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This is the Open Data Institute (ODI)’s response to the Competition and Markets Authority (CMA) consultation on The future oversight of the CMA’s open banking remedies.

In this response, we focus on the desire to see the ‘Future Entity’ stewarding the open banking initiative to be a sustainable and trustworthy data institution – an organisation that stewards data infrastructure on behalf of others, towards public, educational or charitable aims. In particular, the Future Entity would steward open data standards and guidelines to drive competition and innovation in the retail banking and finance sector.

Our general views on the future oversight of open banking and the CMA proposals include that:

  • The Future Entity should have a vision and mission that recognises and incorporates its impact beyond the banking and finance system.
  • The Future Entity should strive to balance its needs for sustainability against its mission and prioritise the sustainability model that allows for the most equitable outcomes.
  • The Future Entity should strive to be a trusted and trustworthy data institution with a commitment to openness and transparency.
  • Open banking is an ongoing data access initiative that will require pronounced changes in culture and practices. The Future Entity has a significant leadership role to play within the sector, particularly in ensuring that those involved have the necessary capabilities and data literacy.
  • We also stress that any commitment to being ‘at the heart of the Open Data and Payments market’ should include the publication of data under an open licence and enable participants in the market to do so as well. Failure to do this will mean the advantages of open data will fail to be realised by the ecosystem and undermines wider national and international efforts for open data.

You can read the ODI's consultation response, submitted in March 2021, below.

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