The Open Banking Standard
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The Open Banking Standard Unlocking the potential of open banking to improve competition, efficiency and stimulate innovation CONTENTS 1. Executive Summary............................................................................................................3 2. Introduction.........................................................................................................................8 3. Foundations......................................................................................................................11 4. Opportunities and Challenges..........................................................................................14 5. Scope of Data...................................................................................................................17 6. Customer Benefits............................................................................................................20 7. The Open Banking Framework.........................................................................................24 7a. Standards.......................................................................................................................25 7b. Developer Resources.....................................................................................................37 7c. Security...........................................................................................................................41 7d. Governance....................................................................................................................55 8. Regulatory and Legal Considerations...............................................................................64 9. Implementation Plan.........................................................................................................76 Appendices...........................................................................................................................81 Glossary.............................................................................................................................143 Acknowledgements............................................................................................................147 1. Executive Summary Context In the 2015 Budget HM Treasury announced its commitment to delivering an open standard for Application Programming Interfaces in UK banking, to help customers have more control over their data and to make it easier for financial technology companies (FinTechs) or other businesses to make use of bank data on behalf of customers in a variety of helpful and innovative ways. The Government explained that this could help to drive more competition in banking to improve outcomes for customers, and further support the UK’s world-leading FinTech industry. In summer of last year, at the request of the Economic Secretary to the Treasury, Harriett Baldwin MP, the Open Banking Working Group (OBWG) was established to take forward this work. Their objective was to produce a detailed framework for how an Open Banking Standard could be designed and delivered, with a timetable for achieving this. The OBWG comprised industry experts from banking, open data, and consumer and business communities to ensure a diverse range of expert views are represented. This report is the OBWG’s detailed framework for delivering an Open Banking Standard in the UK. Leadership in this area will set precedents across many sectors; a strong data infrastructure will be as important to the UK’s economy today, as roads have been to our success in the industrial economy for over a century. Banking as a service has long sat at the heart of the economy because of the need to seamlessly and efficiently connect different economic agents who are buying and selling goods and services. The need for that ease of connectivity only increases in a digitally enabled economy, and the capabilities that underpin it necessitate that connections be made in very different ways. Trust will remain the single most important factor in determining how those different means of connecting will be made beneficial. Our challenge has been to determine how best to enable high security (a critical foundation to building and maintaining trust) while not impeding development in a rapidly changing world. The European Union is rapidly advancing legislation that will, upon implementation in the next two years, require UK banks (subject to consent from individuals and businesses) to open access to their customer data and payments capabilities. The UK has diligently fostered a vibrant financial technology environment and stands ready to reap the benefits of that legislation sooner than many other markets. Other markets (in the EU and beyond) have begun to implement aspects of an open banking standard, but none have produced a definitive outline of such a standard, let alone a roadmap for its implementation. There is, therefore, a significant opportunity for the UK economy if we take a lead in this space. This will require that we invest rigorously in development over the next 6-12 months. Open Banking Standard Our goal in publishing this Framework today is to enable the accelerated building of an Open Banking Standard in the UK. It has been developed based on input from an expert group drawn from the banking, FinTech and data communities, building on preliminary work by HM Treasury in the first half of 2015. At its core, the Framework represents a set of foundational recommendations that are intended to allow the process of building the Open Banking Standard to commence immediately. Those recommendations include a broad implementation plan, covering three distinct phases over the course of the next three years. The implementation plan will, by necessity, need to be flexible over the coming years – both because lessons will be learned as implementation gets underway and because the technology and standards on which it will rely will continue to evolve at a rapid rate in ways that are impossible to anticipate today. Execution of the plan, along with maintenance of the emerging standard itself, will require careful stewardship. Clear and consistent communications will be required to continuously build awareness, understanding and adoption not just with service developers, but also with the individuals and businesses that will benefit. This latter point is fundamental. Our aim in constructing this framework in the way that we have was to ensure that such an open standard provides the highest quality of service for individuals and businesses, that increases competitiveness, improves efficiency and stimulates innovation. This standard will only be as good as the trust that all of the participants required to make it successful have in it; that will ultimately rely on the trust of individuals and businesses. Fundamental importance of data literacy Our work in constructing this framework, as well as more advanced work in other sectors, has repeatedly highlighted the fundamental role of data literacy in supporting the creation of any open data standards. We must align on a common vocabulary – one that cuts across sectors, even if there is sector-specific terminology that must be brought into it. The Open Data Institute (ODI) has done a tremendous amount of work in beginning to build that vocabulary and we commend it to anyone. To aid that, and ensure that readers of this report interpret its contents consistently, we have included a brief glossary of critical terminology used within this report or related to its contents. Given the importance of data literacy and a common vocabulary, our working group opened each of its meetings by reiterating a set of core definitions that we used to guide our work; we feel it important to do the same here. Those core definitions arise from the two important, distinct, but mutually beneficial outcomes that this framework seeks to create: ● an open API for data that is shared, including, but not limited to, customer data; and ● an open data API for market information and relevant open data. An open API is a means of accessing data based on an open standard: it is a public interface. Data exists on a spectrum of accessibility. The data spectrum ranges from closed to shared to open. The data accessed via an open API may be closed, shared or open data. Figure 1.1 The data spectrum * See http://theodi.org/data-spectrum In fact, it could include data considered to be “proprietary”. In that circumstance, the holder of rights to any such “proprietary” data could choose to share (but could not be compelled to do so unless the data was deemed not to be proprietary) that data via the open API, along with stipulations – or licensing terms – related to its use by those with whom it chooses to share it. Open data is data that anyone can access, use and share. An open data API, therefore, is a public interface that provides access to open data. An example of open data in this context could be financial product information. Any individual’s personal bank details or a company’s transaction data are considered closed or shared data. They will be made available via an open API as a result of the implementation of this work, but access to them would be subject to consent of the individual or business to whom the data belongs and specific governance related to that. Such data will not be licensed or made public as open data as a result of this work. A n open standard is developed and maintained collaboratively and transparently, and can be accessed and used by anyone. Key recommendations