Update from Charlotte Crosswell, Chair and Trustee, Open Banking Implementation Entity (OBIE)


Since being appointed Chair and Trustee of the OBIE just over three weeks ago, I wanted to provide an update on the progress that has been made to address the findings and recommendations outlined in Alison White’s independent review into the OBIE.   

I welcome the update the CMA (Competition & Markets Authority) made last week on open banking and agree that taking immediate steps to improve current governance is a priority for both the CMA and OBIE, alongside addressing the other serious issues highlighted in the investigation report (the Report) published last month. As stated by the CMA, taking action now is important to secure and build on the significant achievements in open banking that have been made to date and that are possible in the future.  

The sentiment conveyed to me in my short time as Chair – by an overwhelming number of existing employees – is that the OBIE of today is making good progress on many of the issues highlighted. However, the findings of the Report mean that there is absolutely no scope for complacency or lack of action. I said when I started that I intended to act swiftly and decisively to address the issues and concerns raised, and that is what I am now doing.  

Governance framework 

In October, we appointed our first independent non-executive director (NED) to the Board, Jeremy Newman. He brings an incredible amount of experience and knowledge to the OBIE and will provide appropriate scrutiny and challenge that all well run organisations require. In addition, we have launched an open process to recruit an additional NED to the Board and are working with an independent search agency and have published an advert for the role.  I anticipate we will be in a position to appoint an additional NED before the end of the year.  

These are important steps but there is also more work being undertaken behind the scenes to tackle the issues raised by the Report, including clarifying roles and responsibilities and ensuring there is a robust governance framework in place that is effectively implemented. We will be working closely with the CMA to reflect these changes in revisions to key documents such as the Agreed Arrangements.  

We are committed to providing our stakeholders with an appropriate level of transparency with regards to OBIE’s finances and financial controls. Further work regarding new processes to increase financial transparency is also being progressed by the Board in consultation with the CMA, along with broader review of the organisation’s corporate governance framework, policies and controls.   

Complaints, management and HR support  

Given the seriousness of the issues raised in the Report, it is also important that the OBIE has sufficient resources and support in place to take forward the recommendations. We have now carried out a robust procurement process for two firms that will provide the OBIE with the necessary support to examine and address the recommendations. Jeremy Newman and I have personally overseen the tender processes to ensure that we adhere to best procurement practices, including transparency, value for money and fair competition.  

The first is the appointment of an experienced and reputable independent third party * to handle complaints. There can be no getting away from the serious concerns raised by the independent investigation. This has been my immediate priority as it’s essential we have a fair, robust and independent process in place to review and advise on complaints, including those that pertain to the investigation. Please contact for any complaints related queries.

The second firm, which we hope to appoint shortly, will provide the Board, myself and other OBIE colleagues with additional support to help address the findings as quickly as possible and action the recommendations within the report. This includes providing:  

  1. A progress report of OBIE –  to assess gaps and identify where further action is needed to address the issues identified in the Report.   
  2. Leadership and senior-level support to assist in assessing and delivering changes to address the issues raised by the Report.  
  3. Reviewing the HR agenda, organisational structure, and the work being undertaken around culture and values, including policies, controls and procedures their effectiveness and proposing any immediate changes required. 
  4. Implementing and operationalising OBIE governance changes. 

 More to be done 

Whilst there has been progress, and I would like to thank all OBIE colleagues and stakeholders that have made this possible since my appointment, this work does and should take time. I am determined that all the changes we make are both considered and appropriate, and always in keeping with best practice.   

It is important for me that we prioritise people, both internally and externally to the OBIE, and I am committed to building a culturally progressive, inclusive and fit for purpose organisation. 

Since joining, I have already spoken to hundreds of people from the wider open banking ecosystem. It is wonderful to hear the collaboration and innovation taking place. However, it is important that I take the necessary steps to ensure that OBIE continues to deliver on its open banking mission and that it does so in the right way. 

There will be a number of internal developments in the coming weeks which we will be sharing direct with the OBIE team and the CMA. I will also commit to providing additional significant updates externally when relevant.  

Notes to Editors: 

 *The OBIE has appointed global law firm Eversheds Sutherland as an independent third party to review and advise on complaints. 

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 CMA 9 (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:

  • Enforce the obligations on the CMA 9 under the CMA Order
  • Design the specifications for the Application Programme Interfaces (APIs) that banks and building societies use to securely provide open banking
  • Support regulated third party providers and banks and building societies to use the OBIE’s Open Banking Standards
  • Create security and messaging standards
  • Manage the OBIE’s open banking Directory which allows regulated participants like banks, building societies and third-party providers to enrol in open banking
  • Produce guidelines for participants in the open banking ecosystem
  • Set out the process for managing disputes and complaints