Open Banking was launched in the UK in 2017 as part of a package of improvements following the Competition and Markets Authority's (CMA) market investigation into retail banking. The CMA ordered the 9 largest retail banking providers in the United Kingdom to open up customer data using secure data protocols. To deliver this outcome, banking providers were required to establish an independent Open Banking Implementation Entity (OBIE), currently overseen and chaired by Charlotte Crosswell OBE as Implementation Trustee. A Roadmap was put in place that set out the specific requirements on the 9 banking providers.
Following a report from the Implementation Trustee, the CMA has determined that the 6 largest banking providers in the UK (Barclays, HSBC, Lloyds, Nationwide, NatWest and Santander) have now implemented all the requirements of the Open Banking Roadmap, and the Roadmap is therefore substantially complete.
Open Banking enables consumers and businesses to share their transaction data securely with trusted third parties, who can provide customers with applications and services which save them time and money. In a market where larger, established banks have accounted for over 80% of the current account market for many years, Open Banking improves financial decision making for consumers and drives down costs for small and medium sized businesses, boosting competition and innovation. Open Banking now has over 6 million active users in the UK who will continue to benefit as Open Banking reaches this important milestone. Open Banking is widely recognised as a major success, with many other countries considering similar open standards.
Despite having implemented the requirements of the Open Banking Roadmap, the 6 banking providers have continuing obligations under the CMA's Retail Banking Order, to allow customers to access their data securely and benefit from Open Banking. The OBIE will continue to ensure that the 6 banking providers maintain the required standards and will promote Open Banking to encourage industry adoption.
Alongside this, the OBIE will continue its work to ensure that the 3 remaining major banks (Allied Irish Bank, Bank of Ireland and Danske) that have not implemented all of the requirements of the Open Banking Roadmap do so as soon as feasible. To support the OBIE in this, the CMA will consider enforcement action as appropriate to ensure this happens in a timely way.
Together with the OBIE, the CMA will continue to work with government and the other regulators to support a smooth transition of the work undertaken by the OBIE under the CMA's order to a future entity that can expand the benefits of Open Banking beyond the scope of the CMA's Order. The Joint Regulatory Oversight Committee (JROC), set up in March 2022 and comprising HM Treasury, the CMA, Financial Conduct Authority (FCA) and the Payment Systems Regulator (PSR), will take Open Banking forward and will be setting out its recommendations on the design of the future Open Banking entity in Q1 2023.
Sarah Cardell, Chief Executive of the CMA, said:
It is fantastic to see how many consumers have benefited from Open Banking since the CMA's Order was issued in 2017 - which has transformed the way millions of people manage their money.
Today's update is an important milestone. The largest banking providers in the UK have completed the Roadmap, and so Open Banking moves into a new phase.
We will continue to ensure the standard is maintained and that providers are held to their obligations under the CMA's Order, including making sure those remaining banks reach the same data sharing standard.
The OBIE's work is vital to the ongoing success of Open Banking and we look forward to continuing to work closely with the FCA, PSR and HM Treasury to help deliver the future arrangements for Open Banking.
Notes
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Open Banking now has over 6 million active users in the UK.
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The Payment Services Regulations 2017 (PSRs), which implemented PSD2 in the UK, took open banking further by providing a legal right for trusted third party providers to access payment accounts accessible online, provided they have the customer's explicit consent. All account providers must allow TPPs to access the payment account data and make payment
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OBIE previously announced that Charlotte Crosswell will step down from her role as Implementation Trustee on 31 January 2023. The CMA has been actively recruiting a new Implementation Trustee to oversee the next phase of work for the OBIE. This process is expected to conclude shortly.
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The CMA's market investigation into the retail banking sector (Retail Banking Market Investigation) found separate adverse effects on competition (AECs) in the retail banking markets in both Great Britain (GB) and Northern Ireland (NI). The CMA put in place the Retail Banking Market Investigation Order 2017 (the Order) to remedy these AECs). The Open Banking remedy in Part 2 of the Order required the 9 largest banking providers by market share in GB and NI (the CMA9) to setup and fund the OBIE to develop read-only open and common technical and product data standards and read and write, open and common banking standards for the secure sharing of transaction data. The CMA9 are required to grant free access to this data to Third Party Providers who, using this data, can provide services to consumers to address the AECs.
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The Order set out the high-level requirements for Open Banking. The detailed technical requirements for developing and implementing the read-only and read-write data standards were set out in the Open Banking Roadmap documents. The most recent iteration of the Open Banking Roadmap was published in May 2020 (Notice of approval of changes to the Agreed Timetable and Project Plan).
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The CMA wrote to the OBIE in April 2022 and further in August 2022 regarding the conditions that need to be fulfilled in order for the implementation of the phase of the Roadmap to be considered to be complete.
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The Joint Regulatory Oversight Committee (JROC) set out its initial joint statement in March 2022 and its most recent statement on the future of Open Banking was published in December 2022.
- In this statement 'Allied Irish Bank' refers to Allied Irish Bank (GB), 'Bank of Ireland' refers to Bank of Ireland (UK) plc, 'Danske' refers to Northern Bank Limited, trading as Danske Bank, 'HSBC' refers to HSBC Group, 'Lloyds' refers to Lloyds Banking Group, 'Nationwide' refers to Nationwide Building Society and 'NatWest' refers to NatWest Group.