The OBIE was set up under the direction of the CMA as a member-owned company limited by guarantee.

Funding is provided by the CMA 9 and it is incumbent on the Trustee* to ensure the OBIE remains fully independent. It was envisaged under the Order that the OBIE would be a temporary legal structure tasked with delivering certain aspects of the Order. The OBIE’s governance and management reflects the requirements placed on the OBIE and the Trustee to focus on successful delivery of the Order.

The Order requires the Implementation Trustee to lead the Open Banking Implementation Entity and therefore is the Chairperson of the Board. Day-to-day activities and operations are managed by a Programme Director who in turn manages a leadership team. The Order contains a number of specific requirements including designing and publishing the Open Banking standards. The Order also makes the Trustee responsible for setting the requirements of the CMA 9 under the Order and of overseeing their compliance. The OBIE supports the Implementation Trustee in this endeavour.

The Implementation Trustee is required to take into account the views of a wide range of stakeholders in determining appropriate actions under the Order. In order to do this the Order requires the Implementation Trustee to chair an advisory group known as the Implementation Entity Steering Group, or IESG. IESG comprises representatives from the 9 largest high-street banks in the UK (or CMA 9), the CMA, Pay.UK, the Payment Systems Regulator, industry representatives, the Information Commissioner’s Office (ICO), HM Treasury and the FCA, as well as Independent Representatives for both Consumers and Small Businesses.

The role of the IESG is to advise the Implementation Trustee on matters related to the decisions he is empowered to take under the Order. The Order requires the Implementation Trustee to identify consensus amongst the IESG, however, where such consensus cannot be achieved, the Implementation Trustee may impose a decision.

The day-to-day operations of the OBIE are managed by an Executive Committee led by the Programme Director. The OBIE’s governance is evolving to reflect the fact that the open banking initiative is moving from a programme delivery body to a service provider and ecosystem enabler. As the implementation requirements of the Order draw to a conclusion the CMA is actively considering the future of the OBIE and what the appropriate funding and governance requirements would be.

*While we have referred to the ‘Trustee’ throughout this document due to expediency, the role is referred to as the Implementation Trustee in the CMA Order.


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