Category: Trustee

The Open Banking Implementation Entity (OBIE) has today announced the appointment of Theresa Casey as General Counsel to strengthen the senior leadership team.

Ms Casey is a highly qualified General Counsel, with strong corporate governance, transformation, and financial services experience, most recently as General Counsel and Company Secretary at N Brown Group Plc. 

This latest senior hire follows a number of key leadership appointments in recent months.

In February, Henk Van Hulle was appointed as the organisation’s first Chief Executive Officer. The creation of this new position was part of a package of changes to deliver a management framework and strong, effective governance for the OBIE.

Towards the end of 2021, two independent non-executive directors, Barbara Ridpath, and Jeremy Newman, were appointed to the OBIE Board. Since joining the OBIE, their considerable experience and expertise has already played a positive and impactful role in strengthening the organisation’s governance, while also providing independent oversight and scrutiny.

Significant work has also been underway to review the OBIE’s HR agenda, corporate governance, conflicts of interest, culture and values, and procurement processes. In January 2021, the OBIE appointed a new People and HR Director, Debbie Lombard, to lead on developing HR practices and workplace culture, and ensure these are understood and adopted across the organisation.

The appointments to the senior leadership team follow changes introduced since the publication of the Alison White Report. Further to the report’s release, the OBIE moved quickly to appoint PA Consulting to provide recommendations on where action was needed.

Amongst the key recommendations of this analysis was to ensure the provision of leadership and senior-level appointments, in order to assess, address and action the issues identified in the report.  Furthermore, the HR, culture and people agenda, organisational structure, corporate governance and conflicts of interest were reviewed. Much of this work is already in train and being completed at pace, and will be subject to continuous review.

Charlotte Crosswell, who was appointed as Chair and Trustee of the OBIE in October 2021, welcomed Ms Casey’s appointment. She said: “I am delighted to welcome Theresa as the OBIE’s new General Counsel and believe her experience will further strengthen the leadership of the OBIE. This completes the additions to our senior team and will be critical in embedding and driving forward the significant changes we have made to our governance, management, processes, and policies, alongside our workplace practices and culture. When I joined the OBIE, I promised to listen, learn and act, and this remains my focus, as well as ensuring that the progress we have made to date, keeps advancing.”

Henk Van Hulle, CEO of the OBIE said: “Completing the appointments to our senior leadership team strengthens the OBIE’s governance as we prepare for our next phase and the imminent CMA decision on the future arrangements for open banking. We are privileged to have a very talented team at the OBIE, and I thank them, past and present, for all of their hard work to establish open banking in the UK and bring its benefits to over 5 million consumers and small businesses.”

Ms Casey said: “I am pleased to be joining the OBIE at this time and I am committed to working with the Board and CEO, and the rest of the management team to ensure the OBIE of today, and whatever new entity we transition to, remains a culturally progressive, inclusive, organisation with strong governance and is truly fit for the next stage.”


About Us

Open Banking Ltd is the entity set up by the CMA9 as ordered by the CMA in 2016 to deliver open banking. Its trading name is Open Banking Implementation Entity (OBIE).

The OBIE is funded by the CMA9 (Allied Irish Bank, Bank of Ireland, Barclays, Danske, HSBC, Lloyds Banking Group, Nationwide, Natwest Group and Santander). The OBIE works with the CMA9, as well as challenger banks, financial technology companies, third party providers and consumer groups.

The OBIE’s role is to:

For enquiries, please contact: CiceroOpenBankingPR@cicero-group.com, 020 7297 5965

The Competition and Markets Authority’s (CMA) today published all of the responses it received (60) to its recent consultation on the future oversight of the open banking remedies, including the submission presented by the OBIE’s Implementation Trustee, Imran Gulamhuseinwala OBE.

The Trustee’s full written response to the Consultation can be accessed here.

Imran Gulamhuseinwala said: “We are at a critical juncture in the journey of Open Banking in the UK, with the CMA set to decide the future path that journey will take in the coming weeks. I am proud of what we have achieved thus far, with the infrastructure largely built and adoption and innovation picking up pace. But we now must look to the future.

The UK has long led the world in the field of financial innovation and we have a golden opportunity for Open Banking to evolve to the next logical phase, Open Finance – opening up new products and opportunities for citizens and businesses alike. My response provides the CMA with a forward-looking and positive plan to bank what we have achieved and to prepare us for what comes next.”

