Joint Regulatory Oversight Committee’s (JROC) proposals for the design of the Future Entity for UK open banking - Which? response

JROC must mandate adequate levels of consumer representation in Open Banking governance. This will help to ensure decisions deliver good consumer outcomes. As it considers next steps for Open Banking, and how to make the transition to the Interim and Future Entity and beyond (e.g. to open finance and other smart data schemes), JROC must ensure that there is an appropriate level of consumer representation and that consumer interests are taken into account. There should be a consumer representative on the Appointments Committee, and also on the Board of both the Interim and Future Entity. In addition, the entire Board of the Interim and Future Entity should be tasked with delivering good consumer outcomes.

The funding model for the Future Entity must be equitable and sustainable, but should also enable wide access to open banking e.g. for charities and academic institutions. We strongly support the proposal that there should be an 'exempt' Third Party Provider (TPP) category to enable those TPPs that are not able to pay commercial rates for access. Such an approach is essential to ensure open banking continues to democratise access to data.