The UK’s financial landscape is on the precipice of a structural evolution. With the passage of the Data (Use and Access) Act 2025, the foundational framework that launched the nation’s world-leading open banking ecosystem—the Competition and Markets Authority (CMA9) mandate—is officially sunsetting. In its place, a new, permanent regulatory body, provisionally titled the "Future Entity," is being forged to steer the next decade of financial innovation.
In a pivotal development, Ezechi “Ez” Britton has been appointed as the independent chair of the Future Entity Design Steering Group. A seasoned fintech veteran and former CEO of the Centre for Finance, Innovation and Technology (CFIT), Britton is tasked with navigating the transition from a government-mandated remedial regime to a self-sustaining, industry-funded ecosystem under the direct supervision of the Financial Conduct Authority (FCA).
The Main Facts: A New Chapter for Open Banking
The appointment of Britton marks the beginning of the end for the legacy Open Banking Implementation Entity (OBIE), later rebranded as Open Banking Limited (OBL). The Future Entity is not merely a name change; it is a fundamental redesign of how the UK manages financial data and payment infrastructure.
The core mandate of the Future Entity is to consolidate the roles currently performed by OBL—including standard-setting, performance monitoring, directory services, and certification—into a single, robust organization. As a non-profit, FCA-supervised body, it will serve as the engine room for the UK’s transition into "Open Finance," a broader vision where the principles of secure data sharing extend beyond retail current accounts to include mortgages, pensions, insurance, and investment portfolios.
Britton’s role is to shepherd a coalition of over 30 leading financial institutions, fintech disruptors, and payment service providers. Together, they must draft the blueprint for the entity’s governance, funding mechanisms, and technical roadmap, ensuring that the UK maintains its competitive edge in the global fintech arena.
Chronology: From CMA9 to the Future Entity
To understand the weight of Britton’s appointment, one must look at the trajectory of UK financial regulation over the past decade.
2017–2018: The CMA9 Mandate
The story began in 2017, when the Competition and Markets Authority issued a landmark order requiring the UK’s nine largest banks (the CMA9) to open their APIs to third-party providers. This was a corrective measure designed to break the monopoly held by traditional incumbents and foster competition. The OBIE was established to implement these standards.
2021–2023: The Kalifa Review and CFIT
As the initial regulatory mandate matured, industry leaders recognized that the "remedial" nature of the CMA9 order was insufficient for long-term growth. The 2021 Kalifa Review of UK Fintech provided the strategic roadmap for the next phase, leading to the creation of the Centre for Finance, Innovation and Technology (CFIT), where Britton served as founding CEO. CFIT bridged the gap between policy, academia, and industry, proving that the sector was ready to scale beyond the initial mandates.
2024–2025: The Data (Use and Access) Act
The passage of the Data (Use and Access) Act 2025 provided the legislative teeth required to move away from the CMA order. By transitioning oversight to the FCA, the government signaled that open banking is no longer a temporary experiment but a permanent pillar of the UK financial infrastructure.
2025 and Beyond: The Future Entity
With the design phase now underway, the steering group led by Britton aims to finalize the organizational structure of the Future Entity. The transition is expected to be a phased hand-off, ensuring that the critical APIs supporting 11 million monthly users remain stable throughout the migration.
Supporting Data: Why the Transition is Necessary
The argument for the Future Entity is supported by compelling usage statistics. Since its inception, the UK’s open banking framework has achieved critical mass.
- User Adoption: Over 11 million active monthly users now rely on open banking services, ranging from personal finance management apps to automated payment services.
- Market Penetration: The initial CMA9 focus on retail banking covered approximately 90% of current accounts. However, this focus ignored the vast majority of financial services, including wealth management and lending.
- Economic Impact: The transition to the Future Entity is designed to unlock "commercial account-to-account" (A2A) rails, which experts estimate could save the UK economy billions in transaction fees annually by bypassing traditional, high-cost card networks.
The current model, while successful, is hindered by the limitations of its founding mandate. The Future Entity will be empowered to standardize data protocols across a much wider array of financial products, removing the "silo effect" that has hampered earlier attempts at integrated financial health monitoring.
Implications: The Rise of Commercial VRPs
Perhaps the most significant technical challenge—and opportunity—facing Britton’s steering group is the scaling of Variable Recurring Payments (VRPs).
VRPs represent the evolution of the Direct Debit. While the first wave of "sweeping" VRPs focused on moving money between a customer’s own accounts (e.g., topping up a savings account), the next frontier is Commercial VRPs (cVRPs).
The cVRP Advantage
For the consumer, cVRPs offer granular control. Instead of a rigid, unpredictable Direct Debit, a customer can set parameters—such as "pay my utility bill only when it is under £150"—providing unprecedented liquidity management. For merchants, the benefits are even more profound. By facilitating direct account-to-account payments, cVRPs eliminate the need for interchange fees charged by card schemes, which can cost merchants between 0.5% and 3% per transaction.
The Future Entity will be responsible for setting the technical uptime standards and security protocols that will make cVRPs a reliable, mainstream payment method. This is not just a technological upgrade; it is a shift in the power dynamic of the UK payments market, moving toward a more efficient, real-time settlement environment.
Leadership and Philosophy: The Britton Approach
Ezechi Britton’s appointment is widely viewed as a strategic choice. Unlike a traditional bureaucrat, Britton brings the mindset of a venture builder and a software engineer. His tenure at CFIT was defined by his ability to build consensus among disparate stakeholders, a skill that will be tested as he mediates between risk-averse incumbent banks and aggressive, high-growth fintechs.
In his previous roles, Britton has been a vocal advocate for diversity and inclusion in the financial sector, famously receiving an MBE in 2022 for his contributions to the field. His leadership style is expected to favor transparency and interoperability, core values that will be essential as the Future Entity establishes its funding model—a process that will require banks and third-party providers to agree on the long-term financial viability of the infrastructure they all share.
Conclusion: Securing the Future of Finance
The creation of the Future Entity, guided by the steady hand of Ezechi Britton, is the final hurdle in the UK’s transition to a mature open data economy. By moving from a restrictive, mandate-driven era to an industry-led, regulated framework, the UK is positioning itself to remain at the forefront of global financial innovation.
As the steering group begins its work, the eyes of the global financial community are fixed on London. The challenge is immense: balancing the security of consumer data with the need for rapid, frictionless innovation. However, with the legal framework of the Data (Use and Access) Act now in place and a clear mandate to drive commercial A2A rails, the Future Entity is poised to become the definitive architecture of the 21st-century financial system. The transition will be complex, but for an industry that has already redefined the relationship between banks and consumers, it is a necessary leap into the next generation of financial services.