The consultation, which ran from the 5 to the 29 March 2021, sought “stakeholder views on what arrangements it would be appropriate to put in place to ensure the effective oversight and governance of the CMA’s open banking remedies” following the completion of the OBIE’s existing implementation Roadmap, and to generate insight from the ecosystem on an appropriate transition process towards a future governance model.

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For further information, please contact: press@openbanking.org.uk

About Us

The Open Banking Implementation Entity (OBIE) is the entity set up by the CMA in 2016 to deliver open banking. Its trading name is Open Banking Limited.

The OBIE is governed by the CMA and funded by the CMA9 (Allied Irish Bank, Bank of Ireland, Barclays, Danske, HSBC, Lloyds Banking Group, Nationwide, Natwest Group and Santander). Its works with the CMA 9, as well as challenger banks, financial technology companies, third party providers and consumer groups. The OBIE’s role is to:

The Financial Conduct Authority (FCA) has published industry feedback from its Open Finance call for input from December 2019.

Responding to the findings, Imran Gulamhuseinwala OBE, Trustee, Open Banking Implementation Entity said:

“Both today’s report from the FCA and the recent Kalifa Review clearly highlight the transformation and the benefits that open banking is bringing across financial services.

“More than three million consumers and SMEs are using open banking enabled apps. That’s not only boosting competition and innovation, but it means that customers are getting better deals and more suitable products.

“The success of open banking is reflected in the strength of the UK’s FinTech sector. The UK has more open banking third party providers than the whole of the EU combined. That’s something not only to celebrate, but crucial in understanding how we maintain momentum and pave the way for open finance and Smart Data.”

 

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For further information, please contact: press@openbanking.org.uk

About Us

The Open Banking Implementation Entity (OBIE) is the entity set up by the CMA in 2016 to deliver open banking. Its trading name is Open Banking Limited.

The OBIE is governed by the CMA and funded by the CMA9 (Allied Irish Bank, Bank of Ireland, Barclays, Danske, HSBC, Lloyds Banking Group, Nationwide, Natwest Group and Santander). Its works with the CMA 9, as well as challenger banks, financial technology companies, third party providers and consumer groups. The OBIE’s role is to:

 

The Competition & Markets Authority (CMA) has today issued Directions to five banks in respect of the Retail Banking Market Investigation Order 2017. These Directions relate to delays in delivering certain aspects of the Open Banking programme, in particular with regard to mobile app functionality. Whilst it is recognised that four of the mandated banks have met the deadline, the Implementation Trustee of OBIE has recommended to the CMA that Directions are issued to those banks who have missed the agreed deadlines, and that enforcement processes are put in place.

Commenting on the CMA Directions, Trustee of the Open Banking Implementation Entity (OBIE), Imran Gulamhuseinwala OBE, said:

“While we are aware that the Open Banking programme has ambitious and challenging timescales, it is disappointing that some banks have needed more time to deliver some important new Open Banking functionality to their customers.

“However, we are pleased to see that four of the mandated banks have delivered these changes either on or ahead of time – which means that their customers will start to reap the benefits of the enhanced functionality and features that have been introduced.

“While it is still early days, overall it is clear that Open Banking is gaining momentum and traction, with innovative new products and services launching which will ultimately help customers move, manage and make more of their money.”

A revised Implementation Delivery Plan, which takes into account the revised deadlines agreed with the banks, and details key implementation dates on an individual bank basis can be accessed here.

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For further information, please contact:

press@openbanking.org.uk

About Us

Open Banking is a new, secure way for customers to take control of their financial data and share it with organisations other than their banks. Open Banking has the power to revolutionise the way we move, manage and make more of our money. For businesses, it is about making the management of cashflow and receiving payments cheaper and easier. Open Banking will make things simpler, faster and more convenient.

Open Banking follows the Competition & Markets Authority (CMA) investigation into the supply of personal current accounts (PCAs) and of banking services to small and medium-sized enterprises (SMEs).

Open Banking was created to enable innovation, transparency and competition in UK financial services. It is tasked with delivering the Application Programming Interfaces (APIs), data structures and security architectures that will enable developers to harness technology, making it easy and safe for individuals and SMEs to share the financial information held by their banks with third parties.

Open Banking will bring substantial benefits. It gives customers and SMEs greater market choice and greater control over their money and associated data, along with better and easier access to new financial services providers in a secure environment.

