The landscape of UK financial technology is undergoing a structural metamorphosis. Following the passage of the Data (Use and Access) Act 2025, the United Kingdom is transitioning away from the legacy Competition and Markets Authority (CMA9) framework toward a more robust, regulator-led model. Central to this transition is the appointment of Ezechi “Ez” Britton as the independent chair of the Future Entity Design Steering Group.
Tasked with overseeing the creation of a permanent, sustainable body to succeed Open Banking Limited (OBL), Britton’s appointment signals a shift from a time-bound implementation mandate to a permanent, innovation-led infrastructure for the UK’s financial sector.
The Mandate: Redefining the Future Entity
The "Future Entity" is a placeholder title for the body that will replace the Open Banking Implementation Entity (later rebranded as Open Banking Limited). Unlike its predecessor, which was born out of a specific competition mandate, the Future Entity is being established as a permanent, non-profit organization under the direct, statutory oversight of the Financial Conduct Authority (FCA).
The body is charged with four core pillars of operation:
- Standard Setting: Maintaining and evolving the technical APIs that allow for secure data sharing.
- Performance Monitoring: Ensuring high uptime and reliability across the UK banking infrastructure.
- Directory Services: Managing the secure registry of authorized third-party providers (TPPs).
- Certification: Overseeing compliance and security standards for participants in the ecosystem.
For the industry, this represents a move toward institutional maturity. By embedding the entity into the FCA’s regulatory framework, the UK government aims to ensure that open banking is no longer treated as a temporary project but as a foundational utility for the British economy.
Chronology: From CMA9 to Statutory Maturity
To understand the significance of this transition, one must look at the evolution of the UK open banking journey:
- 2016–2017: The CMA mandates the nine largest UK retail banks (the “CMA9”) to open their data via standardized APIs following a market investigation into the dominance of legacy incumbents.
- 2018: Open Banking Limited (OBL) is established to implement these requirements. The UK introduces PSD2-compliant APIs, setting a global benchmark for banking competition.
- 2020–2023: Adoption grows exponentially, reaching over 11 million monthly active users. However, the industry begins to hit the limits of the original CMA order, which focused primarily on basic account information and payments.
- 2024: The UK government announces the Data (Use and Access) Act, providing the legal mechanism to transition oversight from the CMA to the FCA.
- 2025: The appointment of Ezechi Britton marks the formal commencement of the design phase for the permanent "Future Entity."
Ezechi Britton: A Proven Architect of Fintech
Ezechi “Ez” Britton, who was awarded an MBE in 2022 for his services to diversity and young people in technology, arrives at the steering group with a multi-disciplinary background. As the former founding CEO of the Centre for Finance, Innovation and Technology (CFIT), Britton was instrumental in translating the findings of the Kalifa Review of UK Fintech into tangible industry policy.
His experience spans the entire spectrum of the fintech lifecycle—from co-founding the fintech lender Neyber to his work as a venture capitalist and software engineer. Industry observers suggest that Britton’s appointment is strategic; his ability to bridge the gap between regulatory requirements and commercial viability will be tested as he negotiates the needs of over 30 banks, fintechs, and payment service providers currently participating in the design coalition.
Supporting Data: The Case for Transformation
The urgency of this structural change is rooted in the overwhelming success—and the resulting technical strain—of the UK’s open banking ecosystem.
- Usage Velocity: The UK has moved from zero to 11 million active monthly users in less than seven years.
- Economic Impact: Thousands of third-party providers are now building products on top of open banking rails, ranging from personal finance management (PFM) tools to sophisticated B2B accounting platforms.
- The Funding Gap: Under the original OBL model, funding was provided by the CMA9 banks. As the ecosystem expands, a new, equitable funding model is required to ensure that all participants—not just the legacy incumbents—contribute to the maintenance of the infrastructure.
- Technical Scalability: The current API architecture, while functional, requires a more permanent governance structure to accommodate the transition from "read-only" data sharing to complex, real-time "write" capabilities.
The Strategic Shift: Beyond Static Data
The transition to the Future Entity is not merely administrative; it is a pivot toward a high-performance, real-time payment ecosystem. The most anticipated development in this roadmap is the scaling of Variable Recurring Payments (VRPs).
From Sweeping to Commercial Utility
First-generation open banking focused on "sweeping"—the ability for a customer to automatically move money between their own accounts to optimize interest or avoid overdrafts. The Future Entity is tasked with establishing the standards for "commercial VRPs" (cVRP).
Commercial VRPs allow consumers to authorize businesses to take payments from their bank accounts on a recurring basis, with limits and durations defined by the user. This creates a powerful alternative to card network payments, offering:
- Lower Fees: By bypassing the card schemes, businesses can avoid significant interchange and processing fees.
- Real-time Liquidity: Payments are settled near-instantly, improving cash flow for merchants and retailers.
- Consumer Protection: Unlike legacy Direct Debits, cVRPs offer granular control, allowing users to pause, cancel, or modify payments directly within their banking app.
Implications for the Financial Sector
The establishment of the Future Entity under the Data (Use and Access) Act 2025 carries profound implications for the future of British finance.
1. Regulatory Certainty
For fintechs, the move to an FCA-supervised body provides the long-term certainty required to raise capital and scale operations. Investors have historically been cautious about the "cliff edge" of the CMA9 mandate; the new statutory framework removes this uncertainty, effectively signaling that open banking is a permanent, government-backed pillar of the UK financial market.
2. The Dawn of "Open Finance"
While open banking focused on payment accounts, the mandate for the Future Entity includes laying the groundwork for "Open Finance." This expanded scope will eventually encompass pensions, insurance, mortgages, and wealth management. By standardizing these verticals, the UK aims to create a holistic view of a citizen’s financial health, enabling smarter, AI-driven financial advice and personalized products.
3. A Competitive Global Hub
The UK is currently competing with jurisdictions like the EU (via PSD3/PSR), Brazil, and Australia, all of which are iterating on their own open finance models. The creation of the Future Entity serves as a defensive and offensive move, ensuring the UK remains the global leader in technical standards and regulatory innovation.
Conclusion: A New Chapter
As Ezechi Britton steps into his role, he inherits a legacy of success that has fundamentally altered how consumers interact with their money. However, the challenges ahead—governance, funding, and the technical complexity of expanding into open finance—are significant.
The Future Entity is more than just an administrative replacement for OBL; it is the infrastructure for the next decade of UK financial services. By shifting toward a model that balances commercial innovation with robust, regulator-monitored safety, the UK is ensuring that its open banking experiment becomes a permanent, sustainable, and thriving reality for millions of users. As the design steering group begins its work, the eyes of the global fintech community will be firmly fixed on London, watching to see how the next iteration of the open finance revolution takes shape.
