Independent assessment to support establishment of a Future Entity
Executive Summary
The FCA has appointed KPMG to conduct an independent assessment of proposals for establishing a **Future Entity** – a standards-setting body for UK open banking APIs that will replace Open Banking Limited. This initiative is critical because it establishes the governance framework for open banking ahead of new legislative powers the FCA will receive under the Data (Use and Access) Act 2025, with a statutory instrument expected by end-2026.
What Changed
- The regulatory landscape for UK open banking is undergoing fundamental restructuring:
- Transition of regulatory authority: The FCA is becoming the primary regulator for open banking, replacing the Joint Regulatory Oversight Committee (JROC).
- Future Entity establishment: A new standards-setting body will become the primary UK standard-setting organization for open banking APIs, responsible for setting and maintaining common standards for minimum service and interoperability, monitoring AP
- Independent assessment process: KPMG will evaluate competing proposals from industry participants to determine which organization should lead the Future Entity establishment.
- Legislative framework: HM Treasury will introduce legislation granting the FCA new rulemaking powers for open banking under the Data (Use and Access) Act 2025.
- Interface body regulation: The Future Entity and commercial scheme operators will be regulated as "interface bodies" under the Data (Use and Access) Act 2025.
Suggested Considerations
- *For industry participants and trade associations:
- *Engage with the assessment process: Participate in the independent assessment by submitting proposals or supporting existing proposals for Future Entity leadership
- *Arrange FCA Q&A sessions: Organizations interested in leading Future Entity establishment should contact the FCA directly to schedule one-hour Q&A sessions ahead of the independent consultancy process launch
- *Coalesce behind proposals: Industry should decide which proposal option should lead the next phase of work, with the FCA commissioning assessment of either multiple proposals or a single industry-supported proposal
- *Prepare for VRP implementation: Ensure systems and processes are ready for live Variable Recurring Payments transactions expected in Q1 2026
- *Monitor legislative developments: Track HM Treasury's introduction of legislation under the Data (Use and Access) Act 2025 and prepare for new FCA rulemaking powers
Key Dates
Compliance Impact
Urgency: HIGH
Who is Affected
References
AI-generated analysis. May contain errors or omissions — verify with the original FCA source before acting. Full disclaimer.
Summary
We have published a letter to trade associations to provide an update in the development of a Future Entity (FE) for open banking. The letter confirms the appointment of KPMG to provide an independent assessment of proposals to establish a standards-setting body for UK open banking APIs that is capable of becoming the Future Entity. It explains the purpose and scope of the assessment, the respective roles of the FCA, industry, trade associations and the independent assessor, and how firms can...