Notes to Editors:

1. Open Banking Ltd was set up by the Competition & Markets Authority (CMA) in September 2016 to fulfil one of the remedies mandated by the CMA following an investigation into UK retail banking.

2. The CMA’s investigation into the retail banking market (whose findings were published in August 2016) concluded that older and larger banks do not compete hard enough for customers’ business and that Open Banking should deliver a new, secure option for customers to be able to compare the deal they are getting from their bank.

3. Open Banking was created to enable innovation, transparency and competition to UK financial services. It is tasked with delivering the Application Programming Interfaces (APIs), data structures and security architectures that will make it easy and safe for customers to share their financial records by January 2018.

4. The data provided by Open Banking will enable developers to harness technology that allows individuals and businesses to share their financial records held by their banks with third parties.

5. Open Banking is a private body; its governance, composition and budget was determined by the CMA. It is funded by the UK’s nine largest current account providers and overseen by the CMA, the Financial Conduct Authority and Her Majesty’s Treasury.

6. The 9 mandated institutions (referred to as the CMA9) are: Barclays plc, Lloyds Banking Group plc, Santander, Danske, HSBC, RBS, Bank of Ireland, Nationwide and AIBG.

The Implementation Trustee of the Open Banking Implementation Entity (OBIE) has issued Trustee Directions under Article 11.6 and Schedule 1 of the Retail Banking Market Investigation Order 2017 to Bank of Ireland, Danske Bank and HSBC Group* (HSBCG).

These Directions come into force with effect from 20th December 2018 and will continue to be in force until such time they are varied or revoked by the Implementation Trustee under the Order.

Commenting on the Directions, Implementation Trustee Imran Gulamhuseinwala OBE said:

“Bank of Ireland, Danske Bank and HSBC have each confirmed that they are facing up to a six month delay in providing customers with the benefits of App to App Redirection for Payment Initiation Services (PIS) functionality. This functionality is due in release 3 and therefore this delay represents a failure to comply with the CMA Order.

“The majority of release 3 functionality will be in place by these banks at the required time, however the delay in App to App redirection (PIS) is disappointing and is likely to slow down the rate of Open Banking adoption. Any further slippage or failure to comply will have further repercussions and result in further Directions.”

View the Directions on the Open Banking website.

View the full list of Directions issued by the CMA under the Retail Banking Market Investigation Order (CMA website)

*  HSBCG includes HSBC Retail Bank, First Direct and M&S Bank for the purposes of this announcement

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For further information, please contact:

press@openbanking.org.uk

About Us

Open Banking is a new, secure way for customers to take control of their financial data and share it with organisations other than their banks. Open Banking has the power to revolutionise the way we move, manage and make more of our money. For businesses, it is about making the management of cashflow and receiving payments cheaper and easier. Open Banking will make things simpler, faster and more convenient.

Open Banking follows the Competition and Markets Authority (CMA) investigation into the supply of personal current accounts (PCAs) and of banking services to small and medium-sized enterprises (SMEs).

Open Banking was created to enable innovation, transparency and competition in UK financial services. It is tasked with delivering the Application Programming Interfaces (APIs), data structures and security architectures that will enable developers to harness technology, making it easy and safe for individuals and SMEs to share the financial information held by their banks with third parties.

Open Banking will bring substantial benefits. It gives customers and SMEs greater market choice and greater control over their money and associated data, along with better and easier access to new financial services providers in a secure environment.

Notes to Editors:

1. Open Banking Ltd was set up by the Competition & Markets Authority (CMA) in September 2016 to fulfil one of the remedies mandated by the CMA following an investigation into UK retail banking.

2. The CMA’s investigation into the retail banking market (whose findings were published in August 2016) concluded that older and larger banks do not compete hard enough for customers’ business and that Open Banking should deliver a new, secure option for customers to be able to compare the deal they are getting from their bank.

3. Open Banking was created to enable innovation, transparency and competition to UK financial services. It is tasked with delivering the Application Programming Interfaces (APIs), data structures and security architectures that will make it easy and safe for customers to share their financial records by January 2018.

4. The data provided by Open Banking will enable developers to harness technology that allows individuals and businesses to share their financial records held by their banks with third parties.

