Open Banking – Improving the Customer Experience



Customers rightly expect modern financial services to be easy to use, so the Open Banking Implementation Entity (OBIE) has focused on ensuring that open banking-enabled services can be delivered in a user friendly way. The two areas of the Open Banking Standard that enable this are App-to-App authentication (which allows customers to authenticate in their bank’s mobile app, often using biometrics such as Touch or Face ID) and the Customer Experience Guidelines (CEG), which clearly set out how a customer journey can be low friction, speedy and simple.

Since the launch of the third version of the Open Banking Standard, in September 2018, the OBIE has seen a significant improvement in journey completion rates, meaning that customers are now able to more easily access services they desire. We provide an overview below of how the six largest banks in Great Britain and the three largest banks in Northern Ireland (known collectively as the CMA9) have implemented the CEG, and the measures the OBIE and the CMA9 are taking to remedy any outstanding issues.

Whilst there has been good progress, we will continue to monitor conformance with the CEG until its requirements are met in full, so that users of open banking-enabled services receive a uniformly conformant authentication journey. Third party providers need a frictionless authentication experience to confidently provide services to consumers and businesses.

Implementation progress

We are now seeing good levels of conformance across both the core elements of the CEG and App-to-App authentication, evidenced through each of the CMA9’s conformance assessments.

The main areas of outstanding non-conformance include:

  • Journeys which require customers to navigate unnecessary steps or additional screens to complete authentication for account information sharing or payment initiation.
  • The manner in which the Contingent Reimbursement Model (CRM) Code has been implemented to combat authorised push payment (APP) fraud. The OBIE is supportive of measures to reduce instances of fraud, but where the Code has not been implemented in the required risk-based way, customers may be required to go through several additional steps to complete a low-risk payment, such as when the payee is on a list of regular payees.

Action being taken

We have agreed detailed action plans with each of the CMA9 to ensure that implementation issues are resolved early in the New Year, and in most instances much earlier. In a small number of cases, we are continuing to work with CMA9 banks to find appropriate solutions that are easy-to-use and deliver good customer outcomes.

Commenting on the recently published implementation progress of the CMA9 banks for the Open Banking Customer Experience Guidelines, Trustee of the OBIE, Imran Gulamhuseinwala OBE said:

“The Customer Experience Guidelines exist to set minimum standards for the banks to adhere to so that they can provide a safe and simple experience for their customers. I welcome the CMA9 banks’ commitment to complying with the guidelines and to make further improvements where necessary.”


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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.