APPENDIX

Scope of ecosystem audit

The Ecosystem Audit is a core part of the analysis driving the immediate outcomes and is summarised in Section 3. This appendix provides additional detail on the scope.

It is clear the open banking ecosystem is becoming more complex, and several models are 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:

Agents: there are several agents of 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 AIS (TPNPA): Several TPNPAs have been provisionally identified. These firms receive data from regulated AISPs, but do not act as regulated AISPs themselves.

Technical Service Providers (TSPs): TSPs do not offer a service to the end-user, so are not included in this analysis. It is, however, clearly a powerful enabler of market development that these firms support regulated parties bringing products and services to market.

We do not include agents, as they are not on the Directory. TPNPAs are not included in this analysis as there is 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 they are nonetheless important enablers of ecosystem growth. In future iterations, the Impact Report could be expanded to include agents and TPNPAs. However, there are practical constraints in doing so which would need to be overcome. This limitation should be considered in reviewing the results in Section 3.

Outcome areas

Theory of Change model

The Impact Report is based on a Theory of Change – consistent with methodological approaches used to evaluate the intended impacts of policy interventions. It helpfully illustrates the progressive intermediate steps required to achieve the ultimate desired goals. The Theory of Change established three key components that it is important to measure:

Outputs and immediate outcomes (availability and awareness)

a necessary first step to achieving ultimate outcomes is availability, awareness and positive perceptions of open banking-enabled products and services. However, there is consensus that customer awareness of open banking technology is less important than awareness of open banking-enabled propositions and services.

Intermediate outcomes (experience)

the second step is customer adoption and a positive experience of open banking-enabled products and services that meet their needs.

Ultimate outcomes (benefits)

the third step is that customers experience sustained benefits from being able to access and use open banking-enabled products and services in a way that improves their financial position.

In the first Impact Report, we set out six customer outcome areas that provide a comprehensive, but concise categorisation of the customer objectives of open banking, as set out in the CMA Order.

Our Ecosystem Audit analysis continues to demonstrate that, with very few exceptions, the propositions in market consistently fall within these categories. These outcome areas are shown in Appendix 4.

We anticipate that the accuracy of the measures will improve in future Impact Reports as we develop new data sets, commission additional research, and with the continued growth of the ecosystem. A critical mass of customers using open banking-enabled services is a key prerequisite to drawing any reliable conclusions as to ultimate customer outcomes.