5. Open Banking is a private body; its governance, composition and budget was determined by the CMA. It is funded by the UK’s nine largest current account providers and overseen by the CMA, the Financial Conduct Authority and Her Majesty’s Treasury.

6. The 9 mandated institutions (referred to as the CMA9) are: Barclays plc, Lloyds Banking Group plc, Santander, Danske, HSBC, RBS, Bank of Ireland, Nationwide and AIBG.
 

Open Banking Standards to Expand Functionality and Cover all PSD2 Products

The Open Banking Implementation Entity (OBIE), the body set up by the Competition & Markets Authority (CMA) to enable a new, secure way for customers to take control of their financial data and share it with organisations other than their banks, today announces a series of important enhancements to its original scope as set out in the CMA Order (published in August 2016).

As referenced in the Chancellor of the Exchequer’s Autumn Budget today, the OBIE has now been asked by the CMA9 and Her Majesty’s Treasury to create open banking standards for all payment account types covered by the European Union’s second Payments Services Directive (PSD2). This means customers using credit cards, e-wallets and prepaid cards will also be able to take advantage of open banking services. In parallel, the CMA has today approved amendments to the agreed arrangements under the CMA Order, to include a programme of enhancements to ensure that Open Banking delivers maximum benefits for retail customers and SMEs.

The Open Banking project was created in 2016 by the CMA to bring competition and innovation to the personal and small business current account markets. The CMA mandated the nine largest current account providers in Great Britain and Northern Ireland (the ‘CMA9’) to create the OBIE and work with it to build a common set of API standards that would allow regulated companies safe and secure access to their accounts with the explicit permission of the customer.

The enhancements announced today will build on the core requirements of the CMA Order, which come into force in January 2018, and form a programme of releases throughout 2018 and into 2019.

Imran Gulamhuseinwala, Trustee of the OBIE, said:

“This is a truly innovative project and the UK is leading the world in opening up the banking system to new services and, ultimately, re-shaping it around the customer. Key to any innovation is the process of discovery and it became clear through the second half of 2017 that there is much more the OBIE could do to drive adoption of Open Banking and create a richer environment for new services. These enhancements should give even greater confidence to the FinTech community to seize the opportunity to participate fully in the financial services ecosystem.

“They will create standards for future dated, recurring and international payments as well as all the payment and product types covered by PSD2. These enhancements will maximise the benefits of open banking services for the customer. The OBIE will continue to work with the CMA, HMT, CMA9 and other stakeholders to drive this forward.”

Adam Land, Senior Director at the CMA, commented:

“Today’s announcement is a major milestone in the delivery of open banking, which will transform UK banking for retail customers and small businesses. This will make it easier for customers to manage their money, find the best deal for their needs and avoid overdraft charges.

“There is huge interest globally in the way that UK regulators have worked together with the banking industry, the FinTech sector, consumer groups and others to drive this project forward at pace. This plan, which the CMA has approved today, is both deliverable and bold in scope.”

View full details of the enhancements here.

A copy of the CMA’s Notice of approval of changes to the Agreed Timetable and Project Plan will be made available today on the CMA website which can be accessed here: https://www.gov.uk/cma-cases/review-of-banking-for-small-and-medium-sized-businesses-smes-in-the-uk.


For further information, please contact:

press@openbanking.org.uk

About Us

Open Banking is a new, secure way for customers to take control of their financial data and share it with organisations other than their banks. Open Banking has the power to revolutionise the way we move, manage and make more of our money. For businesses, it is about making the management of cashflow and receiving payments cheaper and easier. Open Banking will make things simpler, faster and more convenient.

Open Banking follows the Competition and Markets Authority (CMA) investigation into the supply of personal current accounts (PCAs) and of banking services to small and medium-sized enterprises (SMEs).

Open Banking was created to enable innovation, transparency and competition in UK financial services. It is tasked with delivering the Application Programming Interfaces (APIs), data structures and security architectures that will enable developers to harness technology, making it easy and safe for individuals and SMEs to share the financial information held by their banks with third parties.

Open Banking will bring substantial benefits. It gives customers and SMEs greater market choice and greater control over their money and associated data, along with better and easier access to new financial services providers in a secure environment.

Notes to Editors:

1. Open Banking Ltd was set up by the Competition & Markets Authority (CMA) in September 2016 to fulfil one of the remedies mandated by the CMA following an investigation into UK retail banking.

