The United Kingdom's open banking architecture is undergoing its most consequential structural transformation since its inception, and the government and industry have chosen Ezechi "Ez" Britton to lead the design of the body that will govern it. Britton has been appointed independent chair of the Future Entity Design Steering Group — the coalition tasked with architecting the replacement for Open Banking Limited (OBL). The appointment arrives at a pivotal moment: with more than 11 million active monthly users now relying on open banking infrastructure, the original regulatory framework that created the ecosystem has demonstrably outgrown its mandate.
The Future Entity — still carrying its provisional regulatory label — will assume the core functions currently administered by OBL: standard-setting, performance monitoring, directory services, and certification. Crucially, it will operate as a dedicated non-profit organisation under the supervisory authority of the Financial Conduct Authority (FCA), rather than as an industry implementation vehicle anchored to a set of mandated banks. The legal scaffolding for this transition is provided by secondary legislation under the Data (Use and Access) Act 2025, which explicitly equips the FCA with powers to supervise the new, industry-funded body as it absorbs OBL's legacy responsibilities.
From CMA Order to Statutory Framework
To understand why this transition matters, one must return to the origin of UK open banking. The entire ecosystem was built on the back of the Competition and Markets Authority (CMA) 2017 retail banking market investigation order, which compelled the UK's nine largest current account providers — collectively known as the CMA9 — to construct secure, standardised application programming interfaces (APIs) granting authorised third parties access to customer data and payment initiation capabilities, with explicit consumer consent. OBL, originally created as the Open Banking Implementation Entity, was the instrument for executing that directive.
That enforcement-driven model served its purpose. The UK established itself as one of the world's most advanced open banking jurisdictions, a regulatory template studied and emulated internationally. But the CMA order was structurally limited: it applied only to the major retail banks and addressed a narrow scope of payment and account data. As the market expanded — reaching the significant milestone of 11 million active monthly users — it became evident that a regime built around compelling nine banks to comply was no longer adequate to govern a multibillion-pound ecosystem involving hundreds of participants across payments, lending, and personal finance.
A Coalition of Over 30 Stakeholders
OBL is currently serving as a neutral coordinator for the design process, convening a working group of more than 30 banks, fintechs, and payment service providers. This coalition carries the mandate to deliver a comprehensive blueprint covering the Future Entity's operational scope, governance architecture, technical capabilities, and funding mechanism. The breadth of the coalition signals an intent to build consensus across the industry rather than impose a top-down structure, reflecting lessons from the original CMA-mandated model where buy-in was compelled rather than cultivated.
Britton's appointment to chair this group carries considerable symbolic and practical weight. He is best known as the founding chief executive of the Centre for Finance, Innovation and Technology (CFIT), a government-backed body established in the wake of the Kalifa Review of UK Fintech. At CFIT, Britton developed a reputation for bridging the gap between regulatory intent and commercial implementation — precisely the skill set required to navigate a design process that must satisfy regulators, incumbent banks, challenger fintechs, and consumer advocates simultaneously. He also co-founded the venture builder Collectively Better and the fintech Neyber, and has spent time as both a software engineer and a venture capitalist. In 2022, he was awarded a Member of the Order of the British Empire (MBE) for services to diversity and young people.
Variable Recurring Payments: The Commercial Frontier
While governance architecture dominates the structural conversation, the Future Entity's most commercially significant mandate may lie in scaling Variable Recurring Payments (VRPs). The first generation of VRPs — known as "sweeping" — enabled automated transfers between a single customer's own accounts. Commercial VRPs (cVRPs) extend this infrastructure substantially, enabling recurring bill payments, utility subscriptions, and e-commerce checkout flows that operate directly on account-to-account (A2A) rails.
The implications for the payments industry are considerable. In utility billing, for instance, cVRPs allow direct debiting based on exact monthly meter readings rather than fixed estimates — a consumer protection benefit — while simultaneously removing card network interchange fees for billers. For merchants and service providers, A2A infrastructure via cVRPs represents a meaningful reduction in payment processing costs. By establishing standardised interface rules and technical uptime benchmarks, the Future Entity aims to provide the regulatory clarity necessary to accelerate cVRP adoption at scale.
What This Means for the Industry
The appointment of Britton and the formal launch of the design process mark the point at which UK open banking transitions from a compliance exercise into a market infrastructure institution. The Future Entity, once established, will not merely enforce standards — it will actively drive the commercial open banking models that third-party providers, banks, and consumers depend on. Its remit is also explicitly designed to serve as the technical foundation for broader open finance capabilities, extending data-sharing frameworks into pensions, insurance, and wealth management.
For the financial services industry, the message is unambiguous: the regulatory and commercial infrastructure underpinning open banking is being rebuilt for permanence, not patched for short-term compliance. The Design Steering Group now has the leadership, the statutory framework, and the industry coalition to make that permanent structure a reality. How Britton and his coalition of over 30 stakeholders resolve the competing demands of governance, funding, and technical scope will determine whether the UK retains its position at the frontier of global open finance — or watches that advantage erode.
Written by the editorial team — independent journalism powered by Codego Press.