The appointment of Ezechi "Ez" Britton as independent chair of the UK's Future Entity Design Steering Group marks the most consequential governance moment in British open banking since the Competition and Markets Authority (CMA) issued its 2017 retail banking market investigation order. That directive forced the country's nine largest current account providers — collectively known as the CMA9 — to build standardised application programming interfaces (APIs), establishing a framework that would eventually attract more than 11 million active monthly users. Nearly a decade on, the architecture those mandates produced is now being formally retired in favour of something broader, more commercially ambitious, and permanently supervised by the state.
The body at the centre of this transition, still formally referred to as the Future Entity in regulatory documentation, will absorb the core standard-setting, performance monitoring, directory, and certification functions currently managed by Open Banking Limited (OBL). Critically, it will operate as a dedicated non-profit organisation under Financial Conduct Authority (FCA) supervision — a structural departure from the industry-led enforcement model that governed the CMA9 regime. Secondary legislation enacted under the Data (Use and Access) Act 2025 provides the FCA with explicit statutory powers to oversee the permanent, industry-funded Future Entity, removing any ambiguity about regulatory authority that existed under the original CMA order.
A Framework Overtaken by Its Own Success
The case for structural change is, in many respects, a product of the original regime's achievements. The CMA9 mandate was legally bounded: it applied only to the major retail banks and was focused primarily on basic payment initiation and current account data access. That scope made sense in 2017, when the concept of third-party providers accessing customer financial data was still commercially unproven. It makes considerably less sense in an environment where open banking counts over 11 million active monthly users and where both consumer appetite and commercial innovation have moved well beyond what that narrow mandate ever anticipated. OBL, which evolved from the original Open Banking Implementation Entity created to execute the CMA directive, has been operating as a de facto standard-setter for a market it was never fully resourced to govern at scale.
The Future Entity is designed to close that gap. OBL is currently acting as a neutral coordinator for the design process itself, convening a working group of more than 30 banks, fintechs, and payment service providers. That coalition is charged with producing a comprehensive blueprint covering the Future Entity's operational scope, governance architecture, technical capabilities, and funding mechanism. The breadth of that coalition — spanning incumbent lenders and challenger fintechs alike — signals both the ambition of the exercise and the complexity of reconciling competing commercial interests under a single regulatory roof.
Why Britton's Profile Matters
Britton arrives at the steering group with credentials that span the precise intersection of public policy, financial innovation, and technology infrastructure that this role demands. He served as the founding chief executive of the Centre for Finance, Innovation and Technology (CFIT), the government-backed body launched in the wake of the Kalifa Review of UK Fintech — a reform agenda that positioned open banking as a cornerstone of Britain's post-Brexit financial services strategy. Before that, he co-founded the employee financial wellbeing fintech Neyber and spent years operating as both a software engineer and a venture capitalist. He was awarded an MBE in 2022 for services to diversity and young people.
That combination of hands-on technical background, startup founding experience, and senior institutional leadership is not incidental. The Future Entity's design process requires someone capable of mediating between the regulatory objectives of the FCA, the commercial imperatives of incumbent banks, and the innovation agenda of the fintech community. Britton's tenure at CFIT demonstrated an ability to operate across those constituencies without being captured by any one of them — precisely the quality an independent chair of a body this consequential needs to project.
Variable Recurring Payments and the Open Finance Horizon
Beyond governance, the Future Entity's most commercially significant mandate concerns the scaling of Variable Recurring Payments (VRPs). The first generation of VRP infrastructure — known as sweeping VRPs — was limited to automated transfers between a single customer's own accounts. The next phase, commercial VRPs (cVRP), extends this payment rail to recurring bill payments, utility subscriptions, and e-commerce checkout flows. In utility billing specifically, cVRP enables direct debiting based on exact monthly meter readings rather than fixed estimates, improving consumer liquidity management and eliminating interchange fees for billers who currently route such payments through card networks.
Establishing standardised interface rules and technical uptime benchmarks for cVRP is central to the Future Entity's early agenda. Regulatory clarity at the infrastructure layer is widely regarded as the missing precondition for commercial adoption at scale — something the voluntary, market-led approach of the past several years has struggled to deliver. Beyond payments, the new body is also expected to serve as the structural backbone for a broader expansion of data sharing into open finance verticals, including pensions, insurance, and wealth management.
What This Means for the Market
The appointment of an independent chair and the formal convening of a 30-plus member design coalition represent the UK's most concrete steps yet toward institutionalising open banking as permanent financial infrastructure rather than a regulatory remedy. For fintechs building on open banking rails, FCA supervision of the Future Entity offers a more stable and predictable standards environment than anything the CMA9 order could provide. For incumbent banks, it signals that participation in the new regime will carry enforceable obligations rather than negotiable commitments. And for the broader open finance agenda — connecting bank accounts, investment portfolios, pension pots, and insurance policies into a single consented data layer — the Future Entity represents the foundational architecture upon which that ambition will either be realised or stall. Britton's task is to ensure the blueprint delivered by this steering group is equal to that scale of expectation.
Written by the editorial team — independent journalism powered by Codego Press.