The Operational Guidelines
The OGs have the following objectives:
To provide clarity to ASPSPs to enable them to design effective and high-performing dedicated interfaces while fulfilling their regulatory obligations.
To ensure that TPPs have access to consistently well-designed, well-functioning and high performing dedicated interfaces.
To ensure that consumers and SMEs using TPP services have positive experiences that encourage them to continue to consume open banking-enabled services.
In addition, adherence to these OGs and the OG Checklist will provide the following benefits:
Exemption support: Support ASPSPs with their application to their NCA for an exemption from providing a contingency mechanism.
Lower Costs: Minimise the potential costs to a business when systems or supporting networks are down (including instances where they have not been tested appropriately).
Reduced Reputational Risk: Protect the reputation of individual participants and the Open Banking ecosystem as a whole.
The Operational Guidelines Checklist
The OG Checklist consolidates the requirements of the FCA Checklist1 and recommendations of the OG, and helps ASPSPs identify where they are conforming to the OG. Each element of the OBIE Standard includes aspects which are either one, or a combination, of:
CMA Order: These are required by the Order and only apply to the CMA9 banks as identified in the CMA Order.
PSD2: These are either Mandatory or Optional under PSD2 (Level 1) or RTS (Level 2) texts, according to the interpretation of OBIE. Any item considered to be Mandatory under PSD is considered a requirement in the Open Banking Standard. ASPSPs, based on their interpretation of the legislation, should explain their rationale for deviating from the OBIE Standard to their NCA when applying for an exemption. (See e.g. Column B of the FCA’s Form B2).
OBIE: These are items that OBIE believes would be particularly beneficial for PSUs and TPPs if implemented by ASPSPs based on consultation with a large number of stakeholders.
1In particular the FCA’s own questions which we refer to as the FCA Checklist from https://www.fca.org.uk/publication/forms/contingency-exemption-request-form-2018.pdf which should be read alongside Chapter 17 of the PSRs Approach