Scope of ecosystem audit

The ecosystem audit is a core part of the analysis driving the Immediate Outcomes and is summarised in Section 4. This appendix provides additional detail on the scope.

It is observable that the open banking ecosystem is becoming more complex with a number of models being used to bring products and services to market. Our analysis focuses on one part of this market. Other parts of the market which are not included are:


There are a number of agents of Account Information Service Providers (AISPs) registered with the FCA (although not all of these may be live to market). Operating as an agent of an AISP provides an alternative route to market for some participants.

Third Parties Not Providing Account Information Services (TPNPA):

A number of TPNPAs have been provisionally identified. These firms receive data from regulated AISPs, but do not act as regulated AISPs themselves.

Technical Service Providers (TSP):

By definition a Technical Service Provider does not offer a service to the end user and is therefore not included in this analysis. It is however clearly a powerful enabler of market development that such firms exist to support regulated parties bringing products and services to market.

We do not include Agents, as the OBIE has no direct relationship with agents as they are not on the Directory. TPNPAs are not included in this analysis as there is currently no available data source which would allow us to quantify their role or the number of products and services which they provide. Any arrangement between an AISP and a TPNPA to onward share data is confidential. TSPs are excluded as they do not provide a product or service to the end user, but are nonetheless important enablers of ecosystem growth.

It is worth noting that a single organisation can operate under all models. One organisation can act as a Third Party Provider (TPP) with a direct to end user proposition, a TPP which onward shares data to a TPNPA, a principle of one or more agents and a TSP. It is understood that some organisations do indeed operate in all 4 capacities.

In future iterations, the CEF could be expanded to include Agents and TPNPAs, however there are considerable practical constraints in doing so which would need to be overcome. This limitation should be considered in reviewing the results below.

Outcome areas


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