Over the past years regulations on open banking got more and more accurate, to the point that innovative businesses and startups are now able to put a new category of apps on the market. This trend is shaping a new way to manage people’s money, their savings and their spending habits.
If you have an innovative idea, the UK is one of the European countries that have the clearest regulations for open banking, as well as one of the easiest application processes.
Open banking in the UK is regulated and controlled by the CMA (Competition and Markets Authority), and the participants are the CMA9, i.e.: the nine major banks in the UK: HSBC, Barclays, AIB, Bank of Ireland, Lloyds Bank, NatWest, Northern Bank, Santander and Nationwide Building Society. The FCA process all the applications.
So if you want to gain access to Open Banking APIs, here’s what you need to do.
Meet the Open Banking Implementation Entity
The OBIE is the subject created by the CMA and the CMA9 in charge of setting standards for Open Banking APIs, user experience, cybersecurity and more.
The regulation set by the CMA, known as PSD2 regulation, is enforced by the OBIE. Complying with the PSD2 means having access to the APIs of the nine major banks in the United Kingdom. This means that your goal is to be listed in the OBIE’s directory as a Third Party Provider (TTP).
This is your ultimate goal: become a TTP. And you’ll have to go through the Financial Control Authority (FCA) if you operate in the UK or an equivalent authority if your startup was founded in another jurisdiction.
We’ll now summarise the application process to the FCA.
How to apply for Open Banking APIs with the FCA
Before applying for TPP membership, you have to request and obtain an AISP authorisation by the FCA.
The FCA set a few conditions you must abide by:
- Some of your business as an AISP must be carried out in the UK;
- You can’t provide any payment service other than AIS;
- You must have a business plan;
- The insurance cover of your choice should offer adequate indemnity compensation limits;
- You have internal policies to guarantee security and safe onboarding procedures, e.g.: KYC and AML policies;
- None of the managers and directors should have ever been convicted for financial crimes;
- All of the managers and directors should have solid skills and good reputation.
This means every person on board must apply. The FCA will also ask you a few documents and statements:
- Governance arrangement and internal procedures;
- Details of people who will be responsible of the payment services provided;
- Policies for incident reporting, data protection, business continuity plan, principles and definitions for statistical data collection and security.
In case you’ll get help from third party agents you’ll need to list them as well and give their details to the FCA.
Once your application is sent through, FCA agents will examine it and come to a decision in 3 months. However, if the application is incomplete, you might experience delays of up to 12 months.
Apply for OBIE’s TPP directory
Once you have a positive response from the FCA and your registration number, you can register your business on the OBIE directory.
The request is sent through an online form, which should ideally be filled in by the main legal representative of the company, as some digital ID will be required.
You’ll need to provide an explanation about your business model and a few more details, such as company registration number, registered address, etc.
Forward your requests
Once your business is registered and recognised by OBIE and FCA you can access Open Banking APIs. In some cases you’ll have to send a formal request, otherwise you’ll just need to register to a dedicated online platform, but your access will be granted with no problem.