The Operational Guidelines Checklist
The Operational Guidelines Checklist (the OG Checklist) will serve as an essential tool that will enable Participants to self-attest against key criteria identified within the Operational Guidelines. Participants can answer specific questions to demonstrate conformance to the Operational Guidelines.
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 OBIE 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.
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:
- OBJECTIVE – be fact based and not rely upon the judgement of the ASPSP or TPP – quantitative evidence should be used wherever possible.
- CLEAR – standalone, single clause, closed questions which demand a “yes or no” answer.
- DEFINED – unambiguous and tightly constructed with links to definitions where appropriate.
- TRACEABLE based on regulatory requirements and/or the OBIE Standard (rationale for inclusion and classification will be made explicit).