2. The CMA’s investigation into the retail banking market (whose findings were published in August 2016) concluded that older and larger banks do not compete hard enough for customers’ business and that Open Banking should deliver a new, secure option for customers to be able to compare the deal they are getting from their bank.

3. Open Banking was created to enable innovation, transparency and competition to UK financial services. It is tasked with delivering the Application Programming Interfaces (APIs), data structures and security architectures that will make it easy and safe for customers to share their financial records by January 2018.

4. The data provided by Open Banking will enable developers to harness technology that allows individuals and businesses to share their financial records held by their banks with third parties.

5. Open Banking is a private body; its governance, composition and budget was determined by the CMA. It is funded by the UK’s nine largest current account providers and overseen by the CMA, the Financial Conduct Authority and Her Majesty’s Treasury.

6. The 9 mandated institutions (referred to as the CMA9) are: Barclays plc, Lloyds Banking Group plc, Santander, Danske, HSBC, RBS, Bank of Ireland, Nationwide and AIBG.
 

Mark Mullen, CEO of Atom bank, has agreed to become the Challenger Bank representative to the Open Banking Implementation Entity (the ‘IE’), the organisation set up by the Competition & Markets Authority to create the standards that will enable UK customers to make the most of their financial data.

In this role, Mark will serve as the voice of the UK’s vibrant challenger bank sector. He will convene panels of his peers to gather their opinions and discuss the challenges, technical and procedural, that the IE is tasked with meeting.

Imran Gulamhuseinwala, Trustee of the IE, said:

“It’s extraordinarily exciting to have Mark on board. Atom has been one of the most dynamic players in UK retail banking and his experience and passion will be vital to the task of giving customers real control over their money.

“The IE must ensure that the standards we set enhance the opportunities for companies like Atom and the customers they serve. Mark is the perfect person to make sure we hear the voice of the challenger sector loud and clear.”

Mark has led Atom since 2014. Prior to that, he enjoyed a long and successful career at HSBC, which included leading the First Direct business.

Open Banking allows customers to give companies other than their banks access to their personal or business current accounts. Those companies can read a customers’ financial data and make payments from their accounts.

It gives customers real control of their financial data and allows them to select services from a wide range of companies without disrupting their existing banking arrangements.

Open Banking will enhance comparison services, automate financial advice and create an array of innovative, constantly evolving services.

It is dependent on a type of software called an Application Programming Interface that determines how a company should communicate with a bank, and vice versa, as well as setting tight security standards. The IE is creating the specifications which will determine how Open Banking APIs are coded and a set of guidelines for companies offering Open Banking services.


For further information, please contact:

press@openbanking.org.uk

About Us

Open Banking is a new, secure way for customers to take control of their financial data and share it with organisations other than their banks. Open Banking has the power to revolutionise the way we move, manage and make more of our money. For businesses, it is about making the management of cashflow and receiving payments cheaper and easier. Open Banking will make things simpler, faster and more convenient.

Open Banking follows the Competition and Markets Authority (CMA) investigation into the supply of personal current accounts (PCAs) and of banking services to small and medium-sized enterprises (SMEs).

Open Banking was created to enable innovation, transparency and competition in UK financial services. It is tasked with delivering the Application Programming Interfaces (APIs), data structures and security architectures that will enable developers to harness technology, making it easy and safe for individuals and SMEs to share the financial information held by their banks with third parties.

Open Banking will bring substantial benefits. It gives customers and SMEs greater market choice and greater control over their money and associated data, along with better and easier access to new financial services providers in a secure environment.

Notes to Editors:

1. Open Banking Ltd was set up by the Competition & Markets Authority (CMA) in September 2016 to fulfil one of the remedies mandated by the CMA following an investigation into UK retail banking.

2. The CMA’s investigation into the retail banking market (whose findings were published in August 2016) concluded that older and larger banks do not compete hard enough for customers’ business and that Open Banking should deliver a new, secure option for customers to be able to compare the deal they are getting from their bank.

3. Open Banking was created to enable innovation, transparency and competition to UK financial services. It is tasked with delivering the Application Programming Interfaces (APIs), data structures and security architectures that will make it easy and safe for customers to share their financial records by January 2018.

4. The data provided by Open Banking will enable developers to harness technology that allows individuals and businesses to share their financial records held by their banks with third parties.

