Definition
Open Banking UK is the British regime for access to banking data and payment initiation, launched in January 2018 under a mandate from the CMA (Competition and Markets Authority).
Imposed first on the 9 largest banks ("CMA9"), it is run by Open Banking Limited (OBL, formerly OBIE), which defines the standards, operates the central Directory and publishes the guidelines. It is the most mature regime in the world, often cited as a benchmark by France and Europe.
Open Banking UK vs PSD2
The UK is technically far more uniform than Europe:
| Criterion | Open Banking UK | PSD2 (EU / France) |
|---|---|---|
| Initial scope | 9 banks (CMA9) | All banks |
| API standard | A single one (OBIE) | Multiple (STET, Berlin Group…) |
| Tech regulator | OBL (centralised) | Fragmented (NCA + EBA) |
| TPP Directory | OBL Directory | NCA + EBA registers |
| Variable Recurring Payments | Yes (VRP since 2022) | No equivalent |
| Maturity | Very high | Very uneven |
The upshot: TPP integration is noticeably simpler in the UK — a single spec, a single Directory, API quality well above the European average.
The 9 mandated banks (CMA9)
Barclays, HSBC, Lloyds Banking Group (Bank of Scotland, Halifax), Santander UK, NatWest Group (RBS, Ulster Bank), Nationwide, Danske Bank, Bank of Ireland and AIB Group. Today, many more banks expose the OBL APIs, but it is the CMA9 that funded OBL and set the pace.
Variable Recurring Payments (VRP)
This is the big UK innovation, absent from today's PSD2:
- the PSU authorises a TPP to initiate recurring payments within a defined framework (max amount per day/month, merchant), without re-SCA every time;
- conceptually, an equivalent of the SDD direct debit, but on an instant-transfer rail and driven by the debtor;
- use cases: an alternative to direct debit, repeated e-commerce payments, sweeping (automatic transfer between accounts).
VRP sweeping is mandatory at the CMA9; commercial VRPs (merchant payments) are spreading and will probably be picked up by PSD3 / PSR.
What Open Banking UK is not
- Does not (yet) include savings, credit, investment or insurance — that is the purpose of the future UK Smart Data Bill (and of FIDA on the EU side).
- Is not run by the FCA alone: OBL steers the spec, while the FCA and HM Treasury supervise.
- Is not fixed: the JROC is preparing the Future Entity that will succeed OBL and broaden the scope.
- Does not apply in Ireland: despite Bank of Ireland and AIB (UK subsidiaries) being in the CMA9, Ireland falls under PSD2.
In the global ecosystem
Open Banking UK is the global benchmark: Brazil, Australia, Saudi Arabia, Bahrain, Mexico and Hong Kong drew explicitly on it (central regulator, single standard, top-down mandate). It is also the favourite playground of the big B2B TPPs (Plaid, TrueLayer, Tink, Yapily, Bud).
Concrete examples
- TrueLayer: a London unicorn, a major AISP/PISP, with very smooth UK integration thanks to the single standard.
- Yapily: a pure-play API banking provider, B2B-focused, expanded to Europe.
- Bud Financial: transaction enrichment, with UK roots.
- Plaid UK: the US giant relied on OBL for its European launch.
- VRP in practice: NatWest launched the first merchant payment via VRP in 2022; Tink offers sweeping, and Volt and TrueLayer push VRP as a card alternative.
- Volume: 15.16M active users in July 2025 (vs 13.3M in March), 31M Open Banking payments in March 2025, ~70%/year growth; VRPs account for ~13-14% of the total.
- Quality: according to OBL, the average availability of the CMA9 APIs often exceeds 99%, with sub-second latencies — well above the PSD2 average.
- To watch: the post-OBL Future Entity and the Smart Data Bill, which could extend the regime to energy, telecoms and transport — a horizontal model the EU could draw on after FIDA.