence in 2026 to further understand the value of a transport scheme and prioritise specific use cases, such as freight logistics or accessibility tools.

2. Institutional Governance and Oversight

• Regulatory Remit: Since the transport regulatory landscape is fragmented, UK Government identifies the Office of Rail and Road (ORR) as the most likely lead regulator to enforce compliance with data-sharing mandates. Other relevant bodies like the Civil Aviation Authority (CAA) and Driver & Vehicle Standards Agency (DVSA) may be involved in mode-specific areas.
  
• Cross-Sector Coordination & Implementation: The Government may create a Smart Data Coordination Entity (SDCE), potentially housed within DBT. This will ensure a transport specific scheme is interoperable with other sectors like energy and finance. They may also appoint a sector-specific Smart Data Implementation Entity (SDIE) (through a competitive process) to lead delivery, develop standards, and handle customer complaints.

3. Establishing a “Trust Framework”

The Government must define the overarching rules that govern the ecosystem, including:

• Consent Mechanisms: Establishing standardised processes for customers to securely give and revoke consent for their data to be shared.
  
• Accreditation of ATPs: Creating a central service to vet and approve third-party providers, ensuring they meet strict security and privacy criteria.
  
• Consumer Protection: Designing dispute resolution mechanisms and providing clear redress channels for users when issues arise.

4. Technical Foundations and Standardisation

• API-First Approach: The DfT’s Transport Data Action Plan identifies Application Programming Interfaces (APIs) as the expected method for sharing data, since they allow for secure, on-demand, and automated querying.
  
• Mandate Common Standards: The Open Transport Initiative has already developed Open Standard and freely available APIs to enable Smart Data sharing for any transport mode. These define the technical standards for data formats and structures to ensure different systems can talk to each other in an interoperable way. The standards have even been tested and validated in OTI’s Smart Data Challenge prize Transport Dashboard.
  
• Data Quality Assurance: Effective intervention includes coupling data-sharing requirements with strict quality standards to ensure the information in source systems is reliable enough for commercial use.

5. Financial Investment

The Government has committed to investing at least £36 million over four years to develop new Smart Data schemes across the economy. This includes funding for industry-led pilots to test practical applications before full-scale rollout, thereby providing the infrastructure, research, and thought leadership necessary to reach a target of five or more active Smart Data schemes by 2030. And yes, we do expect Open Transport to be one of those.

You can find out more about the Open Transport Initiative’s work here.