PSD2 (Revised Payment Services Directive) is the EU-wide regulation that mandates open banking access across the EEA but does not specify a single technical standard. Each country implements PSD2 differently: Berlin Group is the most common technical standard in Germany and Austria; STET is used in France; and other markets have their own implementations. The UK Open Banking Standard, by contrast, is a single, prescriptive technical specification developed by the OBIE that all CMA9 banks plus many smaller UK banks and building societies implement consistently.

For developers, this difference matters. UK Open Banking APIs are typically more uniform, better documented, and easier to integrate than PSD2 APIs across multiple EU countries. The UK standard also tends to expose richer data and a more consistent consent UX. After Brexit the UK retained equivalent rules, so an FCA-issued AISP/PISP licence does not passport into the EU, and EU-issued licences do not passport into the UK — most teams either get separate licences in each region or rely on an aggregator that holds both.

Most UK and European aggregators (TrueLayer, Tink, Yapily, Plaid, Salt Edge) abstract this difference for developers — one API surface, multiple regulatory regimes underneath. See best-open-banking-apis-uk for UK-specific picks, which-api-aggregators-support-european-psd2 for EU coverage, and what-is-uk-open-banking-standard for the standard's full scope.

For a side-by-side comparison with UK bank counts, AIS/PIS/VRP support, licence model, and pricing, see Open Banking APIs in the UK.