5. Open Banking is a private body; its governance, composition and budget was determined by the CMA. It is funded by the UK’s nine largest current account providers and overseen by the CMA, the Financial Conduct Authority and Her Majesty’s Treasury.

6. The 9 mandated institutions (referred to as the CMA9) are: Barclays plc, Lloyds Banking Group plc, Santander, Danske, HSBC, RBS, Bank of Ireland, Nationwide and AIBG.
 

Advisory groups will assist the Implementation Trustee in leading the industry’s delivery of the CMA Open Banking API standard

Following October’s appointment of Andrew Pinder as the Implementation Trustee tasked with leading the project to deliver a new, secure option for customers to best compare the deal they are getting from their banking, convenors for five newly-formed advisory groups have now been appointed.

These separate groups collectively represent the views of:

  • challenger banks
  • fintechs
  • third party providers
  • payment service providers (PSPs) and
  • parties with an interest ensuring consistency with the requirements of the upcoming, revised Payment Services Directive (PSD2).

Gavin Littlejohn, Chairman of a fintech trade association and Chief Executive of Money Dashboard will be convening the fintech advisory group. Ian Major, Director at Runpath, a price comparison website, will convene the third party providers; Thaer Sabri, Chief Executive of Electronic Money Association will be responsible for the PSPs; and James Whittle, will serve as the PSD2 convenor. The challenger banks convenor is still to be finalised and will be named shortly.

These five convenors will sit on the Implementation Entity Steering Group representing the views of their advisory groups, alongside Financial Services Consumer Panelists, Faith Reynolds and Mark Chidley. Faith and Mark are charged with representing consumers and SMEs (small and medium enterprises), respectively.

The advisory groups, which will meet on at least a monthly basis, are intended to provide a forum for debate and discussion to inform both the development and implementation of the standards.

Andrew Pinder, Implementation Trustee, said:

“We are very fortunate to be working with these individuals, who are esteemed experts in their field, and who will be able to help ensure that the fullest debate is held amongst their diverse and representative groups.

“Customer needs are at the heart of our work, and we know that Open Banking has the potential to transform the way in which we bank as it will enable providers of all shapes and sizes to create dramatically improved products that are more competitive, intuitive, personalised, convenient and integrated. My role, and that of the advisory groups, is to lead the industry into delivering the best possible standard, which takes on board all the needs and requirements of users, bringing together the traditional industry players with the market disrupters. If we achieve our goal, we could truly revolutionise banking to the ultimate benefit of customers.”

The Implementation Entity is seeking expertise and insight from stakeholders through these advisory groups. Anyone interested in participating in these groups should contact enquiries@openbanking.org.uk

For further information please contact:

press@openbanking.org.uk.

Notes to Editors

1) An API (Application Programming Interface) is a way for electronic information held in one place to be shared in a controlled and highly secure way: it enables third parties that meet security and service standards to access data and use it to offer services and products. In the retail banking market, a new API standard could transform competition by giving customers more control over their finances, making it easier to access and compare product and service information from different providers.

2) The CMA has required that an implementation entity be set up and funded by the nine banks in the UK with the largest market share (RBS Group, Lloyds Banking Group, Barclays, HSBC Group, Nationwide, Santander, Danske, Bank of Ireland and AIB Group). They have been required by the CMA to deliver the first stage of the project by the end of March 2017, covering publicly available data such as branch opening hours and ATM locations, and information relating to prices, charges and eligibility criteria for loans and personal and business current accounts. Other interested providers will be able to participate in the service and offer it under the same terms as the nine named banks. The second deliverable is the sharing, with customer consent, of customers’ transactional data by January 2018.

3) View the CMA’s Retail Banking Market Investigation: Final Report

4) A new website for the implementation entity will be launched soon.

For more information on the Open Banking Standard, visit here

About the Implementation Entity

The Implementation Entity is the delivery body for an open banking service in the UK. An open banking service, made up of API standards and frameworks, has the potential to dramatically improve competition and innovation in UK banking – benefiting individuals and businesses.

The governance, composition and budget of the Implementation Entity has been agreed by the Competition and Markets Authority, to deliver one of the remedies set out in their retail banking investigation. It is led by an independent Implementation Trustee, with decisions taken by the Implementation Entity Steering Group (IESG), which they chair. In support of wide stakeholder engagement and input, there will be an open sharing of outputs during the development of the standards via the implementation entity advisory group and website.