By the close of 2025, two governments were pulling financial data infrastructure in opposite directions. India kept expanding public rails that lenders and payment apps are expected to plug into. The United States moved to loosen the rule that was supposed to force banks to open consumer data to fintechs at all. Meanwhile, a European bank chose to fund embedded B2B credit directly rather than compete with it.
India's Public Lending Network Passes a Real Adoption Test
The Reserve Bank of India's Unified Lending Interface had 64 lenders onboarded as of December 12, 2025. That is up from 36 a year earlier, and includes 41 banks and 23 non-banking financial companies (Business Standard, 2025). Those lenders now draw on more than 136 data services spanning 12 loan journeys, including land records, satellite data and credit guarantee information, through the same consent-based, API-first model UPI used for payments.
Adoption had been slower than the RBI wanted through most of 2025. Banks flagged difficulty wiring ULI into their existing loan-origination systems. Even so, the jump to 64 lenders in a single year is the first clear sign the platform is moving past pilot status toward the small-ticket and agricultural lending it was built for.
UPI Turns Into an Export Product
UPI is now accepted in eight countries: Bhutan, Singapore, Qatar, Mauritius, Nepal, the UAE, Sri Lanka and France. On December 5, 2025, India's Financial Services Secretary M. Nagaraju said the government is in talks with seven to eight more countries to extend acceptance further, with a particular focus on East Asia (Business Standard, 2025).
The push is no longer just a payments story. India has folded UPI acceptance into ongoing trade negotiations, using it as leverage alongside the fintech sector's cost and scale advantages. NPCI's international arm had already signed agreements with Japan's NTT Data in October 2025 and with Malaysia's PayNet, working toward a phased link between UPI and DuitNow QR ahead of this latest round of talks.
The CFPB Moves to Rewrite Open Banking Access
On December 10, 2025, the Consumer Financial Protection Bureau signaled it will issue an interim final rule rewriting its Section 1033 "open banking" rule under the Dodd-Frank Act. It plans to bypass the standard notice-and-comment process because the agency expects to run out of funding by December 31 (American Banker, 2025; Consumer Financial Services Law Monitor, 2025). The revised rule is expected to let banks charge fintechs fees for accessing consumer financial data, reversing a fee ban written into the original 2024 rule.
That original rule was meant to guarantee fintechs could pull a customer's own bank data for lending decisions, budgeting apps or account aggregation, without a bank charging for or blocking access. Legal observers expect the interim rule to draw fresh lawsuits over its truncated rulemaking process, given how much of the fintech lending and account-aggregation business depends on the outcome.
A European Bank Chooses to Fund Embedded Finance Rather Than Build It
On December 10, 2025, Berlin-based B2B payments firm Mondu secured a 100 million euro debt facility from J.P. Morgan Payments and joined its Partner Network (Finextra, 2025; Tech.eu, 2025). Through the partnership, J.P. Morgan refers corporate clients to Mondu's invoicing, instalment, direct debit and account-to-account payment products, rather than offering competing deferred-payment tools of its own.
Founded in 2021, Mondu says the facility will fund its expansion across Europe's B2B payments market. The deal fits a broader pattern. Banks increasingly appear willing to route embedded credit through fintech partners instead of building it in-house, the same buy-over-build shift showing up across enterprise embedded finance more widely.
What to Watch Next
The UK's Financial Conduct Authority is scheduled to bring Buy Now Pay Later products, formally reclassified as Deferred Payment Credit, under regulation starting July 15, 2026. Most firms will need to register for a temporary permissions window by mid-2026 to keep operating while they seek full authorisation (Skadden, 2025). If the CFPB's interim rule survives the litigation it is expected to face, the US and UK will be moving in opposite directions on consumer credit oversight at nearly the same time. One is retreating from a data-access mandate. The other is extending regulation to a product category it never covered before.