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18 March 2021 6 min read

The Blueprint for the Future of Open Banking

We are delighted to have supported UK Finance and the financial services ecosystem in writing the Blueprint for the Future of Open Banking.

The UK is at the forefront of delivering innovation and change through Open Banking APIs – leading discussions across Europe and worldwide, with API usage doubling every 5 months. This progress is largely due to the regulatory foresight stemming from the CMA order, the creation of the Open Banking Implementation Entity (OBIE) and investment from market participants. As implementation of the CMA Order completes in 2021, we must transition to an Open Banking model that continues to meet the requirements of the industry’s diverse group of over 700 participants.

We believe 2 key elements of the current OBIE model should be retained:

  1. The majority of the services the OBIE provides today: be they operational, such as the directory and dispute management, the standards or the role that OBIE plays in bringing together members of the ecosystem around key areas of change
  2. The operational model: as a single entity (albeit with the monitoring activity that is specific to the CMA9 separated out)

However, the market has changed substantially since OBIE was set up in 2016. There are now multiple providers and the entity has outgrown the CMA order, therefore we believe that who the provider is and requirements for each of the service capabilities should be reviewed. Similarly, as the market evolves over the next 12 months (e.g. with the potential to use the entity to support other industries or areas such as digital identity) it may be that the entity will need an OB Futures board – splitting off macro longer term strategic considerations from the day to day operations.

However, we believe there is a need to make substantial changes to other parts of the model, in particular:

  1. To the current governance model of OBIE, reflecting a future entity that serves an ecosystem as compared to the one that was originally set up for  a single regulatory purpose.
  2. To the funding model to transition the entity to one that is financially self-sustaining. This cannot be achieved on day 1. We have recommended that the CMA9 continue to underpin the model for a period of 3 years. However, an action plan to make the entity self-sustaining in 3 years needs implementation as part of the transition.

Click here to read the full report:

Blueprint for the Future of Open Banking