Due diligence checklist, United Kingdom

UK Open Banking (PSRs 2017): what to ask a vendor

Payment Services Regulations 2017 and the Open Banking Standard. FCA and Open Banking Limited. Account providers expose Open Banking APIs, and third parties access them with consent and strong authentication.

A starting point, not legal advice. The regulator's own page: FCA and Open Banking Limited.

What it is

Account providers expose Open Banking APIs, and third parties access them with consent and strong authentication.

Who it applies to

Applies to every financial institution in the United Kingdom, when procuring open banking and cdr, digital banking, payments.

What to ask a vendor, and the evidence to request

#Ask the vendor forEvidence to request
1Conformance with the Open Banking Standard API specificationsConformance test results or a written statement of conformance against the standard, with the version supported.
2Strong customer authentication and consent management for account information and payment initiationConformance test results or a written statement of conformance against the standard, with the version supported.

In every case

  • A named contact at the vendor responsible for this regime, and how the vendor tracks changes to it.
  • Which named customers the vendor already serves under this regime, as references you may call.

This checklist is a starting point for a procurement team, not legal advice. Read it with the regulator's own page, your institution's policies and your legal and risk teams; the regime may have changed since the date on this document.

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