Operational Guidelines

Operational Guidelines Checklist

This version is:

Published 1 year ago 31 May 2023

The Operational Guidelines Checklist is an essential tool enabling Participants to self-attest against key criteria identified by the Operational Guidelines. Participants answer specific questions to demonstrate conformance to the Operational Guidelines.

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The FCA’s own Checklist along with guidance in Chapter 17 of the PSRs Approach, as well as the EBA Guidelines, detail the regulatory requirements. We have developed the OG Checklist by placing Open Banking Limited (OBL) recommendations underneath the FCA Checklist requirements.

We believe that successfully meeting all requirements and recommendations will support and facilitate an application for an exemption from the contingency mechanism. However, a UK-based ASPSP could choose to submit the FCA Checklist directly without reference to the OG Checklist and still gain an exemption.

Checklist overview

ASPSPs applying for an Open Banking Operational Guidelines Conformance Certificate must submit a completed OG Checklist for each dedicated interface and each brand and segment. We note that multiple brands may have the same implementations and dedicated interfaces, which means the same OG Checklist can be submitted for each of them. Further, we encourage those completing the OG Checklist to consider if any additional submissions may be required e.g. if an ASPSP has “app-only” customers whereby having a consolidated OG Checklist could lead to different answers being provided for different customers.

For each OG Checklist submission, the business owner of the relevant brand/product should sign off and attest to its accuracy.

In developing the Checklist questions, we have defined some key principles that each question must adhere to: